Gibson Vs Maryland Joint Appendix

USCA4 Appeal: 23-1369 Doc: 44 Filed: 07/31/2023 Pg: 1 of 482
NO. 23-1369
In The
United States Court Of Appeals

For The Fourth Circuit
LOIS ANN GIBSON; MARYLAND 20-20 WATCH, FREDERICK, MARYLAND;
CLASS REPRESENTATIVES PURSUANT TO FEDERAL RULE OF CIVIL PROCEDURE 23,
AND/OR PUTATIVE CLASSES OF SIMILARLY SITUATED V OTERS OF MARYLAND
AND/OR ELSEWHERE I N THE UNITED STATES OF AMERI CA; ALL OTHERS
SIMILARLY SI TUATED INJURED PERSONS, I N WHATEVER STATE O R COUNTY THEY
RESI DE, DEPRIVED OF THEI R CO NSTI TUTIONALLY GUARANTEED, FREEDO M,
LIBERTY, EXPRESSION AND RIGHT TO AN EFFECTIVE VOTE BY THE ACTS O R
ACTIONS OF THE DEFENDANTS H EREI N,
Plaintiffs – Appellants,
v.
THE STATE OF MARYLAND and Several Agencies of the Stat e, Including at least t he State
and County Boards of Elections in the Specific Counties Listed herein; A STATE AND
NATIONAL RICO ENTERPRISE, I N PART LOCATED I N MARYLAND, AND/OR DOING
BUSI NESS AS PART OF THE COMMERCE IN MARYLAND WITH COUNTI ES, I .E.,
FREDERICK, HOWARD COUNTY, CARROLL CO UNTIES, MARYLAND AND
18 ADDI TIONAL COUNTIES OR VOTING JURISDI CTIONS; CENTER FOR TECH AND
CIVIC LI FE ( CTCL), A Chicago IRS Code 501 (c) (3) Corporation; PRESENTLY
UNKNOWN DEFENDANTS; TH E STATE OF MARYLAND OFFICE OF THE STATE
PROSECUTOR;KENT COUNTY BOARD OF ELECTIONS; CALVERT COUNTY;
WASHINGTON COUNTY; HOWARD CO UNTY, MARYLAND; CARRO LL COUNTY,
MARYLAND; ANNE ARUNDEL CO UNTY; HARFORD COUNTY;
MONTGOMERY CO UNTY; PRI NCE GEORGE'S COUNTY,
Defendants – Appellees.
ON APPEAL FROM THE UNITED STATES DISTRICT COURT

FOR THE DISTRICT OF MARYLAND AT BALTIMORE
______________
JOINT APPENDIX
______________
Walter T. Charlton, I Daniel M. Kobrin Wendy L. Shiff

WALTER T. CHARLTON & OFFICE OF THE ATTORNEY OFFICE OF THE ATTORNEY
ASSOCIATES GENERAL OF MARYLAND GENERAL OF MARYLAND
P. O. Box 370 200 Saint Paul Place 200 Saint Paul Place
Woodsboro, MD 21798 20th Floor 20th Floor
(410) 571-8764 Baltimore, MD 21202 Baltimore, MD 21202
charltonwt@comcast.net (410)576-6472 (410) 576-6996
dkobrin@oag.state.md.us wshiff@oag.state.md.us
Counsel for The State of Counsel for State of Maryland
Maryland - Appellee Prosecutors' Office – Appellee
Counsel for Appellants
Additional Counsel listed on Back Cover
GibsonMoore Appellate Services, LLC

206 East Cary Street ♦ P.O. Box 1460 (23218) ♦ Richmond, VA 23219
804-249-7770 ♦ www.gibsonmoore.net
NO. 23-1369
Philip E. Culpepper Edward B. Lattner

ANNE ARUNDEL COUNTY OFFICE OF THE COUNTY ATTORNEY
OFFICE OF LAW Executive Office Building
2660 Riva Road 101 Monroe Street
4th Floor 3rd Floor
Annapolis, MD 21401 Rockville, MD 20850
(410) 222-4209 (240) 777-6735
lwculp00@aacounty.org edward.lattner@montgomerycountymd.gov
Counsel for State and National Rico Enterprise; Counsel for State and National Rico Enterprise;
Anne Arundel County – Appellees Montgomery County – Appellees
Guy S. P. Maydieu David M. Wyand

PRINCE GEORGE'S COUNTY OFFICE OF LAW ROSENBERG MARTIN GREENBERG, LLP
1301 McCormick Drive 25 South Charles Street
Suite 4100 Suite 2115
Largo, MD 20774 Baltimore, MD 21202
(301) 952-4229 (410) 727-6600
gsmaydieu@co.pg.md.us dwyand@rosenbergmartin.com
Counsel for State and National Rico Enterprise; Counsel for State and National Rico Enterprise;
Prince George's County - Appellees Harford County - Appellees
Kevin B. Karpinski Elizabeth L. Adams

KARPINSKI, CORNBROOKS & KARP, PA HOWARD COUNTY OFFICE OF LAW
120 East Baltimore Street 3450 Courthouse Drive
Suite 1850 Carroll Building
Baltimore, MD 21202 Ellicott City, MD 21114
(410) 727-5000 (410) 313-1120
kevin@bkcklaw.com eladams@howardcountymd.gov
Counsel for Kent County Board of Elections; Counsel for Howard County-Appellee
Calvert County; Washington County;
Carroll County - Appellees
TABLE OF CONTENTS
Page:
District Court Docket Sheet [1:22-cv-01642-SAG] ...................................... JA1
Complaint,
With Exhibits,
filed July 5, 2022 [DE1]......................................................................... JA18
Plaintiffs’ Emergency Motion for a

Temporary Restraining Order and Preliminary Injunction
Preventing Destruction of Evidence,
With Attachments,
filed July 5, 2022 [DE2]......................................................................... JA85
Attachments:
1. Proposed Order [DE2-1] ............................................................ JA87
2. Memorandum of Points and Authorities in Support of

Emergency Temporary Restraining Order (TRO) and
Preliminary Injunction
filed July 5, 2022 [DE2-2]................................................. JA96
Order
Denying Plaintiffs' Motion for
Temporary Restraining Order
filed July 6, 2022 [DE4]....................................................................... JA112
Plaintiffs’ Motion to Alter and Amend the Denial of a TRO

or Alternatively, for an Expedited Hearing or
Trial on a Preliminary Injunction to Avoid Immediate,
Vital and Irreparable Harm from Per Se Election Fraud,
filed August 2, 2022 [DE6] ................................................................. JA116
i
Order
Denying Plaintiffs' Motion to Reconsider; and
Granting in Part and Denying in Part Motion to Correct
filed August 5, 2022 [DE7] ................................................................. JA131
Amended Complaint,
With Exhibits,
filed August 20, 2022 [DE9] ............................................................... JA136
Exhibits:
1. Grants to 21 Maryland Counties and

Baltimore City [DE9-1] ............................................................ JA179
2.1 Declaration of Lois Ann Gibson

sworn June 16, 2022 [DE1-2] ......................................... JA181
2.2 Redacted Declaration,

dated May 17, 2022 [DE9-3] .......................................... JA183
2.3 Declaration of Jean-Elizabeth Ellis [DE9-4] ........................ JA185
3. Declaration of Newly Non-Resident, Kurt Kolb,

Regarding Automated Voter Harvesting
dated June 23, 2022 [DE9-5] .......................................... JA186
4. Frederick and Carroll County

Grant Contracts, with Terms
dated September 25, 2020 [DE9-6] ................................ JA189
5. Howard County, List of Payments [DE9-7] ......................... JA195
6. Mail-In Ballot Requests by County

dated July 17, 2022 [DE9-8] ........................................... JA209
ii
Exhibits to
Amended Complaint,
filed August 20, 2022 [DE9], Continued:
7. Mail-in Ballot Requests by County

dated November 3, 2020 [DE9-9] ................................. JA210
8. Verification of Harford County Canvas of 2020

dated August 1, 2022 [DE9-10] ..................................... JA211
9. Verification Report, Ballot Images and

Fake Surveillance Camera Report
dated May 26, 2022 [DE] ................................................ JA213
10. Curriculum Vitae, Dr. Douglas G. Frank

dated August 17, 2022 [DE9-12] ................................... JA215
10A. Description of the Specificity Requirements of

Both the Rico Statute [DE9-13]............................................... JA219
10B. Supreme Court Rule

in Boyle v. United States [DE9-14] ......................................... JA221
Third Motion for a Temporary

Restraining Order, Preliminary Injunction and
Acceleration of Trial on The Merits,
With Exhibits,
filed November 9, 2022 [DE37] ......................................................... JA222
Exhibits:
A. Letter from Linda Lamone

dated October 14, 2022 [DE37-1] .................................. JA240
iii
Defendant State of Maryland’s Response in Opposition to

Motion for Temporary Restraining Order,
Preliminary Injunction and
Acceleration of Trial on the Merits
filed November 10, 2022 [DE38] ....................................................... JA247
Plaintiffs’ Reply Memorandum to Defendants’ State of

Maryland, The Maryland State Bord of Elections,
And Howard County
Memorandum Opinion
Order
Denying Motion for Temporary Restraining Order, Preliminary
Injunction, and Accelerated Trial on The Merits
Plaintiff’s Memorandum in Opposition to Defendants State of

Maryland, All Counties Filing Motions to Dismiss, and Other Parties
Filing Motions to Dismiss on Same Grounds
Defendants’ Reply to Plaintiffs’ Opposition to

Defendants’ Motions to Dismiss
filed December 6, 2022 [DE66] ......................................................... JA307
iv
Motion to Alter and Amend the Order Dismissing this Case;

or Alternatively; to Reopen, Receive New Testimony,
Amend Findings, Conclusions, Mandates, or
Judgments as a Matter of Law (JMOL),
With Exhibit,
filed January 13, 2023 [DE74] ............................................................ JA321
Exhibit:
A. Affidavit
Concerning Maryland Midterm Election at Ballenger Creek
Elementary School
dated November 20, 2022 [DE74-1] ............................. JA350
C. Affidavit of Lisa Batsch Smith

dated January 13, 2023 [DE74-3] .................................. JA352
Defendant Maryland State Board of Elections

Opposition to Rule 59(E) Motion to Alter and
Amend the Order Dismissing this Case
filed January 23, 2023 [DE77] ............................................................ JA354
Reply to Defendants’ Oppositions to Rule 59(e) Motion to

Alter and Amend the Order Dismissing this Case
filed February 21, 2023 [DE93].......................................................... JA363
Plaintiffs’ Motion to Transfer this Case to the

Multidistrict Litigation Court and Panel (MDL),
With Attachment,
filed February 23, 2023 [DE94].......................................................... JA371
Attachment:
X-1. Lisa Batsh-Smith CV

dated February 22, 2023 [DE94-1] ................................ JA384
v
Exhibits to
Plaintiffs’ Motion for a Preliminary Injunction
and to Supplement the Record for Newly Discovered
Material Evidence of Fraud, Money Laundering
With (Likely) National Security Ramifications,
filed March 17, 2023 [DE95]:
X-2. Excerpts of Maryland Campaign Finance

Review Methodology [DE95-3] ............................................ JA385
X-3. Excerpts of The Big Cheat RICO Enterprise Data

MD & Selected States [DE95-4] ............................................ JA386
Y-1. Excerpts of MD CTCL Grant Amounts &

MD Blank Ballots Cast EL45A Data [DE95-6] .................... JA398
Plaintiffs’ Motion for a Preliminary Injunction

and to Supplement the Record for Newly Discovered
Material Evidence of Fraud, Money Laundering
filed March 19, 2023 [DE96] .............................................................. JA401
Plaintiff’s Motion for Emergency Relief and for

Court's Corrective Action
filed March 23, 2023 [DE98] .............................................................. JA446
Memorandum Opinion
filed March 29, 2023 [DE101] ............................................................ JA450
Order
Denying Plaintiffs’ Motion to Amend Judgment
filed March 29, 2023 [DE102] ............................................................ JA455
vi
Notice of Appeal
filed April 1, 2023 [DE103] ................................................................ JA456
Order
Granting Motion to Supplement the Record
filed June 15, 2023 [DE109] ................................................................ JA466
vii
6/29/23, 11:02 AM District of Maryland (CM/ECF Live NextGen 1.6)
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APPEAL,CLOSED
U.S. District Court

District of Maryland (Baltimore)
CIVIL DOCKET FOR CASE #: 1:22-cv-01642-SAG
Gibson et al v. Frederick County Maryland et al Date Filed: 07/05/2022

Assigned to: Judge Stephanie A. Gallagher Date Terminated: 12/16/2022
Demand: $999,000 Jury Demand: Plaintiff
Case in other court: USCA, 23-01369 Nature of Suit: 440 Civil Rights: Other
Cause: 28:1331 Federal Question: Other Civil Rights Jurisdiction: Federal Question
Plaintiff
Lois Ann Gibson represented by Walter T Charlton
Walter T Charlton and Associates
213 Morgan St
Washington, DC 20001
4105718764
Fax: 12026598382
Email: charltonwt@comcast.net
LEAD ATTORNEY
ATTORNEY TO BE NOTICED
Plaintiff
Maryland 20-20 Watch represented by Walter T Charlton
a Private Unincorporated Association of (See above for address)
Maryland Citizens and Voters in MD LEAD ATTORNEY
Plaintiff
Amicus Curia represented by Walter T Charlton
(See above for address)
LEAD ATTORNEY
Plaintiff
Charlton Scientific Educational and represented by Walter T Charlton
Engineering Foundation Inc. (See above for address)
LEAD ATTORNEY
Plaintiff
A Committee of Injured Ciitzens/Voters represented by Walter T Charlton
for Themselves and All Others Similarly (See above for address)
Situated LEAD ATTORNEY
Putative Class of similarly situated Voters ATTORNEY TO BE NOTICED
of ) of Maryland who are Similarly
Situated
https://ecf.mdd.uscourts.gov/cgi-bin/DktRpt.pl?112113859894867-L_1_0-1 1/17
JA1
Plaintiff
Any, Presently Unknown State Agency represented by Walter T Charlton
which was Duped by the Multiple (See above for address)
Frauds Alleged herin LEAD ATTORNEY
Plaintiff
All Others Similarly Situated Injured represented by Walter T Charlton
Persons (See above for address)
LEAD ATTORNEY
V.
Defendant
Frederick County Maryland
Defendant
Howard County Maryland represented by Cynthia Grams Peltzman
Howard County Office of Law
3450 Court House Drive
Ellicott City, MD 21043
14103133074
Fax: 14103133292
Email: cpeltzman@howardcountymd.gov
Defendant
Carroll County Maryland represented by Kevin Bock Karpinski
Karpinski, Cornbrooks & Karp, P.A.
120 East Baltimore Street
Suite 1850
Baltimore, MD 21202-1617
410-727-5000
Fax: 410-727-0861
Email: kevin@bkcklaw.com
LEAD ATTORNEY
Defendant
Alleghany County represented by Terry L Beeman , Jr
Buckel, Levasseur, Pillai & Beeman, LLC
206 Washington Street
Cumberland, MD 21502
301-759-3700
Fax: 301-722-0334
Email: lee@beemanlawoffices.com
LEAD ATTORNEY
Defendant
JA2
Anne Arundel County represented by Philip E Culpepper

Anne Arundel County Office of Law
2660 Riva Road
4th Floor
Annapolis, MD 21401
14102227888
Fax: 14102227835
Email: lwculp00@aacounty.org
LEAD ATTORNEY
Defendant
Baltimore City
Defendant
Baltimore County represented by AARON L KELLY
Baltimore County, Maryland
400 Washington Avenue, Room 219
Ste 219
Towson, MD 21204
410-887-4420
Email: akelly1@baltimorecountymd.gov
Bambi C B Glenn
1722 Charmuth Rd
Lutherville, MD 21093
14102523012
Email: bglenn@baltimorecountymd.gov
Defendant
Calvert County represented by Kevin Bock Karpinski
LEAD ATTORNEY
Defendant
Caroline County represented by Andrew Charles Meehan
MacLeod Law Group, LLC
120 Speer Road
Suite 1
Chestertown, MD 21620
14108101381
Fax: 14108101383
Email: ameehan@mlg-lawyers.com
LEAD ATTORNEY
Defendant
Cecil County represented by Justin Bryan Hill
Law Office of Justin B. Hill, LLC
213 East Main Street
JA3
Elkton, MD 21921
410-324-7574
Email: justin@jbhlawoffice.com
LEAD ATTORNEY
Defendant
Charles County
Defendant
Dorchester County represented by Andrew Charles Meehan
LEAD ATTORNEY
Defendant
Garret County represented by Gorman E Getty , III
Gorman E Getty III PA
PO Box 1485
23 Washington St
Cumberland, MD 21502
13017778032
Fax: 13017777048
Email: ggetty@ggettylaw.com
Defendant
Harford County represented by David Matthew Wyand
Rosenberg Martin Greenberg LLP
25 S Charles St Ste 2115
Baltimore, MD 21201
14107276600
Fax: 14107271115
Email: dwyand@rosenbergmartin.com
LEAD ATTORNEY
Defendant
Howard County represented by Cynthia Grams Peltzman
Defendant
Kent County Board of Elections represented by Kevin Bock Karpinski
LEAD ATTORNEY
Defendant
Montgomery County represented by Edward Barry Lattner
Office of the County Attorney for
Montgomery County MD
101 Monroe St Third Fl
JA4
Rockville, MD 20850-2580
12407776735
Fax: 12407776705
Email:
Edward.Lattner@MontgomeryCountyMD.gov
LEAD ATTORNEY
Patricia Lisehora Kane

Office of the Montgomery County Attorney
101 Monroe St 3rd Fl
Rockville, MD 20850
12407776743
Fax: 12407776706
Email:
patricia.kane@montgomerycountymd.gov
Defendant
Prince George's County represented by Guy Saint Pol Maydieu
Prince George s County Office of Law
1301 McCormick Drive
Suite 4100
Largo, MD 20774
301-952-4229
Fax: 301-952-3071
Email: GSMaydieu@co.pg.md.us
LEAD ATTORNEY
Defendant
Queen Anne's County represented by Eric Sean Poltrack
Braden, Thompson, Poltrack, Mundy &
McQueeney LLP
102 St. Claire Place
Suite 2
Stevensville, MD 21666
4106434110
Fax: 4106040400
Email: spoltrack@bt-lawyer.com
LEAD ATTORNEY
Defendant
Talbot County represented by Andrew Charles Meehan
LEAD ATTORNEY
Defendant
Washington County represented by Kevin Bock Karpinski
JA5
LEAD ATTORNEY
Defendant
Wicomico County represented by Andrew N Illuminati
Webb, Cornbrooks, Wilber, Vorhis, Douse &
Mathers, LLP
115 Broad Street
Post Office Box 910
Salisbury, MD 21803-0910
410-742-3176
Fax: 410-743-0438
Email: ailluminati@webbnetlaw.com
LEAD ATTORNEY
Defendant
A RICO Enterprise, Containing the
State of Maryland
Other States Utilizing Unlawful
Conspiracies ) and/or Methodology to Rig
Votes, et al.
Defendant
Each unlawfully acting citizen, or RICO
Entity, or ) Federal or State
Government Employee
with the sole exception of those protected
by Government Immunity
Defendant
A Class of Similarly Situated
Defendants who are now known to have
accepted alleged Grant Money from
CTCL,
thereafter used such funds for unlawful )
purposes to influence election results and
continue to ) utilize such unlawful means
in the future
Defendant
Center for Tech and Civic Life (CTCL)
Defendant
Presently Unknown Defendants,
Expected to be Identified as both
Government Employees
or Private Persons Identified from
Documents Received from Government
Sources
Defendant
JA6
The State of Maryland represented by Daniel Michael Kobrin

Through its Departments Office of the Attorney General
Civil Litigation Division
200 Saint Paul Place
20th Floor
Baltimore, MD 21202
410-576-6472
Email: dkobrin@oag.state.md.us
LEAD ATTORNEY
Defendant
The Office of the State Prosecutor represented by Wendy L Shiff
who has Abrogated its Office by failing to Office of the Attorney General
Stamp Out RICO Enterprises in its 200 St. Paul Place 20th Fl
Jurisdiction, for Whatever Reason Baltimore, MD 21202
4105766996
Fax: 4105766955
Email: wshiff@oag.state.md.us
LEAD ATTORNEY
Date Filed # Docket Text

07/05/2022 1 COMPLAINT against A Class of Similarly Situated Defendants who are now known to
have accepted alleged Grant Money from CTCL,, A RICO Enterprise, Containing the
State of Maryland, Alleghany County, Anne Arundel County, Baltimore City, Baltimore
County, Calvert County, Caroline County, Carroll County Maryland, Cecil County,
Center for Tech and Civic Life (CTCL), Charles County, Dorchester County, Each
unlawfully acting citizen, or RICO Entity, or ) Federal or State Government Employee,
Frederick County Maryland, Garret County, Harford County, Howard County, Howard
County Maryland, Kent County Board of Elections, Montgomery County, Presently
Unknown Defendants, Expected to be Identified as both Government Employees, Prince
George's County, Queen Anne's County, Talbot County, The Office of the State
Prosecutor, The State of Maryland, Washington County, Wicomico County, filed by Any,
Presently Unknown State Agency which was Duped by the Multiple Frauds Alleged
herin, Louis Ann Gibson, A Committee of Injured Ciitzens/Voters for Themselves and All
Others Similarly Situated, Maryland 20-20 Watch, All Others Similarly Situated Injured
Persons, Amicus Curia, Charlton Scientific Educational and Engineering Foundation Inc..
(Attachments: # 1 Exhibit, # 2 Exhibit, # 3 Exhibit, # 4 Exhibit, # 5 Exhibit, # 6 Civil
Cover Sheet, # 7 Summons)(dm4s, Deputy Clerk) (Entered: 07/05/2022)
07/05/2022 2 MOTION for Temporary Restraining Order by A Committee of Injured Ciitzens/Voters
for Themselves and All Others Similarly Situated, All Others Similarly Situated Injured
Persons, Any, Presently Unknown State Agency which was Duped by the Multiple Frauds
Alleged herin, Charlton Scientific Educational and Engineering Foundation Inc., Amicus
Curia, Louis Ann Gibson, Maryland 20-20 Watch (Attachments: # 1 Text of Proposed
Order, # 2 Memorandum in Support)(dm4s, Deputy Clerk) (Entered: 07/05/2022)
07/05/2022 Filing fee: $ 402.00, receipt number 641 (kos, Deputy Clerk) (Entered: 07/05/2022)
07/05/2022 3 Summons Issued 21 days as to A Class of Similarly Situated Defendants who are now
known to have accepted alleged Grant Money from CTCL,, A RICO Enterprise,
Containing the State of Maryland, Alleghany County, Anne Arundel County, Baltimore
JA7
City, Baltimore County, Calvert County, Caroline County, Carroll County Maryland,
Cecil County, Center for Tech and Civic Life (CTCL), Charles County, Dorchester
County, Each unlawfully acting citizen, or RICO Entity, or ) Federal or State Government
Employee, Frederick County Maryland, Garret County, Harford County, Howard County,
Howard County Maryland, Kent County Board of Elections, Montgomery County,
Presently Unknown Defendants, Expected to be Identified as both Government
Employees, Prince George's County, Queen Anne's County, Talbot County, The Office of
the State Prosecutor, The State of Maryland, Washington County, Wicomico County.
(dm4s, Deputy Clerk) (Entered: 07/05/2022)
07/06/2022 4 ORDER denying 2 Plaintiffs' Motion for Temporary Restraining Order. Signed by Chief
Judge James K. Bredar on 7/6/2022. (bmhs, Deputy Clerk) (Entered: 07/06/2022)
08/01/2022 5 Supplemental MOTION re 3 Summons Issued,,, 1 Complaint,,,,, contained in Complaint,
but Omitted in Error from Summons list by Filer, by A Committee of Injured
Ciitzens/Voters for Themselves and All Others Similarly Situated, All Others Similarly
Situated Injured Persons, Any, Presently Unknown State Agency which was Duped by the
Multiple Frauds Alleged herin, Charlton Scientific Educational and Engineering
Foundation Inc., Amicus Curia, Louis Ann Gibson, Maryland 20-20 Watch (Attachments:
# 1 Summons To Correct List to Court, # 2 Summons To Correct List to Court, # 3
Summons To Correct List to Court, # 4 Summons To Correct List to Court)(Charlton,
Walter) (Entered: 08/01/2022)
08/02/2022 6 MOTION to Alter/Amend Judgment Denying TRO by A Committee of Injured
Ciitzens/Voters for Themselves and All Others Similarly Situated, All Others Similarly
Situated Injured Persons, Any, Presently Unknown State Agency which was Duped by the
Multiple Frauds Alleged herin, Charlton Scientific Educational and Engineering
Foundation Inc., Amicus Curia, Louis Ann Gibson, Maryland 20-20 Watch (Attachments:
# 1 Exhibit Exhibit 6, # 2 Exhibit Exhibit 7, # 3 Exhibit Exhibit 8, # 4 Exhibit Exhibit 9,
# 5 Amended Draft Order Injunctive)(Charlton, Walter) (Entered: 08/02/2022)
08/05/2022 7 ORDER denying 6 Plaintiffs' Motion to Reconsider; and granting in part and denying in
part 5 Motion to Correct; and directing the Clerk to issue summons for CTCL. Signed by
Judge George Levi Russell, III on 8/5/2022. (bmhs, Deputy Clerk) (Entered: 08/05/2022)
08/05/2022 8 Summons Issued 21 days as to Center for Tech and Civic Life (CTCL).(bmhs, Deputy
Clerk) (Entered: 08/05/2022)
08/20/2022 9 AMENDED COMPLAINT against All Plaintiffs, filed by A Committee of Injured
Ciitzens/Voters for Themselves and All Others Similarly Situated. (Attachments: # 1
Exhibit Exhibit 1, # 2 Exhibit Exhibit 2.1, # 3 Exhibit Exhibit 2.2, # 4 Exhibit Exhibit
2.3, # 5 Exhibit Exhibit 3, # 6 Exhibit Exhibit 4, # 7 Exhibit Exhibit 5, # 8 Exhibit
Exhibit 6, # 9 Exhibit Exhibit 7, # 10 Exhibit Exhibit 8, # 11 Exhibit Exhibit 9, # 12
Exhibit Exhibit 10, # 13 Exhibit Exhibit 10 A, # 14 Exhibit Exhibit 10 B)(Charlton,
09/01/2022 10 WAIVER OF SERVICE Returned Executed by Calvert County. Calvert County waiver
sent on 7/28/2022, answer due 9/26/2022.(Karpinski, Kevin) (Entered: 09/01/2022)
09/01/2022 11 WAIVER OF SERVICE Returned Executed by Washington County. Washington County
waiver sent on 7/28/2022, answer due 9/26/2022.(Karpinski, Kevin) (Entered:
09/01/2022)
09/13/2022 12 NOTICE by A Committee of Injured Ciitzens/Voters for Themselves and All Others
Similarly Situated (Attachments: # 1 Summons Draft-Needs Seal, # 2 Summons Draft-
Needs Seal, # 3 Summons Draft-Needs Seal)(Charlton, Walter) (Entered: 09/13/2022)
JA8
09/15/2022 13 Summons Issued 21 days as to Cecil County, The Office of the State Prosecutor, The
State of Maryland.(bmhs, Deputy Clerk) (Entered: 09/15/2022)
09/19/2022 14 MOTION to Dismiss for Failure to State a Claim by The State of Maryland
(Attachments: # 1 Memorandum in Support Memorandum of Law in Support)(Kobrin,
Daniel) (Entered: 09/19/2022)
09/20/2022 15 QC NOTICE: 14 Motion to Dismiss for Failure to State a Claim filed by The State of
Maryland was filed incorrectly.
**The following attachments or exhibits are missing - Proposed Order. To correct this
problem, file Proposed Order using the event Notice (Other) and link Proposed Order to
14 Motion. (bmhs, Deputy Clerk) (Entered: 09/20/2022)
09/20/2022 16 WAIVER OF SERVICE Returned Executed by Anne Arundel County. Anne Arundel
County waiver sent on 9/16/2022, answer due 11/15/2022.(Culpepper, Philip) (Entered:
09/20/2022)
09/20/2022 17 NOTICE by The State of Maryland re 14 MOTION to Dismiss for Failure to State a
Claim (Proposed Order) (Kobrin, Daniel) (Entered: 09/20/2022)
09/21/2022 18 MOTION to Dismiss the Amended Complaint by Calvert County, Washington County
(Attachments: # 1 Memorandum in Support, # 2 Text of Proposed Order)(Karpinski,
Kevin) (Entered: 09/21/2022)
09/22/2022 19 NOTICE of Appearance by Patricia Lisehora Kane on behalf of Montgomery County
(Kane, Patricia) (Entered: 09/22/2022)
09/22/2022 20 NOTICE of Appearance by Edward Barry Lattner on behalf of Montgomery County
(Lattner, Edward) (Entered: 09/22/2022)
09/22/2022 21 MOTION to Dismiss for Failure to State a Claim by Montgomery County (Attachments:
# 1 Memorandum in Support of Motion to Dismiss First Amended Complaint, # 2 Text of
Proposed Order Proposed Order)(Lattner, Edward) (Entered: 09/22/2022)
09/28/2022 22 NOTICE of Appearance by Andrew N Illuminati on behalf of Wicomico County
(Illuminati, Andrew) (Entered: 09/28/2022)
09/28/2022 23 MOTION to Dismiss First Amended Complaint by Wicomico County (Attachments: # 1
Memorandum in Support Memorandum in Support of Motion to Dismiss First Amended
Complaint, # 2 Text of Proposed Order Proposed Order to Dismiss)(Illuminati, Andrew)
(Entered: 09/28/2022)
09/28/2022 24 NOTICE of Appearance by Philip E Culpepper on behalf of Anne Arundel County
(Culpepper, Philip) (Entered: 09/28/2022)
09/28/2022 25 MOTION to Dismiss for Failure to State a Claim by Anne Arundel County (Attachments:
# 1 Memorandum in Support, # 2 Text of Proposed Order)(Culpepper, Philip) (Entered:
09/28/2022)
09/28/2022 26 MOTION to Dismiss for Failure to State a Claim by The Office of the State Prosecutor
(Attachments: # 1 Text of Proposed Order)(Shiff, Wendy) (Entered: 09/28/2022)
10/10/2022 27 Consent MOTION for Extension of Time to File Response/Reply by A Committee of
Injured Ciitzens/Voters for Themselves and All Others Similarly Situated.(Charlton,
10/11/2022 28 ORDER granting 27 Consent MOTION for Extension of Time to File Response/Reply .
Signed by Judge George Levi Russell, III on 10/11/2022. (kb3s, Deputy Clerk) (Entered:
10/11/2022)
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10/21/2022 29 MOTION to Dismiss for Failure to State a Claim by Harford County (Attachments: # 1
Text of Proposed Order)(Wyand, David) (Entered: 10/21/2022)
10/31/2022 30 NOTICE of Appearance by Gorman E Getty, III on behalf of Garret County (Getty,
Gorman) (Entered: 10/31/2022)
10/31/2022 31 MOTION to Dismiss by Garret County (Attachments: # 1 Memorandum in Support, # 2
Text of Proposed Order)(Getty, Gorman) (Entered: 10/31/2022)
11/07/2022 32 Second MOTION for Extension of Time to File Response/Reply as to 17 Notice (Other),
15 QC Notice - Miscellaneous, To Respond to pending Motion by defencants to dismiss
by A Committee of Injured Ciitzens/Voters for Themselves and All Others Similarly
Situated.(Charlton, Walter) (Entered: 11/07/2022)
11/08/2022 33 ORDER granting 32 Consent Motion for Extension of Time. Signed by Judge George
Levi Russell, III on 11/8/2022. (ols, Deputy Clerk) (Entered: 11/08/2022)
11/08/2022 34 MOTION to Dismiss for Failure to State a Claim by Howard County, Howard County
Maryland (Attachments: # 1 Memorandum in Support)(Peltzman, Cynthia) (Entered:
11/08/2022)
11/08/2022 35 QC NOTICE: 34 Motion to Dismiss for Failure to State a Claim filed by Howard County,
Howard County Maryland was filed incorrectly.
34 . (ols, Deputy Clerk) (Entered: 11/08/2022)
11/08/2022 36 NOTICE by Howard County, Howard County Maryland re 34 MOTION to Dismiss for
Failure to State a Claim Proposed Order (Peltzman, Cynthia) (Entered: 11/08/2022)
11/09/2022 37 Third MOTION for Temporary Restraining Order and Motion for Preliminary Injunction
and Transfer MDL, by A Committee of Injured Ciitzens/Voters for Themselves and All
Others Similarly Situated (Attachments: # 1 Exhibit Ex A and BLetter and Data Refuting)
(Charlton, Walter) (Entered: 11/09/2022)
11/09/2022 Case Reassigned to Judge Stephanie A. Gallagher. Judge George Levi Russell, III no
longer assigned to the case. (kns, Deputy Clerk) (Entered: 11/09/2022)
11/10/2022 38 RESPONSE in Opposition re 37 Third MOTION for Temporary Restraining Order and
Motion for Preliminary Injunction and Transfer MDL, (Proposed Order) filed by The
State of Maryland. (Attachments: # 1 Text of Proposed Order)(Kobrin, Daniel) (Entered:
11/10/2022)
11/11/2022 39 RESPONSE in Opposition re 37 Third MOTION for Temporary Restraining Order and
Motion for Preliminary Injunction and Transfer MDL, filed by Harford County.
(Attachments: # 1 Text of Proposed Order)(Wyand, David) (Entered: 11/11/2022)
11/14/2022 40 PAPERLESS ORDER Plaintiffs have filed a Motion for a Temporary Restraining Order,
Preliminary Injunction, and Acceleration of a Trial on the Merits. ECF 37. Defendants
State of Maryland and Harford County have filed responses in opposition. ECF 38; ECF
39. This Court orders that any reply by Plaintiffs is due by close of business tomorrow,
November 15th, 2022. If Plaintiffs do not wish to file a reply, they should inform this
Court as timely as possible. Signed by Judge Stephanie A. Gallagher on 11/14/2022.
(kc2s, Chamber) (Entered: 11/14/2022)
11/15/2022 41 REPLY to Response to Motion re 6 MOTION to Alter/Amend Judgment Denying TRO, 2
MOTION for Temporary Restraining Order, 37 Third MOTION for Temporary
Restraining Order and Motion for Preliminary Injunction and Transfer MDL, with
Summary of alleged voting malfunctions and maladministration filed by A Committee of
JA10
Injured Ciitzens/Voters for Themselves and All Others Similarly Situated. (Attachments:
# 1 Exhibit Incorrect statements of Administrator of State Board as to Accuracy of
System, # 2 Exhibit Rebuttal Data - Expert, # 3 Exhibit Expert testimony as to
Inaccuracies in alleged Fraud, # 4 Exhibit County Showing alleged mules and likely
bribes)(Charlton, Walter) (Entered: 11/15/2022)
11/15/2022 42 NOTICE by A Committee of Injured Ciitzens/Voters for Themselves and All Others
Similarly Situated re 41 Reply to Response to Motion,, To correct upload error Ex C-1
replaces Ex C. (Charlton, Walter) (Entered: 11/15/2022)
11/16/2022 43 MEMORANDUM OPINION. Signed by Judge Stephanie A. Gallagher on 11/16/2022.
(ols, Deputy Clerk) (Entered: 11/17/2022)
11/16/2022 44 ORDER denying 37 Plaintiffs' Motion for a temporary restraining order, preliminary
injunction, and accelerated trial on the merits. Signed by Judge Stephanie A. Gallagher on
11/16/2022. (ols, Deputy Clerk) (Entered: 11/17/2022)
11/17/2022 45 NOTICE of Appearance by Justin Bryan Hill on behalf of Cecil County (Hill, Justin)
(Entered: 11/17/2022)
11/17/2022 46 MOTION to Dismiss for Failure to State a Claim by Cecil County (Attachments: # 1 Text
of Proposed Order)(Hill, Justin) (Entered: 11/17/2022)
11/21/2022 47 NOTICE of Appearance by Andrew Charles Meehan on behalf of Talbot County
(Meehan, Andrew) (Entered: 11/21/2022)
11/21/2022 48 MOTION to Dismiss for Failure to State a Claim and Other Reasons by Talbot County
(Attachments: # 1 Memorandum in Support, # 2 Text of Proposed Order)(Meehan,
Andrew) (Entered: 11/21/2022)
11/21/2022 49 NOTICE of Appearance by Andrew Charles Meehan on behalf of Dorchester County
11/21/2022 50 MOTION to Dismiss for Failure to State a Claim and Other Reasons by Dorchester
County (Attachments: # 1 Memorandum in Support, # 2 Text of Proposed Order)
11/21/2022 51 NOTICE of Appearance by Andrew Charles Meehan on behalf of Caroline County
11/21/2022 52 MOTION to Dismiss for Failure to State a Claim and Other Reasons by Caroline County
(Attachments: # 1 Memorandum in Support, # 2 Text of Proposed Order)(Meehan,
Andrew) (Entered: 11/21/2022)
11/21/2022 53 QC NOTICE: 47 Notice of Appearance filed by Talbot County, 51 Notice of Appearance
filed by Caroline County, 49 Notice of Appearance filed by Dorchester County was filed
incorrectly.
**Each attorney must file their Notice of Appearance using their CM/ECF login in order
to be added as counsel to a case. Mr. Patrick W. Thomas should filed a Notice of
Appearance on his own behalf. (ols, Deputy Clerk) (Entered: 11/21/2022)
11/22/2022 54 NOTICE of Appearance by AARON L KELLY on behalf of Baltimore County (KELLY,
AARON) (Entered: 11/22/2022)
11/22/2022 55 MOTION to Dismiss for Failure to State a Claim by Baltimore County (Attachments: # 1
Memorandum in Support Memorandum in Support, # 2 Text of Proposed Order Proposed
Order)(KELLY, AARON) (Entered: 11/22/2022)
11/22/2022 56 NOTICE of Appearance by Terry L Beeman, Jr on behalf of Alleghany County (Beeman,
JA11
Terry) (Entered: 11/22/2022)

11/22/2022 57 MOTION to Dismiss for Failure to State a Claim by Alleghany County(Beeman, Terry)
(Entered: 11/22/2022)
11/23/2022 58 -FILED IN ERROR- RESPONSE in Opposition re 34 MOTION to Dismiss for Failure to
State a Claim, 48 MOTION to Dismiss for Failure to State a Claim and Other Reasons,
18 MOTION to Dismiss the Amended Complaint, 26 MOTION to Dismiss for Failure to
State a Claim, 14 MOTION to Dismiss for Failure to State a Claim, 55 MOTION to
Dismiss for Failure to State a Claim, 23 MOTION to Dismiss First Amended Complaint,
52 MOTION to Dismiss for Failure to State a Claim and Other Reasons, 50 MOTION to
Dismiss for Failure to State a Claim and Other Reasons, 21 MOTION to Dismiss for
Failure to State a Claim, 46 MOTION to Dismiss for Failure to State a Claim, 25
MOTION to Dismiss for Failure to State a Claim, 29 MOTION to Dismiss for Failure to
State a Claim, 31 MOTION to Dismiss , 57 MOTION to Dismiss for Failure to State a
Claim and other defenses. filed by A Committee of Injured Ciitzens/Voters for
Themselves and All Others Similarly Situated. (Attachments: # 1 Exhibit List of Case
FIles, # 2 Exhibit Linda Lamone Correspondence, # 3 Exhibit Draza Smith, # 4 Exhibit
Data Info, # 5 Exhibit Counties and Funding, # 6 Exhibit Lois Gibson Affidavit, # 7
Exhibit Affidavit, # 8 Exhibit Affidavit, # 9 Exhibit CTCL Agreements Grants, # 10
Exhibit Howard County Mules, # 11 Exhibit Affidavit)(Charlton, Walter) Modified on
11/23/2022 (ols, Deputy Clerk). (Entered: 11/23/2022)
11/23/2022 59 QC NOTICE: 57 Motion to Dismiss for Failure to State a Claim filed by Alleghany
County was filed incorrectly.
11/23/2022 60 QC NOTICE: 58 Response in Opposition to Motion, filed by A Committee of Injured
Citzens/Voters for Themselves and All Others Similarly Situated was filed incorrectly.
**When filing a response, you should only select the Motions that the document is
responding to. Please refile and ensure you select only the Motions filed by State of
Maryland, Montgomery, Wicomico, Anne Arundel, Garret, Washington, Harford and
Cecil Counties. It has been noted as FILED IN ERROR, and the document link has been
disabled. (ols, Deputy Clerk) (Entered: 11/23/2022)
11/23/2022 61 NOTICE by Alleghany County re 57 MOTION to Dismiss for Failure to State a Claim
Proposed Order (Beeman, Terry) (Entered: 11/23/2022)
11/23/2022 62 MOTION to Dismiss Amended Complaint by Carroll County Maryland (Attachments: # 1
Memorandum in Support, # 2 Text of Proposed Order)(Karpinski, Kevin) (Entered:
11/23/2022)
11/23/2022 63 MOTION to Dismiss Amended Complaint by Kent County Board of Elections
(Attachments: # 1 Memorandum in Support, # 2 Text of Proposed Order)(Karpinski,
Kevin) (Entered: 11/23/2022)
11/23/2022 64 RESPONSE in Opposition re 34 MOTION to Dismiss for Failure to State a Claim, 48
MOTION to Dismiss for Failure to State a Claim and Other Reasons, 62 MOTION to
Dismiss Amended Complaint, 18 MOTION to Dismiss the Amended Complaint, 26
MOTION to Dismiss for Failure to State a Claim, 14 MOTION to Dismiss for Failure to
State a Claim, 55 MOTION to Dismiss for Failure to State a Claim, 23 MOTION to
Dismiss First Amended Complaint, 52 MOTION to Dismiss for Failure to State a Claim
and Other Reasons, 50 MOTION to Dismiss for Failure to State a Claim and Other
Reasons, 21 MOTION to Dismiss for Failure to State a Claim, 63 MOTION to Dismiss
Amended Complaint, 46 MOTION to Dismiss for Failure to State a Claim, 25 MOTION
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to Dismiss for Failure to State a Claim, 29 MOTION to Dismiss for Failure to State a
Claim, 31 MOTION to Dismiss , 57 MOTION to Dismiss for Failure to State a Claim ,
pursuant to civil rule of civil procedure 12(b) 1 and 6 and other claims filed by A
Committee of Injured Ciitzens/Voters for Themselves and All Others Similarly Situated.
(Attachments: # 1 Exhibit List of Case FIles, # 2 Exhibit Linda Lamone Correspondence,
# 3 Exhibit Draza Smith, # 4 Exhibit Data Info, # 5 Exhibit Counties and Funding, # 6
Exhibit Lois Gibson Affidavit, # 7 Exhibit Affidavit/ Declaration, # 8 Exhibit
Affidavit/Declaration, # 9 Exhibit CTCL Agreements Grants, # 10 Exhibit Howard
County Mules, # 11 Exhibit Bio Information, # 12 Text of Proposed Order Order)
11/28/2022 65 Supplemental MOTION for Service of Process for two Defendants declining service. To
be served by US Marshals and Service to include all Exhibits previously filed in Pacer
and Court Orders excepting only extensions of time to be added by US Marshals after
conferring with Counsel and instruction of Court. by A Committee of Injured
Ciitzens/Voters for Themselves and All Others Similarly Situated (Attachments: # 1
Summons Baltimore City, # 2 Summons CTCL Chicago, # 3 Supplement 1st Amended
Complaint, # 4 Supplement US Marshals Form w Proposed instructions, # 5 Supplement
US Marshals Form w Proposed instructions)(Charlton, Walter) (Entered: 11/28/2022)
12/06/2022 66 REPLY to Response to Motion re 63 MOTION to Dismiss Amended Complaint, 62
MOTION to Dismiss Amended Complaint, 18 MOTION to Dismiss the Amended
Complaint filed by Calvert County, Carroll County Maryland, Kent County Board of
Elections, Washington County.(Karpinski, Kevin) (Entered: 12/06/2022)
12/06/2022 67 REPLY to Response to Motion re 21 MOTION to Dismiss for Failure to State a Claim
filed by Montgomery County.(Lattner, Edward) (Entered: 12/06/2022)
12/06/2022 68 MOTION to Dismiss for Failure to State a Claim by Queen Anne's County (Attachments:
# 1 Memorandum in Support, # 2 Text of Proposed Order)(Poltrack, Eric) (Entered:
12/06/2022)
filed by Harford County.(Wyand, David) (Entered: 12/07/2022)
filed by Howard County Maryland.(Peltzman, Cynthia) (Entered: 12/07/2022)
12/13/2022 71 MOTION to Dismiss for Failure to State a Claim by Prince George's County
(Attachments: # 1 Memorandum in Support Memorandum In Support Of Dismissal, # 2
Text of Proposed Order Proposed Order)(Saint Pol Maydieu, Guy) (Entered: 12/13/2022)
12/16/2022 73 ORDER granting 14 Maryland Board of Elections' Motion to Dismiss for Failure to State
a Claim; granting 18 Calvert & Washington Counties' Motion to Dismiss; granting 21
Montgomery County's Motion to Dismiss for Failure to State a Claim; granting 23
Wicomico County's Motion to Dismiss; granting 25 Anne Arundel's Motion to Dismiss
for Failure to State a Claim; granting 26 Maryland State Prosecutor's Motion to Dismiss
for Failure to State a Claim; granting 29 Harford County's Motion to Dismiss for Failure
to State a Claim; granting 31 Garrett County's Motion to Dismiss; granting 34 Howard
County's Motion to Dismiss for Failure to State a Claim; granting 46 Cecil County's
Motion to Dismiss for Failure to State a Claim; granting 48 Talbot County's Motion to
Dismiss for Failure to State a Claim; granting 50 Dorchester County's Motion to Dismiss
for Failure to State a Claim; granting 52 Caroline County's Motion to Dismiss for Failure
to State a Claim; granting 55 Baltimore County's Motion to Dismiss for Failure to State a
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Claim; granting 57 Allegany County's Motion to Dismiss for Failure to State a Claim;
granting 62 Carroll County's Motion to Dismiss; granting 63 Kent County's Motion to
Dismiss; granting 68 Queen Anne's County's Motion to Dismiss for Failure to State a
Claim; granting 71 Prince George's County's Motion to Dismiss for Failure to State a
Claim; dismissing the case against the remaining Defendants; denying as moot 65
Plaintiff's Motion for Service. Signed by Judge Stephanie A. Gallagher on 12/16/2022.
01/13/2023 74 MOTION to Alter/Amend Judgment with points and authorities, evidence, and proposed
Order reinstating case by A Committee of Injured Ciitzens/Voters for Themselves and All
Others Similarly Situated (Attachments: # 1 Exhibit Wifi Existance at Preceinct, # 2
Exhibit Wifi Part of all ES&S Machines WB, # 3 Exhibit Fact and Expert IT Opinion, # 4
Exhibit Evidence of Violations Cash Rules Nationwide and Maryland)(Charlton, Walter)
(Entered: 01/13/2023)
01/16/2023 75 -FILED IN ERROR- Third MOTION for Extension of Time to File A 3rd Amended
Complaint to include new evidence existing and in process regarding election systemic
errors and false transactions including voting by A Committee of Injured Ciitzens/Voters
for Themselves and All Others Similarly Situated(Charlton, Walter) Modified on
01/17/2023 76 QC NOTICE: 75 Motion for Extension of Time to File, filed by A Committee of Injured
Ciitzens/Voters for Themselves and All Others Similarly Situated needs to be corrected. It
has been noted as FILED IN ERROR, and the document link has been disabled. The
following corrective actions are needed regarding missing or incomplete information:
Please refile using the event under Motions > Amend/Correct. The Motion should be the
main document and the proposed Amended Complaint and Redline Copy as individual
attachments to the Motion. Please also provide a proposed order as a third attachment.
01/26/2023 77 RESPONSE in Opposition re 74 MOTION to Alter/Amend Judgment with points and
authorities, evidence, and proposed Order reinstating case filed by The State of
Maryland. (Attachments: # 1 Text of Proposed Order)(Kobrin, Daniel) (Entered:
01/26/2023)
01/26/2023 78 -REFILED AT 82 -RESPONSE in Opposition re 74 MOTION to Alter/Amend Judgment
with points and authorities, evidence, and proposed Order reinstating case filed by
Calvert County, Carroll County Maryland, Kent County Board of Elections, Washington
County.(Karpinski, Kevin) Modified on 1/26/2023 (ols, Deputy Clerk). (Entered:
01/26/2023)
authorities, evidence, and proposed Order reinstating case filed by Anne Arundel
County. (Attachments: # 1 Text of Proposed Order)(Culpepper, Philip) (Entered:
01/26/2023)
01/26/2023 80 QC NOTICE: 78 Response in Opposition to Motion, filed by Kent County Board of
Elections, Washington County, Carroll County Maryland, Calvert County was filed
incorrectly.
authorities, evidence, and proposed Order reinstating case filed by The Office of the
State Prosecutor. (Attachments: # 1 Text of Proposed Order)(Shiff, Wendy) (Entered:
01/26/2023)
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authorities, evidence, and proposed Order reinstating case filed by Calvert County,
Carroll County Maryland, Kent County Board of Elections, Washington County.
(Attachments: # 1 Text of Proposed Order)(Karpinski, Kevin) (Entered: 01/26/2023)
authorities, evidence, and proposed Order reinstating case filed by Harford County.
(Attachments: # 1 Text of Proposed Order)(Wyand, David) (Entered: 01/26/2023)
authorities, evidence, and proposed Order reinstating case filed by Baltimore County.
(Attachments: # 1 Text of Proposed Order Proposed Order)(KELLY, AARON) (Entered:
01/26/2023)
authorities, evidence, and proposed Order reinstating case filed by Caroline County,
Dorchester County, Talbot County. (Attachments: # 1 Text of Proposed Order Proposed
Order)(Meehan, Andrew) (Entered: 01/27/2023)
authorities, evidence, and proposed Order reinstating case filed by Wicomico County.
(Attachments: # 1 Text of Proposed Order Proposed Order)(Illuminati, Andrew) (Entered:
01/27/2023)
authorities, evidence, and proposed Order reinstating case filed by Montgomery County.
(Attachments: # 1 Text of Proposed Order)(Lattner, Edward) (Entered: 01/27/2023)
authorities, evidence, and proposed Order reinstating case filed by Garret County.
(Attachments: # 1 Text of Proposed Order)(Getty, Gorman) (Entered: 01/30/2023)
authorities, evidence, and proposed Order reinstating case filed by Howard County,
Howard County Maryland. (Attachments: # 1 Text of Proposed Order)(Peltzman,
Cynthia) (Entered: 01/30/2023)
02/08/2023 90 Consent MOTION for Extension of Time to File Response/Reply as to 84 Response in
Opposition to Motion, 78 Response in Opposition to Motion, 89 Response in Opposition
to Motion, 85 Response in Opposition to Motion, 77 Response in Opposition to Motion,
87 Response in Opposition to Motion, 81 Response in Opposition to Motion, 83
Response in Opposition to Motion, 86 Response in Opposition to Motion, 79 Response in
Opposition to Motion, 80 QC Notice - Miscellaneous, 88 Response in Opposition to
Motion, 82 Response in Opposition to Motion, to Alter and Amend the Judgment by A
Committee of Injured Ciitzens/Voters for Themselves and All Others Similarly Situated
(Attachments: # 1 Text of Proposed Order Order Granting Consent Motion)(Charlton,
02/09/2023 91 PAPERLESS ORDER granting 90 Motion for Extension of Time to File Response/Reply
74 MOTION to Alter/Amend Judgment. Signed by Judge Stephanie A. Gallagher on
2/9/2023. (vals, Chambers) (Entered: 02/09/2023)
02/09/2023 92 RESPONSE re 74 MOTION to Alter/Amend Judgment with points and authorities,
evidence, and proposed Order reinstating case filed by Prince George's County.
(Attachments: # 1 Text of Proposed Order Proposed Order)(Saint Pol Maydieu, Guy)
(Entered: 02/09/2023)
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02/21/2023 93 REPLY to Response to Motion re 74 MOTION to Alter/Amend Judgment with points and
authorities, evidence, and proposed Order reinstating case Reply with attachments of
Evidence relevant to standing and response to defendants oppositions to Alter and Amend
Judgement with Draft Order. filed by A Committee of Injured Ciitzens/Voters for
Themselves and All Others Similarly Situated. (Attachments: # 1 Exhibit List of the
Alleged Mules with Payments, # 2 Exhibit Working Document from Expert, # 3 Exhibit
Information Data X, # 4 Exhibit Information Data X1)(Charlton, Walter) Modified on
02/23/2023 94 -FILED IN ERROR- MOTION to Transfer Case To Multi District Litigation Panel with
Points and Authorities and Expert opinion with Proposed Order per Federal Rule of Civil
Procedures Part 5 and 28 U.S.C. Section 1407 by A Committee of Injured Ciitzens/Voters
for Themselves and All Others Similarly Situated (Attachments: # 1 Exhibit 6 page expert
engineering opinion based upon govt file evidence demonstrating existence of Money
Laundering and obfuscation of Election financing data. Nation Wide - including
Maryland.)(Charlton, Walter) Modified on 3/21/2023 (ols, Deputy Clerk). (Entered:
02/23/2023)
03/17/2023 95 -FILED IN ERROR- Emergency MOTION for Preliminary Injunction with Engineering
and Evidentiary Details by A Committee of Injured Ciitzens/Voters for Themselves and
All Others Similarly Situated (Attachments: # 1 Exhibit Flow Chart Big Cheat, # 2
Exhibit Engineering Details, # 3 Exhibit Financial Review, # 4 Exhibit Detailed
Evidence, # 5 Exhibit Blank Ballot Examples, # 6 Exhibit Blank Ballot Analysis and
Verification, # 7 Exhibit Decertification Authorities)(Charlton, Walter) Modified on
03/19/2023 96 -FILED IN ERROR- Corrected MOTION for Leave to File A corrected Main Document
# 95, an Unedited Versiion of This Document Was Uploaded in Error, This Document
Corrects and Replaces the Main Document # 95 That Was filed in Error by me on
3/17/2023, Appologies Walter T Charlton by A Committee of Injured Ciitzens/Voters for
Themselves and All Others Similarly Situated(Charlton, Walter) Modified on 3/21/2023
(ols, Deputy Clerk). (Entered: 03/19/2023)
03/21/2023 97 QC NOTICE: 95 Motion for Preliminary Injunction, filed by A Committee of Injured
Ciitzens/Voters for Themselves and All Others Similarly Situated, 96 Motion for Leave to
File, filed by A Committee of Injured Ciitzens/Voters for Themselves and All Others
Similarly Situated, 94 Motion to Transfer Case, filed by A Committee of Injured
Ciitzens/Voters for Themselves and All Others Similarly Situated was filed incorrectly.
**This case was closed on 12/16/2022 and parties cannot seek an injunction in a closed
case. It has been noted as FILED IN ERROR, and the document link has been disabled.
03/23/2023 98 -FILED IN ERROR- MOTION for Emergency Relief and for Court's Corrective Action,
Verified by Counsel by A Committee of Injured Ciitzens/Voters for Themselves and All
Others Similarly Situated, All Others Similarly Situated Injured Persons, Any, Presently
Unknown State Agency which was Duped by the Multiple Frauds Alleged herin, Charlton
Scientific Educational and Engineering Foundation Inc., Amicus Curia, Lois Ann Gibson,
Maryland 20-20 Watch (Attachments: # 1 Text of Proposed Order) (ols, Deputy Clerk)
Modified on 3/24/2023 (ols, Deputy Clerk). (Entered: 03/23/2023)
03/24/2023 99 ECF FILED IN ERROR ORDER. Signed by Judge Stephanie A. Gallagher on 3/24/2023.
(Attachments: # 1 First Page of Filed in Error Document) (ols, Deputy Clerk) (Entered:
03/24/2023)
03/28/2023 100 Emergency Correspondence re: 59 (e) Motion- closing case in error before final ruling
ECF 74 et seq. (Charlton, Walter) (Entered: 03/28/2023)
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03/29/2023 102 ORDER denying 74 Plaintiffs' Motion to Amend Judgment. Signed by Judge Stephanie
A. Gallagher on 3/29/2023. (ols, Deputy Clerk) (Entered: 03/29/2023)
04/01/2023 103 NOTICE OF APPEAL as to 101 Memorandum Opinion, 7 Order on Motion for
Miscellaneous Relief, Order on Motion to Alter/Amend Judgment, 72 Memorandum
Opinion, 4 Order on Motion for TRO, 73 Order on Motion to Dismiss for Failure to State
a Claim,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,, ,,,,,,,,,,,,,,,,,,,,,,,,,,,,, Order on
Motion for Miscellaneous Relief,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,, 43 Memorandum Opinion, 44
Order on Motion for TRO, 102 Order on Motion to Alter/Amend Judgment by All Others
Similarly Situated Injured Persons. Filing fee $ 505, receipt number AMDDC-10522619.
04/03/2023 104 Transmission of Notice of Appeal and Docket Sheet to US Court of Appeals re 103
Notice of Appeal,,. IMPORTANT NOTICE: To access forms which you are required to
file with the United States Court of Appeals for the Fourth Circuit please go to
http://www.ca4.uscourts.gov and click on Forms & Notices.(bw5s, Deputy Clerk)
(Entered: 04/03/2023)
04/06/2023 105 USCA Case Number 23-1369 for 103 Notice of Appeal,, filed by All Others Similarly
Situated Injured Persons. Case Manager - Anisha Walker (bw5s, Deputy Clerk) (Entered:
04/06/2023)
05/31/2023 106 Substantive legal issues - addressing (Charlton, Walter) (Entered: 05/31/2023)
06/08/2023 107 NOTICE of Appearance by Bambi C B Glenn on behalf of Baltimore County (Glenn,
Bambi) (Entered: 06/08/2023)
06/14/2023 108 Corrected Correspondence re: Consent Motion for Record Correction unsigned at this
time. (Attachments: # 1 Supplement Notice of Filing a consent motion to correct the
record for "filed in error" expected to be granted immediately. Along with Specifics of
Suplements to 4th Circuit Record requested to be added to record.)(Charlton, Walter)
(Entered: 06/14/2023)
06/15/2023 109 ORDER of USCA "Granting" motion to supplement the record as to 103 Notice of
Appeal,, filed by All Others Similarly Situated Injured Persons (bw5s, Deputy Clerk)
(Entered: 06/20/2023)
06/20/2023 Assembled Electronic Record Transmitted to Fourth Circuit -- Initial (ECF 94, 95, 96, 97,
98, and 99)(bw5s, Deputy Clerk) (Entered: 06/20/2023)
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JA17
Case 1:22-cv-01642-SAG Document 1 Filed 07/05/22 Page 1 of 67
IN THE UNITED STATES DISTRICT COURT

FOR THE DISTRICT OF MARYLAND
Lois Ann Gibson, a Private Citizen/Voter )

Frederick, Maryland; )
C/O. Counsel P.O. Box 370 )
Woodsboro, Maryland 21798 )
And ) Case No.
Maryland 20-20 Watch, a Private Unincorporated )
Association of Maryland Citizens and Voters, in Md., )
by Chairman, Lewis T. Porter, Investigator/Voter )
C.O. Post Office Box 370, Woodsboro, Md. 21798 )
And )
Amicus Curiae, Charlton Scientific Educational and )
Engineering Foundation, Inc. ; )
And )
A committee of injured citizen/voters for )
themselves and all others similarly situated pursuant )
to Federal Rule of Civil Procedure Rule 23, and the )
Federal Rules of Civil Procedure, Multi-District )
Litigation Sections, Consisting of a: )
Putative Class of similarly situated Voters of )
of Maryland who are Similarly Situated, and denied )
or superseded in their vote, and/or Right to Vote, )
and/or Injured by Abrogation of His/Her Voting Power )
and/or Constitutional Right to a Fair and Honest Vote, )
and/or Shall be Immediately and Irreparably Harmed )
and/or Likely Injured by the Continuing Ongoing )
Frauds described herein specified and/or specifically )
detailed herein )
And )
Any, presently unknown State Agency which was )
Duped by the Multiple Frauds Alleged herein )
And )
All others similarly situated injured persons, in )
whatever state or County they reside, in this )
RICO Multi-District Litigation for False Vote )
Tabulation; Deceased and Moved Roll harvesting, )
Conspiracy; for Money Laundering and for False Vote )
Bribery; Totaling or Tabulation Manipulation with )
-i-
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Causing Immediate and Irreparable harm to )

Government Credibility, Confidence in Present )
and Future Elections by Placing False Financial )
Information into State or Federal Financial Records )
and/or Voting Rolls. )
)
PLAINTIFFS )
)
V. )
)
Frederick County Maryland, )
And )
Howard County, Maryland, )
And )
Carroll County, Maryland )
)
Additional Defendants: )
)
18 additional counties alleged to participate )
in the fraudulent procedures, receiving bribery )
and unlawful influencing by compromised “Grants” )
to Maryland Vote Workers of tax free funds, these are:)
)
Allegheny, Anne Arundel, Baltimore City, )
Baltimore County, Calvert, Caroline, Cecil, Charles, )
Dorchester, Garret, Harford, Howard, Kent County )
Board of Elections, Montgomery, Prince Georges, )
Queen Anne’s, Talbot, Washington, Wicomico; )
And; )
A RICO Enterprise, Containing the State of Maryland, )
and Other States Utilizing Unlawful Conspiracies )
and/or Methodology to Rig Votes, et al: )
And/or )
Each unlawfully acting citizen, or RICO Entity, or )
Federal or State Government Employee, with the sole )
exception of those protected by Government Immunity )
Acting with guilty knowledge of the fraudulent facts )
nevertheless, intentionally, or by a conspiracy to alter, )
individually, to place false or knowingly, incorrect, )
or to render false, forge or utter, or merely or destroy )
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materials from the voting process or accountability )

records, or to falsely pay others to falsify or do so )
alone, or in conspiracy with others, thereby aiding and )
abetting the unlawful violations of any citizen’s voting )
rights in any state or jurisdiction, by aiding and )
knowingly or negligently, thereby abetting paying for )
or underwriting the fraudulent voting means, systems )
delivery of fraudulent materials or activities, with )
guilty knowledge thereof; of such practice or act; )
And; )
a class of Similarly Situated Defendants who are now )
known to have accepted alleged “Grant” Money from )
CTCL, and thereafter used such funds for unlawful )
purposes to influence election results and continue to )
utilize such unlawful means in the future, and/or )
whom presently intend do so in the Future, or )
Alternatively have aided and abetted the Fraud, both )
Civil and Criminal and/or found to have occurred, )
now or in Future Election(s) On a Continuing Basis; )
)
And further; those classes or Classes of Defendants )
similarly situated in Other Districts Similarly Situated )
Utilizing Similar Fraudulent Schemes in Other States; )
and or the District of Columbia, or Judicial District )
further, Each and Every Election Executive Or )
Worker who, with Knowledge of the Unlawful Nature )
of their Own Acts has aided and abetted the creation or )
carrying out of the damages to this Country and each )
part thereof by the perpetration of the Unlawful Acts )
described herein and shall be convicted of such )
Acts in Accordance with the Laws of the United States )
or the Laws of Maryland or the respective States )
wherein such Unlawful Acts Occurred. )
)
Defendants. )
And )
Center for Tech and Civic Life (CTCL) )
233 N Michigan Ave., Suite 1800 )
Chicago, Il. 60601; )
And; )
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Presently Unknown Defendants, expected to be )

identified as both government employees, or private )
persons identified from documents received from )
government sources, including non-profit foundations )
in Fact RICO Enterprises, numbering in the many )
dozens, Foreign and Domestic, who, by good and )
verified admissions and verified evidence, or at trial )
shall be demonstrated to have conspired and/or be )
found to have or currently are conducting Civil or )
Criminal Process of Law, to have participated and/or )
knowingly Aided and Abetted the Activities )
Complained of herein; have thereby violated the civil )
and Criminal Laws of the Constitution of the State of )
Maryland and/or the United States of America, )
including without limitation, the RICO Act and/or )
The False Claims Act, wherein each such statute is )
applicable: )
And; )
The State of Maryland, Through its Departments )
And: )
The Office of the State Prosecutor, who has )
Abrogated its Office by failing to Stamp Out RICO )
Enterprises in its Jurisdiction, for Whatever Reason. )
)
DEFENDANTS )
)
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COMPLAINT
FOR VOTE FRAUD,

CREATION OF A RICO ENTITY, A STATE AND
NATIONAL CONSPIRACY PARTICIPATED IN BY NAMED
DEFENDANTS, AND UNKNOWN OTHERS, TO COMMIT
VOTE FRAUD IN A NATIONAL ELECTION VIOLATION
OF 6 U.S.C. § 4511
FOR EMERGENCY, TEMPORARY, PRELIMINARY,

AND PERMANENT INJUNCTIVE AND OTHER
EQUITABLE RELIEF
1
Section 5, “The EISCC operates under the critical infrastructure partnership advisory
council (CIPAC) framework established by the Secretary of Homeland Security pursuant to
section 871 of the Homeland Security Act of 2002 (6 U.S.C. §451)”
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(Part one- Setting, Jurisdiction, Law, and Conclusions, for

Details of Facts See Part Two, following, page 38, for a Draft
Temporary Restraining Order, See Attachment A, For Index of
Exhibits, See Page 61, following Complaint. )
I. VOTE FRAUD – RICO CONSPIRACY, WITH IMMEDIATE AND
IRREPARABLE HARM – DANGER OF DESTRUCTION OF RECORDS, FOR
AN IMMEDIATE PROTECTIVE ORDER,
AND
CONSTITUTIONAL CORRECTIVE ACTION FOR A REMEDY IN THIS STATE
AND
OTHER EQUITABLE RELIEF, TO CORRECT A CORRUPTED
NON-FUNCTIONAL, INSUFFICIENT EVIDENCE AND CUSTODY CONTROLS
OF A CORRUPTED VOTING AND RECORD KEEPING SYSTEMS,
DENYING ALL CITIZENS THEIR CONSTITUTIONAL RIGHTS FOR NOW
AND IN THE FUTURE;
BY ACTION OF THE COURT SYSTEM AS IS ITS CONSTITUTIONAL DUTY :
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COMPLAINT FOR INJUNCTIVE AND OTHER RELIEF
PRELIMINARY STATEMENT
There has been an overwhelming response from Whistle Blowers and
Concerned Citizens of Counties throughout Maryland, and elsewhere, of Obvious and
Determinative Fraud in Voting in Maryland and Nationally, in the 2020 Federal
Elections; this Complaint attempts to Invoke the Power of this Court to Correct those
Harms which Threatens the Survivability of Our Great Nation :
A similar pattern and practice of unlawful activities has been noted and
cataloged all across the Country. This complaint focuses on Maryland, initially in three
Counties, but with striking similarities noted in 21 of 24 jurisdictions. Three jurisdictions/
Counties, did not participate in the specific frauds investigated and alleged herein.
EVIDENCE
This complaint is supported by a large sample of documents furnished by
one Maryland County, which is expected to be representative of all 21 Counties in
Maryland receiving the $ 6,245,797 in Grants 2.
Howard County Maryland furnished a list of 861 checks which purport to
be the money spent by Howard County which was received from a Grant from CTCL.
The total of the 861 separate payments in dollars is exactly the same number as the
2
Exhibit #1, with details supplementing follow on succeeding pages, after page 61. An
index of Attachments and Exhibits is page 61,
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reported Grant total, $ 688,2263.
The names on the payments list as reported by the County were sorted
alphabetically. About 760 names appear, with some duplicate names. Research disclosed
that the top three earners were from the same family. Each was paid over $ 11,000, and
received exactly the same amount in their, final paycheck, $2,940.19. Again, as reported
by the County, the entire amount of the Grant was paid out to these about 760 people.
And the amount of the total payments matches exactly the amount of the
Grant, $ 688,226. Plaintiffs infer from this information, here are the Mules, subject to
further documentary proof.
Plaintiffs allege, based upon the eyewitness reports from other Counties,
that a significant number of these 760 Cash recipients were in fact the “Mules”4 who also,
in fact created and/or delivered the fake and duplicate election ballots observed by two
other witnesses who presently choose to remain anonymous. Incontrovertible proof of
this allegation is expected to result from a small number of 30(b)(6) depositions, with
3
Howard County refused to produce its Contract with CTCL. Carroll County refused to
produce its disbursements of Grant Money received from CTCL. All three Counties are expected
to be deposed as to details of all of this evidence which is expected to produce a uniform pattern
of abuses consistent with all of the other 21 Counties of Maryland investigated.
4
“Mules” describe persons who transport drugs, or in this instance, fake or fabricated or
otherwise fraudulent ballots foisted upon honest poll-watchers by unscrupulous persons.
Recently this unlawful practice received substantial alternative media attention in the
documentary, “2000 Mules”.
See also the Arizona, Maricopa County Audit interim report of Jovan H. Pulitzer,
released on or about June 28th, 2022. Maricopa County is in the south-central part of the U.S.
state of Arizona. As of the 2020 census, the county's population was 4,420,568,
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subpoenas, to acquire for the deposition the supporting detailed documents.
Also, very recently the methodology of cheating on the drop-box and mail-
in practices have been exposed by two related sets of documentary exposures. On
information and belief, these fraudulent practices were in use Nationwide from at least
2016 to date. This allegation places these practices into the Jurisdiction of a Federal
RICO Claim almost standing alone.
This lawsuit expects to draw from both of those related factual large
volume efforts for use by experts witnesses to be selected within the period of
effectiveness of the requested Temporary Restraining Order. These efforts, now
becoming standard practice for exposures of drop-box and other election frauds in
falsification of ballots are the Arizona Audit, report of Jovan Pulitzer, who has agreed to
participate in this effort, hopefully as an expert witness. Also, considered is the slightly
different approach of the 2000 Mules Documentary. Both of these recent presentations
contain factual matters believed to be relevant, or identical, to the practices addressed in
this Complaint.
THE TEMPORARY RESTRAINING ORDER
Plaintiffs request a temporary restraining order to protect all such related
documents from destruction; and permission to immediately conduct several depositions
pursuant to F. R. Civ. P. Rule 30(b)(6). The existing substantial sample of evidence is
expected to be expanded in detail and geographic scope, in time for a full presentation at
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the preliminary injunction hearing. And of course further expanded as necessary for trial
as needed for the multi-district nature of this litigation.
This is the thrust of this complaint.
Jurisdiction and Venue - Maryland and Nationwide
Analysis by investigators and counsel began many years ago in Maryland.
Anecdotal evidence has been gathered to present to the Court a fair and well-balanced
overview.
It has become obvious that this situation is not simply a local concern, it is
nationwide. It may vary in practice and severity from place to place, even within
individual states. In Maryland, three Counties have been sampled, presenting in detail a
bleak but similar initial picture. Those Counties are Frederick, Howard and Carroll.
However, by stepping back and taking an overview of the State as a whole, a pattern
emerges which is shocking in dishonest uniformity.
II. STATEMENT OF FACTS:
1. This case is not about Donald Trump or the 2020 election. Rather, it is
about correcting the existing election system to ensure election integrity for all citizens in
the future.
2. This case is also about examining the honest system deficiencies, frauds,
manipulations and loss of election integrity of the past election, all destined to be repeated
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in the future. The repeat is inevitable through a lack of systemic and monetary controls
noted, including past cycle’s violations of Federal and State law.
3. All of the above summary facts are incorporated into this Statement of
Facts as if fully set forth herein as to the appropriateness of Multi-District litigation by the
Federal Court system, as the only constitutional entity with jurisdiction over all of the
unconstitutional and likely treasonous matters alleged herein, and even thos matters yet to
be addressed and after discovered.
4. But, this RICO case also involves the overarching conspiracies of a
number of people in a number of roles, creating “the presence of fraud” throughout the
election system, and likely all aspects of our government and private enterprises.
5. Cash grants to 21 Counties and Baltimore City, $ 6,245,797 total)5 were
used for unlawful and/or misstated purposes different from reported and contracted
reasons. The actual payments to election workers were tailored to impact election
results. For example placing false ballots into the voting drop-boxes.
6. On information and belief, at least hundreds of millions of dollars has
been distributed to elements of the RICO Enterprise(es) since the beginning of the
practices described herein, likely even before the election of 2016.
7. In the hearing for the Preliminary Injunction for this case, evidence
5
Exhibit #1, Source of Information, Capital Research. Org, M-20-Go/TV-CEIR-
Report/PDF; also, this public information gathered and maintained in IRS records, pertaining to
Tax Exempt Charities. (IRS Code Section 501(c)(3)).
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obtained by subpoenas is expected to further detail obvious misuse of Grant proceeds, to
demonstrate biased, and likely unlawful payments for vote harvesting and delivery to
drop-boxes.
8. Substantial evidence in the form of financial records was obtained in
State PIA request responses. The samples disclose misinformation pertaining to the
Grant Process, misreporting of monies spent, and likely misuse of the monies spent for
election influencing acts.
9. During the period of time from the filing of this Complaint, until the
hearing on the Preliminary Injunction, Plaintiffs intend to use the subpoena process to
each county to obtain evidence pertaining to the grants received, the strictures of the
election law and the magnitude of the known violations for each of the 21 Counties listed
on Exhibit #1 hereto.
10. The Temporary Restraining Order requests:
a. A Stay of evidence destruction, a continuation of Federal Election law,
contained in 52 U.S.C. § 20,701, indefinitely, for the District of Maryland, and also;
b. to be seriously considered for all other Districts in the Federal Judicial
System, first as a TRO, and thereafter as Preliminary and Permanent Injunctions.
11. Permission, immediately after service of process, to allow Plaintiffs to
conduct at least three, F. R. Civ. P. 30(b)(6) depositions, along with the issuance of
subpoenas regarding grant data and spending purposes. Thereby, the partial evidence of
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fraudulent activities pertaining to the three examined Counties, Frederick, Caroll, and
Howard, shall be supplemented and used in the scheduled Hearing on the Requested
Preliminary Injunction (about two weeks hence).
12. Based upon the patterns already discovered, it is expected that
documentary evidence will be consistent across the board of biased spending designed for
influencing election results, and cover-up of financial reporting of prohibited practices.
13. Exhibit #2 .1 is a sworn declaration of Ms Gibson, an Eye Witness to
Drop-Box stuffing, is expected to be amplified prior to the conducting of the Preliminary
Injunction hearing by questioning the Howard County election workers who were paid
with Grant funds from Chicago.
A supplemental investigation utilizing previously obtained documents
regarding Grants and uses of Grant Funds is expected to demonstrate incontrovertible
proof of unlawful payment for drop box stuffing witnessed by a number of witnesses.
Such evidence will be obtained by the subpoena process acting immediately after filing
the complaint, and amplified by depositions incident to Federal Rule of Civil Procedure
30(b)(6).
14. Specific attention will focused upon uses of the grant funds which do
not comport with agreed uses under the terms of written Grant contracts.
15. The three jurisdictions already focused upon for review, will be further
detailed to specify and identify votes cast,, or collected by persons who received the Grant
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funds, contrary to the terms of the grant.
16. Those jurisdictions shall be further subjected to gathering of evidence
for the Preliminary Injunction hearing, and supplemented by such further analysis for
systemic failures similarly noted in the other 18 counties as well. But none of this
analysis shall be possible unless the evidence is preserved during this collection process
as authorized by Federal Law and subpoena power.
17. In sum, this case is about the impact on our nation of the on-going
systemic failures of election integrity from a number of related hidden unlawful sources
by co-conspirators, coupled with;
18. A lack of proper accounting for votes, chain of custody over valid votes,
and the possible fabrication of false votes, sometimes known as “unlawful ballot
harvesting”. The sum of all of these matters may be referred to as a lack of numeric
control and governance over the election system and votes.
19. The impending deadline for the destruction of election data is
September 3, 2022. Destruction of that election evidence, on information and belief, now
ongoing, contrary to 2, U.S.C. § 209,701 will be further specified and reported for
ongoing systemic corrections.
20. To the extent such destruction of evidence continues to occur, or the
deadline arrives before protection occurs further immediate and irreparable harm will
result. That destruction will create the loss of invaluable evidence necessary to
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understand the magnitude and means by which the eyewitness results did in fact occur.
21. These corrections are necessary to restore election integrity going
forward and ensure the continuation of the American dream, its freedoms for its citizens
and the preservation of the value of a singular vote.
III. CONCLUSIONS OF FACT:
In Maryland, 21 out of 24 voting jurisdictions accepted “Grant Funds” from
a Chicago-based, tax exempt charity. Those 21 Counties and Baltimore, received the
total amount of $6,245,797. By separate grant contract documents for each county,
specified categories of purportedly non-partisan “election aid” were specified and agreed
upon in each separate jurisdiction’s documents (See examples, Exhibit #4).
Frederick, Carroll, and Howard Counties were selected for examination as
to Election financing and voting controls applicable therein. It appears from documents
received (Exhibit “#4), contracts substantially identical in format and content, limit the
use of funds to specific mandatory uses which must be reported back to the grantor, or
refunded back to the Grantor. No example of a “Grant Refund” has been disclosed.
Accordingly, on information and belief, based upon this sample, the
methodology for all recipients of funds in the identified 21 Counties and Baltimore City,
is substantially identical. Each voting jurisdiction signed a contract, accepted funds, and
agreed by written contract to accept the written conditions imposed by the Grantor.
But follow-up disclosures as to the actual usage of the funds received
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present a totally different and darker story.
A de facto unlawful coercive system exists, based on information gleaned
from publicly available records for the three counties reviewed. Therefore, such de facto
violations of election and RICO law are herein alleged to be now and previously
operative in an identical and/or similar fashion in all 21 jurisdictions listed in Exhibit #1.
The same grantor furnished the funds for all 21 Counties, (and elsewhere
nationwide) apparently using the same boiler-plate Grant and Contract instruments. By
acquiring these documents, and financial and contract analysis, plaintiffs have developed
a substantial picture of the methodology of how the voter’s system was gamed in
Maryland.
The non-existence of any effective voting control system, particularly over
drop-boxes, appears to be a large source of false and harvested ballots. Nevertheless, the
links to the outside money has been traced, in the three Counties examined, by
“Following the Money”. Please refer to Exhibit #1 for the distribution of approximately
$6.2 million to the 21 counties choosing to participate. Even without using the subpoena
process to date, it substantial systemic deficiencies appear.
Grant funds are alleged to have been used to pay persons, and those persons
were used to “harvest” votes. Then, in large numbers, it appears that the persons paid
with the Grant funds (for example 1 for 1 match, to the penny, in Howard County, were
for $ 688,226.
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The duties performed are not specified, and the contract for Howard County
was not furnished for comparison. Howard County refused to disclose the subject grant
contract, but the dollar amount matches exactly the dollar total of the list of
purported“election workers” identified. The duties identified in the grant may be inferred
as activities relating to or promoting ballot harvesting for several reasons.
First, Howard County did not furnish the requested Contract known to exist
with CTCL as apparently was the standard procedure. A 30(b)(6) deposition for
knowledgeable persons to explain these inconsistencies, and the recipients of the
$ 688,000 of funds by this County shall be a good start toward unraveling what actually
occurred. (To this end, see Exhibits 4 and 5).
Exhibit #4 is the consistent contract methodology for all Grants, and Exhibit
5 is the result to be expected, to a greater or lesser extent in each grant receiving County,
or Baltimore City.
Second, because the dollar amounts of the worker payments exactly
matched the total grant amount, $ 688,226, one or more of these exhibits must contain
errors. It is expected based upon virtual impossibility that one or both of these reports
were forced into agreement before reporting.
Third, The highest paid three workers, apparently from the same family,
each received the same exact large amount. The great bulk of the fees paid were in round
dollar amounts.
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Fourth, the listing of amounts paid by worker’s names were nearly all paid
in round dollar amounts. This is clear evidence that the Grant was of the fee was for
piece-work services for example the rumored 5 or 10 dollars each for ballot delivery, and
not based on hours wages worked, subject to wage withholding and taxes. In any event,
the depositions will tell the tale, and a truthful one at that.
This pattern of circumstantial evidence, shall be verified prior to the hearing
on the preliminary injunction, strongly indicates that workers were in fact paid a piece
rate for something. Informal reports which shall be verified by depositions prior to the
hearing, are to the effect that the harvesters were paid a flat dollar amount, at $ 5.00 per
ballot placed into the drop-boxes.
Accordingly, on information and belief, plaintiffs allege this was the pattern
in the 21 Counties accepting Grant funds including the three counties analyzed.
On information and belief, it is further alleged that this was the
conspiratorial “deal” with the Grantor prior to the issuance of the grant. This allegation is
rendered nearly indefensible because no part of any Grant has been identified as refunded
to the Grantor, as per that specific provision of the Grant Contracts. (Exhibit # 4, pg. 2,
#3 of the standard grant form (Same reference for both Frederick and Carroll Counties)).
The exact matching dollar totals of the over 800 payments to workers in
Howard County, totaling the same, $ 688, 226, appears to match. This is an amazing
coincidence. The exact amount of the “Grant” for specific duties, match the exact list of
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the persons, that is all of the Grant was to pay people. And also because the left over
dollars in the Grant, the profits (or unspent funds to that point), appears to have been
split-up, 1/3/ each, and distributed evenly to the three top earners of the operation as a
payoff for completing the tasks and fulfilling the “grant”. The 30 (b)(6) of the County
cash disbursement supervisor on this subject is expected to be very enlightening.
This is not the accusation of a theft of grant funds at this point, but it
certainly has some of the hallmarks of that act.
Drop-Box Stuffing
The Honorable Court will please refer to Declaration of Lois Ann Gibson,
Exhibit # 2-1)., an apparent unlawful conspiracy, again throughout Maryland to place
false, harvested and/or fabricated ballots into drop boxes has been observed. The actual
drops have been observed and reported. Two additional Frederick County residents that
wish to remain anonymous, at this time have submitted (Affidavit, Exhibit # 2-2) relating
another instance of Ballot stuffing, and (Declaration # 2-3), relating to a Frederick poll
worker whose complaints were admitted to be true at an open meeting of the election
board, that count controls over documents for drop-boxes were non-existent).
Declaration of Mr. Kurtis S. Kolb, (Exhibit # 3) is a recent development of
apparent harvesting of voters records where a departing voter had moved to Florida from
Carroll County, Maryland. His voter’s record was undeleted by a forgery utilizing the
ERIC system resulting in an extra voter’s record, available in the next election. The voter
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disclosed the forgery to the authorities in Carroll County and it is presently being
investigated as an identity theft. This is included herein as a indicator that such matters
are currently on-going and potentially just more of the same if this entire control of voter
records remains unattended and thereby available for whatever fraud is desired.
Therein is the culmination of the matters alleged above into a RICO result
of violations of federal law by conspiracies of several varying known types and likely,
other practices yet to be discovered. This one instance is alleged to have been repeated in
many hundreds of instances applicable to so-called “insecure drop-boxes”.
The magnitude of these events may be confidently inferred (perhaps subject
to confirmation by new methodology discussed following) from graduated payments to
persons actually doing the harvesting whose names have been furnished by freedom of
information (PIA) inquiries.
Eye Witness to Mail-Drop Fraud
Eyewitness, and lead Plaintiff herein, Lois a Gibson (Gibson), a citizen
residing in Frederick Maryland received training as an Election Judge but, on election day
2020 was ill. She therefore was unable to serve as an election judge. However, she was,
sufficiently well and able to prepare her ballot for the presidential election. She
attempted to deliver and deposit her ballot into an official dropbox (one of eight in
Frederick County) near her home in Frederick. However, she was temporarily prevented
from doing so by an individual who arrived in an unmarked truck and proceeded to
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deposit dozens of ballots into the dropbox from a large canvas bag he was carrying.
Gibson inquired of that individual as to what he was doing and he
responded to the effect that he was transferring ballots from the post office, an
unauthorized and apparently false procedure and likewise false response. The individual
was using a canvas sack and an unmarked car and wore no uniform (Exhibit # 2,
Declaration of Gibson).
Later at a scheduled meeting of the election board inquiries from the
participants were made and the election board members responded to the effect that there
were no functional surveillance cameras. Further, no effective, or even ineffective chain
of custody over drop-box collected ballots was ever described for any of the 21 Grant
receiving Counties. On information and belief, however no control or functional
surveillance system exists for any such dropbox location in Maryland. Nor existence of
any such optical recording system ever been identified or described.
Accordingly, on information and belief at this time, no such control over
any such remote voting custody exists.
The Burden of Proof.
The Constitution of the State of Maryland, through a Constitutional
Amendment many years ago, created the venerable Office of the State Prosecutor.
Among other duties, that Office is formed to investigate Vote fraud and irregularities.
Accordingly, where it fails, and persons are injured by that failure, the state is liable, upon
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presentation of valid proof. Although that offices has been contacted, no response has
been received. Accordingly, the events discovered, even to this preliminary phase of this
case, would seem to indicate a lapse in a vital element of control, for which the State
would be accountable as a matter of both law and equitable relief.
The Lapse of Accountability
That is, there never has been described any chain of custody at all for
application to drop boxes. in Frederick County. A similar lack of any reasonable control
over these crucial documents, the key to all election results, are alleged to apply to some
extent, and it appears to be very large and as a practical matter, rather easily accountable
for all of Maryland. This is not to allege all Marylanders are dishonest, it only takes a few
bad apples to spoil the barrel. Similarly, a few bad people can upload many thousands of
false ballots. That is precisely what this case alleges. And within the last two days, a new
source of fake ballots has apparently appeared, likely as an high volume source of drop
box harvested ballots.
A former Maryland resident, Mr. Kurt Kolb, has reported, within the past
several weeks of an incidence of forgery of his Maryland drivers license, and associated
Voters registration records, utilizing the automated “Eric” system (See Declaration of
Kurt Kolb, Exhibit #3). During the investigation of the three Counties and the overall
situation regarding the magnitude of the apparent vote miscounts in Maryland, it has been
a mystery as to the origin of these apparently genuine but actually false votes.
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This declaration discloses a systemic weakness whereby a likely high
volume source of ballots to be generated out of thin air. This source of “fake votes”,
similar in effect to deceased voters, are those persons who have left Maryland and who
are easily identified by unlawful use of the newly functional tracking of both MVA
drivers and Maryland voters. In the event this case proceeds to trial, Plaintiffs would
expect to examine this new system, along with the similar effects available from wrongful
retention of deceased or inactive voters as an unlawful sources of registered voters
ballots. Magically generated, and then appearing in drop-boxes in the wee hours of the
morning.
Further, on information and belief not only is the same situation operative to
some extent across the State of Maryland, but it has recently been reported, that the
legislature has recently expanded the use of drop boxes plan for the upcoming election,
thereby exacerbating the already out of control situation.
IV. The Basics of the Fraud Financing Scheme, Alleged to Blanket Maryland:
Exhibit #4 contains copies of virtually identical (except the dollar value)
of contracts between two Counties of the three counties analyzed regarding voting system
procedures.
Frederick and Carroll counties, responded to PIA requests for information,
by furnishing, among other data, copies of their contracts for Grants. Howard County
declined to furnish their Contract with CTCL, but employees did furnish the substantial,
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but incomplete6, financial records pertaining to both the Grant received, and purported
how the Grant funds were distributed, purportedly from cash disbursement records.
Exhibit #1 lists each County receiving election aid grants from CTCL and
the amount of that County’s Grant. By a separate document, the contract with each
county details what the purported story is for that Grant for that County. However,
comparison to actual expenditures, See Exhibit # 5 (over 860 expenditures of funds listed
by Howard County tells a different story. Those expenditures, were sorted by individuals
receiving the Grant funds for that County. The results were acquired from information
furnished by the County disbursement department. That information is undeniable as to
who, that is which exact person, actually received that exact payment of the total funds
for that particular county. This information is likewise available by Subpoena, for each of
the 21 Counties and Baltimore City.
The only remaining step to prove the criminal conspiracy by each such
participant is to obtain the ballot(s) placed into the drop-boxes, examine them using the
latest technology, and link them to the individual perpetrators. Such forensic examination
is expected to occur, first on a test basis, prior to the hearing on a Preliminary Injunction,
and thereafter for 100% of the Ballots and Envelopes, but only where the tests indicate a
high likelihood of material fraud in that voting location.
6
For Example, strangely, the Middle Initial of purported names of workers hired were
missing on the list of over 800 disburdenments, totaling the amount of the Grant, $ 688,226.
Exhibit 4.
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And, the Court should note, not all such ballots need to be linked. Only
enough in each County jurisdiction to allow arrest and interrogation to crack the
conspiratorial scheme wide open. Further, examination of the 100% test sample, is by
high-speed equipment even if electronic images are not retained by each particular
location, or County or Baltimore.
V. RESOLUTION AND RELIEF
Accordingly, by a combination of forensic technologies described in detail
by the testimony of Jovan Hutton Pulitzer in similar factual situations, and the new
technology used in the 2000 Mules graphic video factual presentations an accurate
recreation of voting results also in similar factual situations, both now past, and for the
future, shall be made not just possible but practical. This technology is now available.
To the extent the fraudulent scheme was effective, it shall be disclosed and presented to
the Court for use by the appropriate control and/or corrective mechanism.
VI. ALTERNATIVELY, IN THE EVENT THIS HONORABLE

COURT DECLINES THE RELIEF SUGGESTED ABOVE:
Presuming arguendo, some that technical or practical consideration bars
prosecution of criminal considerations for the past election, independently, the immediate
and irreparable harm and utterly intolerable nature of this situation in the consideration of
any honest voter of Maryland, and elsewhere across this Great Nation, absolutely requires
this Court as a part of its very reason for existence, a looking forward into the next era of
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elections.
Even the mere allegation of such a mishmash of law and order cannot
proceed into our future. There, the two problems, (1) past results, and (2) future events
must necessarily be approached separately. Any other result is chaos and nightmare
mismanagement, using the kindest terms.
IMMEDIATE AND IRREPARABLE HARM TO:

OUR SYSTEM OF GOVERNANCE, THE CONSTITUTION OF MARYLAND
AND
THE CONSTITUTION OF THE UNITED STATES OF AMERICA
A. RELIEF REQUESTED
Using the Conclusion of Part One, as a starting point, with this viewpoint
as the only known sensible standard, the injunctive relief demanded, or some reasonable
compromise thereto, should be granted. The status quo of the evidence in this case must
be preserved in order that the obvious and egregious errors of the past are not repeated
resulting in the decent into permanent chaos by our great Republic. Indeed we are not
and must not become a banana republic. But we are on our way.
First as a Temporary Restraining Order, and as expanded, corrected, and
modified on a continuing basis, subject to legislative changes to the existing flawed
system if not merely apparent but, respectfully required for surficial of our way of life.
So the modifications to our structure of election mechanics and laws must necessarily be
viewed as not whether a fix is required, but what kind and to what extent.
There can be no reasonable argument that the past events involving
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unlawful acts, if indeed they did occur must cease. Preventing destruction of evidence as
is allowed by the existing “destruct” schedule, applicable to each county or voting
jurisdiction in the State of Maryland is a start.
This principle should be extended into the other judicial Districts in the
United States. The existing Federal Law is based upon normal times. These facts are
apparently typical for the entire Nation, and obviously were not meant to operate in the
presence of the massive fraud, and massive dishonesty as indicated by these demonstrated
facts. And those facts are expected to be expanded at the Preliminary Injunction hearing,
and later at Trial if such is necessary.
Second, although, the relief requested herein is within the guidelines of
Rule 65, the necessity for a comprehensive review for propriety of the applicable
Constitutional Bounds and Equity of Result, by this Honorable Court for all upcoming
elections obviously necessary.
But without preservation of the evidence, there shall be no decision possible
as based upon destroyed evidence. Accordingly, that evidence needs to be preserved
beyond the normal destruction date of September 3, 2022.
Third, unless exposed for what it is, faulty and lacking in basic control
mechanisms, the failures of our voting system and governance, the evidence of what
occurred in the 2020 election, will occur again, by application of the same faulty or
erroneous counting principles and/or outright dishonest activities.
Indeed, recent actions of the Maryland legislature are to the effect that drop-
box usage is to be greatly expanded. Absent the relief requested here, that portends a
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massive increase in the magnitude of use by dishonest elements to unlawfully control the
election, rather than a correction. Unless we all have truly lost our minds this cannot
happen
A. RULE 65, RESTRAINING ORDER REQUESTED:
Immediately after this Complaint is accepted by the Court, a Temporary
Restraining Order should issue forthwith from the Court, for Service by United States
Marshall’s Service, as if the plaintiffs herein are acting either en forma pauperis, or
alternatively as a de-facto attorney general. Immediate and Irreparable Harm will result if
the evidence, in any jurisdiction where the practices outlined herein are even suspected to
have existed. And, as a practical matter;
There will be no possible material harm from this injunction simply because
there will be no major upset in the preservation except a slight delay in scheduling for
destruction in each voting jurisdiction, if indeed, no fraud or violation of federal election
law was later found applicable to that jurisdiction.
But on the other hand, massive harm will result if indeed, the same or
similar violations exist in the evidence to be preserved. If destruction occurs, it will be
lost forever. Therefore, the balancing required by the Court for injunctive relief is
satisfied.
The Court, through its normal injunction process should require each State
to and Maryland to:
(1) Notify Each Voting Jurisdiction in the State of Maryland that the deadline of 22
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months for preservation of all voting related evidence, is hereby tolled until further notice
or modification by this or higher Court;
(2) Plaintiffs may serve, notice of a subpoena Duces Tecum, coupled with a sufficient
number of Rule 30 (b)(6) depositions upon, the person(es) designated by the Chief
Executive of each particular voting jurisdiction in Maryland, or nearest equivalent for
that particular jurisdiction most knowledgeable of the subject matter thereof of said
noticed deposition, following the federal standards pertaining to Rule 30 (b)(6)
depositions; and subpoenas accompanied by the necessary documentary information, and
shall require:
(a) the highest officer of each particular jurisdiction to identify, under oath, by the
person or persons most likely to possess such knowledge (a sworn response, and lists,
identifying and indexing in easily legible form, in English, or suitable electronic word
processor, each type of record evidence existing as of November 3, 2020 and three
months before and at all times thereafter, and the custodian thereof of, describing without
limitation of any kind, the following or all other information necessary to describe:
(i) All paper ballots and associated envelopes; of if such exist, any paper or other
written depictions of any purported individual ballots.
(ii) All electronic or optical or other storage media of voting materials.
(iii) All financial records pertaining to monies or items of value in any way related
to voting records or the voting documents themselves, including, but not limited to Grants
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from any Outside of that particular jurisdiction source including federal government
agencies.
(iv) the names, social security numbers, addresses and date of birth of each person
receiving pay, or anything of value, and the amount thereof for performance of any duty
at all pertaining to the presidential election of November 3, 2020, or thereafter, if this
case lasts that long;
(b) A certification under the penalties of perjury, by the Officer(es) described in
paragraph (a) above, that the items furnished conform in substantial compliance with the
requirements of full and complete disclosure of the requirements of this Order.
( c) That the materials required shall be delivered to the respective United States
District Court by electronic means, in PDF format within 21 days of service upon each
such person, or an alternate with explanations as to the substitution or failure to be
furnished within 7 days of the due date thereof.
So Ordered,
_________________________
United States District Judge
For Applicable Jurisdiction.
B. SCOPE OF THE INJUNCTIVE RELIEF REQUESTED
It is counsel's understanding based upon current information as of this
particular defendant CTCL, functioning out of a home base in Chicago, Illinois has also
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operated in other so-called "swing states" during the presidential election of 2020, and
continues to operate in various locations across the nation today.
Plaintiffs understand the burdensome nature of the relief requested in this
case however that burden is deemed minimal as compared to the chaos and upset
resulting from the operations of this purportedly tax-exempt charity, but actually herein
alleged to be a subversive of other enemy of the Constitutional Republic, the United
States of America.
Further, it is recognized that similarly situated persons, even other charities
but in reality, RICO entities who are a part and parcel of this RICO Entity are also in fact,
subversive organizations may be performing identical or very similar unlawful acts.
In that event, as found by this Court, or other constitutional entity, those
components of the RICO Enterprise alleged herein, are likely to exist elsewhere. The
result is the same, regardless of subsidiary camouflage and classification as a RICO
Enterprise with intent to destroy our way of government. And it, so far, has worked.
C. DECLARATORY JUDGMENT OF A RICO ENTERPRISE INFLUENCING

ELECTIONS:
Accordingly, the RICO Enterprise definition fits and should be liberally
applied to render such operations wheresoever found, extinct. The scope of this
complaint therefore, is suggested and requested to the Honorable Court as requiring a
flexibility of jurisdiction and venue across the country proceeding in accordance with the
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existence of these evil elements of our society, destructive of our nation as a whole as a
matter of planned policy and intent.
Subpoenas are requested to be authorized and expected to be served upon
each County or Jurisdiction receiving Grant funds from CTCL, and CTCL itself.
Ancillary thereto, subpoenas for the financial information for all persons to
which such “Grants”, or other payments for services purporting to be for vote collection,
distribution or delivery of forms is necessary evidence. Such evidence is obtainable from
any organization or person receiving funds purporting to be for election related services.
And as such, it is a very small, but highly illegal but effective step to influence a person
short of funds, food or medicine, to vote for the candidate furnishing the benefit.
In consideration of all of these practical difficulties, expedited permission
for a F.R. Civ. P. 30(b)(6) subpoena and depositions of at least each of the three example
Counties are hereby requested as a permissive matter within the limited scope of the
Temporary Restraining Order, with a view toward completion before, and therefore
usable at the projected hearing on the Preliminary Injunction, or even at an accelerated
trial on the merits.
VII. EVIDENTIARY BASIS FOR THESE ALLEGATIONS
The allegations of fact herein are verified by the Declaration of an official
to an informal group of many investigator/citizens, the Chairman and Secretary of that
group, Lewis T. Porter attesting to the veracity of the documents accompanying this filing
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and his experience and observations in over a decade of citizen service to the community.
Other declarations of specific facts are supplemented by reported admissions of party
opponents, and persons of authority producing official government records, admissible
under the business or banking records rules of evidence.
RICO Enterprise allegations of this Complaint, are supported by a
voluminous and detailed information, entitled “The Reconciliation”. That report was
prepared and widely delivered by the group 20-20 Watch, to the Courts the election
structure, and the Governor’s Office. concerning the voting events in Baltimore during
the 2016 election. This report was striking in nature in describing the various vote frauds
before, during and after that presidential election of 2016.
The RICO statute allows a 10 year period to present such evidence, that
evidentiary material. That evidence is also available as probative evidence in support of
the injunctive relief to be requested in this case as well as for presentation at the hearing
on the Preliminary Injunction and for trial. In sum, the Baltimore 2016 evidence
parallels the findings contained in the Maricopa County Arizona presented just in the past
few days, in June 2022. Despite a full disclosure by Mr. Porter to legal and election
authorities, and the Governor, no corrective action has ever occurred to the knowledge of
20-20 Watch or Mr. Porter. Essentially the frauds disclosed remain uncorrected.
As to the current financial payments to each of the 21 jurisdictions,
including Baltimore City who received funds, that information was obtained from a
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referenced source,, fully verifiable with IRS sources as well as each Voting Jurisdiction’s
financial records. Also, obviously, the individual monies paid amount is ultimately
verifiable to the source, either CTCL itself, as to the Grants. or the non-profit charitable
division of the United States Internal Revenue Service.
As a matter of existing law, those particular IRS records are required to be
furnished in annual reports from each such donor. All of these allegations and requests
are based upon the admissions of a party opponent of the existence of the specific
provisions of the signed (similar or substantially identical) contracts of each of the 18
Counties with the purported RICO Enterprise-CTCL and the individual Counties-
Combined. (See Contract Examples- Exhibit #4).
CTCL received to date from Frederick and Carroll Counties, substantially
identical Grant Contracts, substantially the same as to format and terms. Each signed
Contract, required specific, but innocuous political and tax neutral tasks (and of course,
de-facto existing, and expected to be in the basically same boiler-plate format. Howard
County refused to produce the form, but all such 21 Counties are expected to be
subpoenaed immediately after this lawsuit is accepted by the United States District Court.
As a matter of law, such identical contracts must in fact exist, must de-facto
exist since the funds have indeed flowed distributing those funds are as a matter of law
reported in the respective County or City records. Again, see the listing each recipient of
the total funding of the $ 6.2 million as per Exhibit # 1,
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Howard County, the third county examined in some detail, declined to
furnish the contract documents known to exist between it and CTCL. However,
employees of Howard County did furnish comparatively comprehensive details on the
money spent, along with the admission of the exact amount of the Grant.
Those details are revealing. See Exhibit # 5, listing of monies spent which
appear to be entirely payments to named persons. The total dollars paid from this list,
appearing to have been furnished by Howard county employees equals the grant amount
for the county of exactly, $ 688,226. Plaintiffs allege that these amounts paid and
received are not as contracted by the County with CTCL, and believed to have been paid
wholly or in substantial part to harvest and/or deliver Ballots associated. Details of actual
subjects of services rendered are expected to be elicited prior to the schedule set for the
Hearing on the Preliminary Injunction. The requested early approval of the Rule 30(b)(6)
subpoena and key person(es) depositions is expected to reveal details of how the money
was spent, and the degree to which the election law violations, and/or fraud occurred.
Based upon public information dollar numbers, Howard County received
$688,226; Frederick County received $121,975; and Carroll County received $76,536, all
from CTCL
Based upon the monies received by the 18 counties of Maryland accepting
grant funds from CTCL and financial information received from Howard County on
information and belief many hundreds and likely many thousands of unlawful ballots
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were deposited into unmonitored drop-boxes in these three counties analyzed.
Definitive proof in the form of forensic analysis of the ballots by now well
known technological means, demonstrated to be such in the Arizona audit, amongst
others appears to be a readily achievable and practical result. But only if such analysis is
made available of the now existing ballots, and other materials, including envelopes all of
which are slated for destruction but for the requested protective Order in the form of
preservation by the TRO and/or Preliminary Injunction.
VIII. Preliminary Injunction and Trial Proof Matters

Financial Information of Misuse of Grant Funds-Ballot Harvesting.
Plaintiffs’ request to preserve evidence including financial records, paper
ballots and envelopes should be granted beyond the existing September 3, 2022 Federal
Law preservation date. In that event, related materials, records of electronic banking,
financial records and all other matters related to the election voting and record keeping
process, should also be preserved. The preservation should be between the time of the
hearing on the Preliminary Injunction request and trial.
The geographic scope of the preservation should be for all jurisdictions
accepting Grant monies as presented in Exhibit # 1, those 21 jurisdictions. Evidence now
known to exist for the three counties examined, although purported to and contracted to
be innocuous shall be demonstrated to be used in large part unlawfully influence election
results.
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A large component in the unlawful influencing is expected to be
demonstrated to pay couriers (Mules) for collecting otherwise transporting, collecting,
and harvesting ballots by unlawful means. Also, very recently discovered evidence
demonstrates that individuals that moved out of Maryland, (Exhibit # 3) and deceased
voters have in fact received ballots in some Maryland Counties. The matter of deceased
voters is not new, but the persons leaving Maryland, and tracked by the automatic ERIC
system is an apparently brand new and high potential volume of fraudulent source of
genuine appearing, but fraudulent votes.
These are expected to be be investigated via subpoenas, to determine the
magnitude and reported upon in expected post injunction hearings and/or trial the trial on
the merits.
A detailed listing, apparently from Howard County cash disbursement
records, apparently correspond exactly with the Grant amount, of $ 688,226 the amount
listed as a grant received from CTCL. Large payees listed are expected to admit
payments received that are contrary to contractual strictures with CTCL which
demonstrate violations of election laws, and likely tax law. (See Exhibit # 5).
IX. Alleged Falsification of Financial Records CTCL Election Grants,

Hidden Influencing of Votes; Presence of Tax Fraud:
But the setting, that is the magnitude and scope of the evidence of financial,
RICO and vote fraud and corruption as presented herein, requires that consideration of
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the County judicial voting districts be presented as it applies to a the whole State,
Maryland. This requires considering the obvious fact that some of the Counties in
Maryland did not participate in the alleged frauds allegedly conducted by those that
accepted the Grant funds used for the nefarious purposes other than as reported. All of
the Grant funds were subject to a specific purposes, and reporting of how spent is a
contract as well as tax necessity. Accordingly, any funds for which the proper purpose
cannot be proven by the County, should be presumed to be for the purpose alleged, the
recipient having undertaken by contract the enhanced burden of proof.
But, also hopefully clarifying this situation are very recent and striking new
technological events, which lend some hope of resolving the technical difficulties of
reconstruction of the ballot counting process, not just for Maryland, but for the entire
Republic. This is our hopeful prayer for the future, and one which is based upon our
Constitution, and the laws in both Maryland and the Nation.
These plaintiffs will present a balanced picture of the catastrophic events
which are taking place, even as we file this claim for relief, with a suggested path, starting
immediately with injunctive and other equitable relief designed, along with expert aid and
advice with the guiding hand of this Honorable Court. This new path, hopefully uses the
existing structure of our great Constitution and the structure of our law within that
framework.
For this reason, the facts describing the various unlawful activities, and
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possible solutions to the difficulties presented encompass RICO activities as a reality.
The “presence of fraud” in these events is very real. But the analysis of the magnitude
and effects of the frauds upon the actual vote counts, is indeed subject to resolution,
ONLY, if the evidence is preserved, first for the historic 2020 election, and then using
that framework as what NOT to do, create a sound framework under consistent law for
the future. Thereby our way of life and freedoms may be preserved.
This situation and solution covers both civil and criminal activities with a
wide range, both in geographic and law, for presentation to this Court. First, this case
proposes to discuss, and solve the status of vote integrity in Maryland and secondly
effects upon the rest of the Country. Plaintiffs, hopefully, based upon the hope and trust,
indeed an expectation that this Court would agree with the basic propositions and fact put
forth herein, not because of some random factor, like party affiliation, or political view,
but because the facts presented are incontrovertibly true and correct.
X. CONCLUSION
Plaintiffs submit that the existing crisis is one involving the very survival of
this country and our way of life as a Democratic Republic. Whether or not the structure
of our judicial system can handle the demands now before it is of the greatest imaginable
importance. In such a situation our Constitution has been designed to be flexible. We
respectfully urge the Court to consider these matters as presented in this light, utilizing
the wisdom of the Constitutional structure, and truth, to guide all of us to a resolution of
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these difficult and unprecedented times. The citizenry are entitled to fair, and unbiased
treatment, and consideration of all of the facts relevant to matters governing their
existence, heritage and the rights of their progeny into the future, and expect this
Honorable Court, so help us God.
XI. F. R. Civ. RULE 65 (b) REQUEST FOR

A TEMPORARY RESTRAINING ORDER FOLLOWED BY
RULE 65 (a) PRELIMINARY, AND PERMANENT INJUNCTIONS
The evidence in this case as summarized herein, demonstrates that there is a
substantial likelihood of immediate and irreparable harm resulting from destruction of
evidence of unlawful activities both civil and criminal which occurred during
immediately prior to and immediately after the presidential and state elections of
November 3, 2020. According to existing statutes records retention requirements expire
on or about September 3, 2022 when the expiration of 22 months shall have occurred.
Accordingly, this Court is requested to enjoin any and all destruction of

materials protected by Title 52 U.S.C. § 20,701, from the date of filing of this complaint
until the prohibition is lifted, either automatically or by Court order. There shall be no
material risk of substantial damage or harm by the granting of this injunction and great
harm could arise in the event of destruction of material and relevant evidence of
wrongdoing alleged herein by election officials in virtually every county in voting
jurisdiction in the country. A draft temporary restraining order, and Preliminary
Injunction as requested and required by rule 65 is presented following.
For reasons detailed hereinafter, the 22 Month Records Preservation rule
should be extended for all matters, effective immediately, first as a Temporary
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Restraining Order, for all such Records for all Such States, because of matters detailed
herein. And, upon the expiration or Hearing at the time of the Preliminary or Permeant
Injunctions, extended until discharged by a hearing on at permanent injunction at such
time as all issues raised herein have been resolved7.
XII. Likelihood of Destruction of Material and Determinative Evidence,

Consequences, Irreparable Harm Requiring Protective Injunctive Relief:
A Protective Order should be issued with immediate effect, in the form of a
Temporary Restraining Order (TRO) followed by Preliminary and Permanent injunctions.
This is necessary for immediate effect because of ongoing resistance indicated by
persons, all over State now in control of the actual physical evidence which needs to be
protected from destruction pending resolution of this litigation.
7
Federal Code requiring preservation of Election Evidence for 22 months, Otherwise expiring
on or about September 3rd , 2022.
Title 52, U.S.C. 20701: Retention and preservation of records and papers by officers of elections; deposit
with custodian; penalty for violation Text contains those laws in effect on June 18, 2022
CHAPTER 207-FEDERAL ELECTION RECORDS
§20701. Retention and preservation of records and papers by officers of elections; deposit with
custodian; penalty for violation.
Every officer of election shall retain and preserve, for a period of twenty-two months from the
date of any general, special, or primary election of which candidates for the office of President,
Vice President, presidential elector, Member of the Senate, Member of the House of
Representatives, or Resident Commissioner from the Commonwealth of Puerto Rico are voted
for, all records and papers which come into his possession relating to any application,
registration, payment of poll tax, or other act requisite to voting in such election, except that,
when required by law, such records and papers may be delivered to another officer of election
and except that, if a State or the Commonwealth of Puerto Rico designates a custodian to retain
and preserve these records and papers at a specified place, then such records and papers may be
deposited with such custodian, and the duty to retain and preserve any record or paper so
deposited shall devolve upon such custodian. Any officer of election or custodian who willfully
fails to comply with this section shall be fined not more than $1,000 or imprisoned not more than
one year, or both.
( Pub. L. 86–449, title III, §301, May 6, 1960, 74 Stat. 88 .)
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No harm will result from preservation since the only interference will be in
preservation of the status quo as a mere continuation of the present 22 months beginning
November 3rd, 2020, by existing law. (52 U.S.C. § 20,701).
Substantial evidence has been gathered in this lawsuit and well publicized
other civil actions to the effect that fake and false ballots and errors, both intentional and
planned have occurred, not just in this jurisdiction but across the nation. A Temporary
Restraining Order, followed by a Preliminary Injunction is requested to prevent
destruction of all such election related materials in contravention of that statute,
52 U.S.C. §20701. (Retention and preservation of records and papers by officers of
elections; deposit with custodian; penalty for violation), and the need for forthwith
extension of the time of application of the evidence described herein by the Court with its
emergency Protective Order powers. Vital information on the mechanism of election
fraud shall be lost forever, but for this Court’s prevention of destruction.
A draft Temporary Restraining Order is attached as Attachment A, in
accordance with Federal Rule of Civil Procedure 65 (d).
Plaintiffs hereby request a Protective Order preventing destruction of
Election Materials, including, all electronic financial records of employee or independent
contractor, or machine equipment contracts, paper or electronic Ballots, and Envelopes,
until such time as this Honorable Court may hear the follow-on Motion for a Preliminary
Injunction and rescind or modify the Order. See Accompanying Exhibit A-- Draft
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Temporary Restraining Order for Election Material Preservation (TRO)(Attached).
End of Part One.
--------------------------------------
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Part Two, Summary of Facts;

Followed by Detailed Facts and Proposed Orders;
Evidentiary Exhibits;
Temporary Restraining Order-- Draft;
Preliminary Injunction and Restraining Orders– Reserved
---------------------
Comments on Legislation– By Amicus, —CSEAEIF, Inc- - Reserved
----------------------
XIII. SUMMARY OF FACTS
IMMEDIATE INJUNCTIVE RELIEF IN THE FORM OF

A PROTECTIVE ORDER
(PREVENTING DESTRUCTION OF
ELECTION EVIDENCE NOW SCHEDULED FOR DESTRUCTION IN
LESS THAN 90, DAYS, ON OR ABOUT SEPTEMBER 3, 2022).
Background of this Case and Request for Injunctive Relief:
The facts alleged herein, in the form required by Federal Rule of Civil
Procedure 65, and verified form as required by the rule leave no doubt whatever that if
the conditions in voter integrity and proof breakdown and corruption continue into the
next cycle without interruption similar results will occur.
This conclusion is inescapable. The counting of votes is intrinsically a very
simple mathematical exercise. However, like any simple mathematical exercise it must be
correctly done. AND there is only one way to do that, THE CORRECT WAY. This must
be done without any hint of systemic fraud or dishonesty or manipulation in the process.
Sadly, a correct result for the future can be possible without corrections to
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existing politically and dishonestly corrupted procedures and enforced by honest persons
of authority. Under our Constitutional scheme that process and Authority, as the last
resort, is this Court, as the method of last resort in this State. The examples given below,
amplified by the revelations of the past election cycle makes this conclusion, also
inescapable.
XIV. DETAILED STATEMENT OF FACTS
22. This filing is believed to be an unprecedented, unique, but likely determinative
of the future of election fairness in at least for this State.
23. The designation and classification of this case as a potentially multi-district
Federal and Maryland class action appears to be warranted based upon similarity of
claims, and information now available on similarity of methodology of election fraud now
known to exist in multiple, but likely not in all jurisdictions, in the United States.
24. Accordingly, this case is filed on behalf of all honest American citizens who
have been deprived of their Constitutional freedom and right to a fair election in
Maryland, and elsewhere across America, for now and forever with a hope and trust in
God, that this Country as we know and love it survives.
25. Nation-Wide fraud and money laundering, has undoubtedly occurred and shall,
unless stopped in its tracks, occur again. In the 2020 election, in Maryland, in a series of
Twenty-One fraudulent payments to County Government, through apparently normal
official budgeting receipt channels, payments, disguised as “grants” totaling for the 21
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counties, $ 6, 245,797 (million) dollars, monies were “Granted” to 21 Jurisdictions in
Maryland.
26. Apparently through a uniform process by a carefully controlled, “conditional
agreement”, on information and belief, the same “Grantor” (CTCL or Grantor) in a
separate “Boiler-Plate” type document for each county of the 21 County example) in
Maryland, through their party controlled leaders, donated a substantial sum of money
designated for particularly defined uses related to the Presidential Election of 2020.
27. Those funds were carefully proscribed to be spent, by the Grantor, and agreed in
writing as a signatory to the Grant Document by the County Management, for a particular
(purportedly) innocuous and perfectly lawful, usage.
28. But, disclosure of the money spent does not conform with the stated purposes.
The funds were just not spent that way, in fact a large proportion of the funding are alleged
to be for unlawful purposes designed to aid one party, the one party favored by the
Grantor.
29. This allegation, if proven to be true, as it appears from the three County sample
of financial records examined would be a massive violation of election law as well as tax
law, filtering down to every individual who performed any unlawful service.
30. Such violations, by individuals and supervisors would necessarily be in
violation of any of the applicable laws. In addition, all financial officials would be
misreporting budget funds to the extent any misspending or misreporting occurred.
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31. The purported purposes, clearly were disguised, designed and incorporated into
the “Grant Agreement Document” strictures to fraudulently protect the tax exempt status
of the Grantor, but ONLY IF, the Grantor’s Agents, or Principal Donors, knew or should
have known that BOTH the Grants and the Facilitators, the Harvesters paid the big money
listed on the disbursement sheets.
32. It appears, and Plaintiffs allege, that these money launders were, either the
couriers who delivered the harvested and created unlawful votes, or they conspired with
the persons who got paid for delivering them to the drop boxes. In either event, these
persons who received the money, and those that handed it out, were in fact unlawfully
biased.
33. Similarly, so were the very agents doing the negotiation, for the Grantors,
CTCL, and for each receiving County. Implicitly, its management as well as the Grantee
participated in the Tax fraud which are imbedded into this RICO fraud conspiracy process.
34. In this regard, Plaintiffs seek the immediate permission to conduct at least one
Rule 30(b)(6) deposition from each of the three analyzed counties, Frederick, Carroll and
Howard, on a forthwith basis.
35. Permission is requested to require, immediately upon service, that each County
to furnish the person or persons who negotiated with the Grantor, and those who assigned
personnel and equipment and expended the funds donated including record-keeping on
those expenditures, including personnel for a Rule 30(b)(6) deposition, after responding to
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subpoenas for the relevant documents for each county where material deviation from
normal is indicated.
36. It is expected that testimony will be elicited to the effect that the requirements
expected by the Grantor (CTCL) included prohibited practices, and the Grantor’s funding
persons were well aware of the unlawful nature of the actual requirements as distinguished
from the purported fraudulent requirements of the written Grants. This was because
neither the Grantor, nor the Grantee ever expected those “paper” requirements to be
followed.
37. If those requirements were serious, and other than a fraud which they were,
there would have been some follow-up, corrections and corrected reporting on the actual
incorrect, i.e. overpayments, underpayments or simple reporting errors, or missing a
required limit. It is telling that not only were there none, there were not even any
semblance of any such bookkeeping adjustments.
38. However, after three counties of comparisons, there were no such corrective
actions, not a hint of a single one. This apparent fact demonstrates forcefully the fact of
the subterfuge.
39. In this regard, Plaintiffs request permission to advance and notice several
30(b)(6) depositions, along with necessary subpoenas, forthwith, before the hearing on the
Preliminary Injunction to clarify facts necessary aid the Court at the time of the
Preliminary Injunction hearing.
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40. This information, easily obtained, will demonstrate this key element of the
financial manipulations of each counties record. This is evidence demonstrating the
financing element of the actual vote counting fraud throughout the State of Maryland.
41. As a related but different aspect of the presence of fraud in this entire
situation, those same manipulations were in fact an enabling fraud which violated Federal
Tax law, both individual (as to the contributors and managers of the “purported charitya’,
and lack of enforcement by IRS as a federal agency. The truth is, that the purported tax
constraints were nothing but sham requirements designed to facilitate and hide the real
purpose of the alleged charity, vote fraud, paid for by our own Federal Government via
loss of tax revenue by extremely wealthy contributors. The requirements were merely a
fraud for subverting the legal requirements with camouflage, and the fraud worked,
beautifully.
42. It has been admitted by the Elections Board of Frederick County, by its
chairman, a county employee, that for the past presidential election, there were 8 drop
boxes in Frederick, County and Eight cameras for surveillance.
43. And none were ever monitored (Admission of party opponents in open
meetings).
44. The lead Plaintiff, Ms Gibson, was on election day, a trained Judge of
elections, however, she was ill and therefore could not serve as a judge. However, she did
vote, at one of the drop boxes. She, while attempting to deposit her ballot, observed and
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interacted with a person depositing a substantial number of ballots into the drop-box and
inquired, “what are you doing”. The person responded, “I am making a delivery from the
Post Office”, then quickly got in his vehicle. (Declaration, Lois Ann Gibson) (Exhibit # 2-
1).
45. When later, at a Board meeting, further questioning elicited the responses to the
effect that the video tape cameras were never monitored, so all such events have for the
entire period of drop-box use, apparently been without any intervention, control or
monitoring whatsoever. All of this failure is contrary to the requirements, of the Maryland
constitution for which the State of Maryland, and the Maryland State Prosecutor have the
duty to monitor fraud and abuse. They failed.
46. An oral admission from the Board of Elections of Frederick County is believed
to report that the surveillance cameras for the eight drop-box locations were privately
owned, privately controlled, and no examination at all has ever been made of the tapes
which would indicate with specificity the identity of the couriers acting as mules for the
fake overrun ballots.
47. This entire subject shall be explored for available probative evidence utilizing
30(b)(6) depositions and subpoenas just as soon as the Court authorizes such usage. The
suggested plan (at this time, subject to change) is to start small to obtain details on the
methodology of the fraud, present the facts at the hearing for a preliminary injunction, and
plan the trial evidence gathering soon thereafter.
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48. All of the 21 Counties would be expected to be analyzed for fraudulent drop
boxes and addresses, in detail, with the burden placed upon the County, in each instance
to show a reasonable methodology preventing fraudulent count results. All of this would
be prospectively applied and controlled, with the consequences of the past election to
follow as dictated by the Court to follow in due course thereafter.
49. The accounting records for the three counties examined indicate manipulation
of the county disbursement records to conform to the penny to the grant amounts. As an
accounting matter this item alone renders these figures suspect. These indicators
cumulatively demonstrate that it is extremely likely that the identity of the recipients of the
funds, which does appear to be recoverable via subpoenas, coupled with a deposition
would indicate with specificity that these particular persons performed at least some of the
fraudulent acts. Those resulting, in counting of inactive voters and deceased voters, for
example, and the electronic manipulation of ballot results.
50. This conclusion conforms to the results observed across the country and the strikingly
similar pattern of the unlawful Corporate Financing of the voter fraud. See below for
confirmation of this actions of the part time workers, hired by the unlawful corporate
money. These actual tasks, as compared to the non-partisan tasks for which they were
purportedly hired shall be gleaned, for those part time workers specifically, one way or
another, by the planned subpoenas and depositions, hopefully as approved by the Court on
an emergency basis prior to the hearing on the Preliminary Injunction.
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51. On information and belief, all of the voting machines in Maryland are all under the
control of the Dominion/ES&S Rico Enterprise, rented or owned or otherwise a controlled
system. This system, and management controls are well established to have online
capabilities and manipulation capabilities actually observed as such on multiple occasions.
52. Repeated inquiries for a description of the chain of custody of ballots removed from
drop boxes (if any exist and subsequent handling), i.e. , placing of ballots into the boxes,
removal from the boxes and forwarded ballots to machine counting or other accumulation
stations. Control counts apparently for the three counties apparently do not exist.
53. Certainly, no such detailed descriptions of control methodologies have ever been
received in response to inquiries. No response at all has ever been received from the three
counties examined. And again, no surveillance tapes or results have also ever been
described in materials received, and apparently, on information and belief, do not exist.
54. This aspect of the analysis for the three counties is presently being re-verified, and
shall be subject to the subpoena process in the interim between the filing of this complaint
and the requested hearing on the Preliminary Injunction.
55. On information and belief a substantial number of persons received funding from
participation in the collection of ballots from voters, and distribution to drop-boxes. See
testimony of plaintiff Gibson (Exhibit # 2-1) and adjoining County detailed payments,
(Exhibit # 5) , and the newly discovered scheme (Harvesting unused ballots from voters
who have left the state, via the ERIC system, Exhibit # 3).
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56. Disbursement records disclose that some individuals received multiple checks or
money orders for paid activities that remain undisclosed in the disbursements record,
despite repeated inquiries. Relatively large sums of money for specific persons who
received more than one check have been observed, without the explanation of duties
required by the Grant Contract. As mentioned earlier, three persons from Howard County
received identical sums of over $ 11,000 each, out of a total of over 800 individual money
distributions.
57. A Federal Rule of Civil Procedure Rule 30 (b)(6) deposition coupled with a subpoena
for disbursement documents is presently being requested to be permitted, one such
subpoena and deposition, for each of the three counties for which the initial investigation
leading to injunctive relief is requested.
58. Similar inquiries are expected based upon the successes to be achieved by this
investigative result during the immediate interim week following filing of this complaint,
as applicable to the remaining 18 Counties receiving Grant funds (Exhibit #1).
59. A substantial equipment expenditure appears in disbursement records for the three
Counties for which expenditure data was only partially acquired. The request for several
subpoenas pursuant to a Rule 30(b)(6) deposition, and equipment disclosures shall include
a production and/or inspection of all such equipment, and also ballots, with envelopes
made available for inspection and copying for test purposes.
60. It is expected that a subpoena for production of all electronic images of voting
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and actual paper ballots and envelopes will require a subpoena for leave to examine all
ballots by electronic equipment, likely for all three sample counties.
61. To date requests for such complete production have been resisted, (in two of
the three examined counties) accompanied by a demand for payment for purported
retrieval expenses.
62. At the hearing for a Preliminary Injunction, a request shall be made for a
protective order requiring production of each and every ballot and envelope as well as
electronic images, to the extent such exist. It is not expected that such production will be
on an emergency basis, but a substantial testing is necessary for a complete analysis of the
allegation that false or duplicate copies of ballots were manufactured as a part of the
alleged fraud. Such forensic testing is now well known to be within the state of the
balloting art and science (Ref. Jovan Hutton Pulitzer, et al).
Three Kinds of Fraud in the Grants
63. The three kinds of fraud in the Grants are: (1) To hand out money, purportedly
for a lawful purpose, but as a hidden yet operative part, the real agenda, is to never
countermand, or challenge the misuse and misreporting by the governmental agency of the
actual unlawful use of the funds, and the cover-up of the misuse by misreporting. The
actual use of the funds, that is the actual monies spent from the disbursement records have
been furnished. Those expenditures do not comport with the purported uses required by
the Contracts. Again, the use of at least one Rule 30(b)(6) deposition as to what was done,
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and the associated equipment expenses is expected to elicit details of specific matters
directly related to election ballot and counting fraud. This fact has implications wherever
it has occurred. And it appears to be identical from the consistency of the contracts
required for rewarding of the Grant(s) across Maryland (See Exhibit # 1, - grants from
same grantor, $ 6. 2 Million). (2) disclosure of tax fraud by those large -money
contributors. (3) the Grantor fund would itself be participating in a tax-fraud and would
lose its exemption from tax laws retroactively, with parallel effects upon its donor
contributors.
64. The purportedly innocuous classification of Grant Use matters are by no means
routine violations or mere error. Such manipulation of decades-old IRS Section 501(c)(3)
principles are: (when demonstrated to have occurred with knowledge or intent as appears
herein) would be in reality intentional violations of Tax law, by both the Grantor and the
Grantor’s principals, those with knowledge, who participated in the tax evasion as well as
the misreporting of fraudulent received funds, with intent to subvert the election laws of
the State of Maryland as well as the Tax Laws applicable to non-profit 501 (c)(3)
organizations (For Example, Defendant CTCL) .
65. The existence of these malfunctions have been disclosed and are alleged in this
filing. Given the apparently reoccurring and casual nature of the misreporting discovered
as to the three Counties investigated, to date but only considered as a voting integrity
matter, the evidence is nevertheless clear.
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66. For this reason, all records of all related financial transactions, Grants, reports
of expenditures, 1099 forms for all employees, whether regular or temporary, to deliver
and pick-up ballots, or otherwise are hard documentary evidence of the intent to use
misstatements of or mislabeling of entries into financial records to cover-up the fraud in
the ballot fabrication and false delivery process.
67. And this process will undoubtedly be repeated in future elections unless it is
corrected forthwith, with this lawsuit.
68. Second, the Grantor, the non-profit organization, would upon demonstration of
a biased, non-qualified for charitable taxable use of Grants, be expected to lose its tax
exempt status under IRS Code Section, 501(c)(3). In this event, where the contributors
conspired with the Grantor, and took tax deductions, they would be expected to be
participating in a tax fraud.
69. If, as reputed, large contributors were involved with knowledge of these
improper tax deductions, those Contributors could be liable for recovery for Tax Fraud,
and possible false claims act liability.
70. This disclosure would be expected to have severe consequences to each of the
large contributors who it appears have funded the unlawful nation-wide constitutional
violations, while being rewarded for their unlawful efforts with large tax deductions, to
which they were not in fact eligible. Such considerations would be a related matter to the
main thrust of these claims of voter fraud.
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71. Cleverly, and apparently incorrectly, and if with knowledge of the falsities, the
agreement with each conspiring donee voting jurisdiction (a County, like here Frederick,
Howard, and Carroll, and presumably 18 others) would have to agree to spend the money
for the legitimate purposes as agreed.
72. If the constraints were not met, as they apparently were not, at least in some
instances, each such failing jurisdiction would purportedly (under the terms of the
contract) have to refund the Grant. Apparently none have done so. Each such instance
would be both a voting law violation, and a tax law violation, and each such fabricated
vote would be a constitutional violation if each plaintiff voter whose vote is negated by the
false procedures.
73. New technology now aids in identifying and proof of the various
methodologies to catalog and prove each type of fraud. This has now become practical,
given the disclosure of the Ballots and Envelopes, to an amazing extent.
74. To the extent each official who disbursed the money and covered up the failure
to spend it as agreed, that person would also be committing, or at least aiding and abetting
the overall tax evasion scheme, for every 1099 error and each tax deduction as well. If any
part of the funds were used for an unauthorized, or unlawful purpose, that County would
be in violation of the Maryland Election law.
75. To the extent this evidence, when placed in good form via, subpoenas and
depositions an election law violation has occurred, and will thus occur again unless this
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system is disassembled by legal edict, of one kind or another. This malfunction of the
working persons level within each county government accepting such funds now has
become clear.
76. To this end, once the equitable relief necessary for corrective action become
effective by Order of the Honorable Court, it appears that corrective action in the form of
legislative actions, or even jury decisions may become necessary as determined according
to constitutional constrains under the existing Twombly/Iqbal standard,
77. Nevertheless, as to Grant funds received and expended, the evidence clearly
shows, when finally produced, after years of attempting to obtain it, the purposes for
which the money was spent do not conform to the agreed in writing, election neutral
purposes. Testing of actual uses of the funds as comparted to the required partizan neutral
requirement is expected to demonstrate unlawful bias pervading the Grant distribution
process along prohibited partizan lines. And also cover-up of the violations by knowingly
false financial reporting.
78. Thereby, the honest functioning of Maryland’s entire constitutional process is
not only threatened, but virtually guaranteed to fail in the upcoming election as well. All
that must occur to assure this result and to assure the replication from now on, is a simple
expansion and repeat performance of the “Gibson drop-box trick” which is, by all of the
available evidence, now alive and well in Maryland. (See, Exhibit # 2,1. Declaration of
Witness, Lois Ann Gibson).
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79. To demonstrate the magnitude and the prevalence of the unlawful practices in
Maryland these Plaintiffs submit herewith both anecdotal and sampling evidence
demonstrating the existence of election fraud. The frauds have occurred, both in the
biased financing of the election operations, in hiring of personnel and the false and/or
inaccurate reporting of funds spent as received from Grants, and in the misdirection or
obstruction of inquiries regarding expenditures of “Grants”.
80. All but three Counties in Maryland have partaken of the funding by outside
influences, subject to control over the spending. That control, apparently is uniform in
abuse of not conforming to Federal Guidelines, this also being apparently a tongue- in-
cheek, disguise according to the sampling completed as of the date of this filing. The first
three counties for which data has been retrieved and examined. 18 more counties have
received the suspect funds, but expenditures have yet to be analyzed by plaintiffs herein.
See Exhibit # 1 for Total Funding Reported for Maryland, subject to analysis. $ 6,245,797.
81. The events described in this lawsuit, unless placed under judicial control,
immediately, threaten the stability of the Republic, threaten to destroy all hope of any fair
election process for all time.
82. This filing is also pursuant to the Constitution of the United States of America
and the Constitution of the State of Maryland’s believed to be unique Amendment. That
amendment, established the Maryland Office of the State Prosecutor 8with the jurisdiction
and specific power to investigate election fraud.
That agency has not yet responded to our requests for an investigation and/or
8
Maryland State Prosecutor - Origin & Functions, https://msa.maryland.gov › msa ›
mdmanual › html. The office of State Prosecutor was established by Constitutional Amendment
in 1976 (Chapter 612, Acts of 1976, ratified Nov. 2, 1976). Part of the Constitutional duties of
that Office is to maintain election integrity, free from fraud or political abuse.
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aid in the investigation of the factual underpinnings of these Class Actions.
83. This filing is also, pursuant to federal rule of civil procedure 23, alleging,
among other violations, a RICO conspiracy by multiple parties, alleging fraud, money
laundering and bribery; a conspiracy to violate federal constitutional liberty, due process
of law, and federal and state civil rights (abrogation of voting privileges by fraudulent
dilution of valid votes.
84. This filing is also against the State of Maryland in that the Constitution of the
State of Maryland, in an Amendment thereto established the Office of the Maryland State
Prosecutor, with the specific jurisdiction and authority to investigate Election related
violations of law and fraud. This State failed to carry-out its duty to insure that the voters
systems and function were free from fraud, manipulation and malfunction.
85. Accordingly, the State of Maryland should be held accountable for all expenses
of remedial action with regard to all of the matters herein, and funding of corrective
measures including the attorney’s fees and costs of this litigation and all cures required to
create a workable fraud free system beginning immediately.
86. This prospective loss of the right to vote, is material, genuine, and
undeniable, both as to what has previously occurred, and prospective continuing
irreparable harm absence of the required extraordinary corrective action.
Immediate and Irreparable Harm Has Occurred and is Continuing:
87. Immediate and irreparable harm has already occurred, is continuing, and is, on
information and belief is now being planned by the wrongdoers to be repeated. Thereby
absent extraordinary emergency action by this Court shall be not just continue, but to be
exacerbated, and will occur again into the foreseeable future. There is no reason why any
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doubt whatever exists as to the likelihood of these fraudulent actions to continue.
88. Need for Injunctive Relief with evidence Protective Orders, Witness Protection and
mandatory financial and date protection Orders are required to extend the preservation of
evidence to Conform to 52 U.S.C. § 20701 until full knowledge of these complex facts
can be disclosed, corrected and expunged for all time from our governmental acceptable
function.
89. These acts shall continue, as in the normal course, with continuing immediate
irreparable and unconscionable damages, so long as the denials of rights extant in the
occurrences of the past and foreseeable future are not corrected. All of this is contrary to
the contract contained in both the Maryland Constitution, and the Constitution of the
United States of America. The Property, Liberty, and Voting Rights, of each State of their
residency’s guarantees, (for example here) these Plaintiffs, the State of Maryland, and/or
in their respective State (Again Here the State of Maryland) by the events described in this
Complaint for Relief and/or as attached.
90. NOTICE OF INTENT TO REQUEST A CLASS OR CLASSES OF NAMED

CLASS REPRESENTATIVES:
Approximately one named class representative is expected to be selected to
represent each political subdivision of the State of Maryland, and similarly, for each state,
to act for themselves and a class (or classes) of all other citizens of every qualified vested
voter of Maryland and all other persons, in Districts across the Country, similarly situated,
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as a F. R. Civ. P. Rule 23, class and/or, Alternatively an Opt-In collective action, or both.
91. THE CLASS(ES) OF PLAINTIFFS:
This case is a Federal Claim’s Multi-District RICO Federal Rule of Civil
Procedure, Rule 23, Class Action. Also, alternatively, a Collective Action by a large class
group, or alternatively a Opt-In collective action Citizen/Voters.
XV. CLASS DEFINITION
The class consists of each damaged or injured Citizen Registered Voter.

Each eligible member of the putative class who has had his/her liberty and voting right
either abrogated or diverted or excised. Each class member who was thereby denied a
fair/and/or honest vote, whether or not he/she attempted to exercise that vote, in the past
election (of 2020), and/or shall, if no intervention and relief by this Court occurs, be
denied of their fair and correct vote and resulting denial of property and freedom
guaranteed by the Federal Constitution, by similar nefarious means in the next scheduled
Federal Election, and/or thereafter.
XVI. MOTION FOR A TEMPORARY RESTRAINING ORDER
A. Plaintiffs Hereby Request an Extraordinary Forthwith Emergency
Temporary Restraining Order to Require, Permanent Preservation of Evidence of the
Ballots, Envelopes and All Related Election Records, Both Financial and Operative,
Related to the Presidential Election of 2020, under Penalties of a Finding of Violation of
Felony Spoilation of Federal Election Materials:
Without a forthwith Protective Order, reminding Defendants of the duty to
preserve evidence, coupled with extension of the currently effective evidence preservation
date of September 3, 2022 will undoubtedly result in destruction of evidence, with
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irrevocable and irrecoverable harm. The evidence of malfunctions will be forever lost
from recovery. Accordingly the preservation Order included in a Temporary Restraining
Order should issue, postponing destruction of all election materials pending further Order
of Count.
B. Linked to the preservation of evidence, and considering the great benefits
of additional, easily obtainable evidence Plaintiffs Request Permission immediately upon
service of process, to Issue 3 to 6 Subpoenas for Documents and Two Rule 30(b)(6)
deposition notices for each County or voting jurisdiction in Maryland.
C. This Request for Documentary Evidence Production via Subpoena, and
30(b)(6) testimony supporting document production information, is Intended to Produce
Documents and Testimony which shall, be presented at the Initial Hearing on a
Preliminary Injunction, produce overwhelming and definitive proof of the actual facts and
magnitude, in each of these 21 counties voting jurisdiction im Maryland resulting in the
massive election fraud which, now, has become impossible to deny existed. The use of the
subpoena power of the Court will greatly simplify and clarify the Injunction presentation
clarify the interests of truth and justice.
D. A draft Temporary Restraining Order is Attached as per F. R. Civ. P.
Rule 65(b)(A). In the event this Order is not Granted, all election materials, including
Envelopes and Ballots, and financial records are subject to destruction, pursuant to 52
U.S.C. § 20,701.
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Undersigned Counsel certifies pursuant to F. R. Civ. P. Rule 65 (b)(B) that
in several of the voting jurisdictions, repeated request by Plaintiffs utilizing normal
informal and PIA methods have elicited oral or non responsive answers, strongly
indicating that preservation method are already being violated, or never existed in the first
instance. Therefore further destruction of key evidence is likely and expected to occur
without, or even in spite of a Temporary Restraining Order.
For this reason a TRO should be issued with the normal expiration date of 14
days, subject to renewal as per Rule 65. A draft Order is Attached as Exhibit A.
XVII. CONCLUSION
For all of the above reasons the accompanying draft Temporary Restraining
Order for 14 days, renewable as needed to extend the statutory destruction date for Eletion
materials and financial records of September 3, 2022, renewable upon application, should
be granted. Further permission for the issuance of 5 Notices of F. R. Civ. P.30(b)(6)
depositions is granted. Attachment A is a draft Temporary Restraining Order.
As to the accompanying request for permission to take several Rule 30(b)(6)
depositions, the Court should limit quashing of production of materials requested, incident
to reasonable, substantial and material reasons move to quash any Notice of Deposition
upon a demonstration of substantial burdensomeness or other just cause shown.
Because of the complexity of the alleged frauds, Plaintiffs expect to detail
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the preparation of a proposed draft of the Preliminary Injunction is respectfully reserved
until after the evidentiary heating on the Injunction itself, or as combined with a trial on
the merits.
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XVIII. VERIFICATION
I, Lewis T. Porter, am a named plaintiff in this case, and I am over the age of
18, a Citizen of the State of Maryland, and otherwise qualified to testify before this Court;
I hereby swear under the penalties of perjury that all of the facts appearing herein, and as
attached to this Complaint and Requests for Injunctive relief are true and correct as stated
and each evidentiary attachment hereto is a genuine document to the best of my current,
knowledge, information and belief.
Respectfully submitted,
Lewis T. Porter, Electronic Signature, Plaintiff/ Investigator, Secretary 20-20 Watch
Lewis T. Porter, June 28, 2022
Walter T. Charlton, Electronic Signature, June 28, 2022
Walter T. Charlton, Esq.,

DC Bar # 186940,
Maryland United States District Court Bar # 07638
Walter T. Charlton & Associates, CPA/Attorney
11213 Angus Way, Woodsboro, Maryland 21798
Telephone, 410 571 8764, email, charltonwt @ comcast.net
Post Office Box # 370, Woodsboro, Maryland 21798
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INDEX OF ATTACHMENTS
Attachment A- Draft Temporary Restraining Order..........................................
Motion for a Temporary Restraining Order, Preliminary Injunction and

Permanent Injunctive Relief...................................................................
Exhibit # 1 Grants to 21 Maryland Counties and Baltimore City, ... $ 6, 245,797.
Exhibit # 2 .1 Declaration of Eye-Witness to Ballot Stuffing, Lois Ann Gibson.
Exhibit # 2..2 Declaration of Two Witnesses, Names Redacted..........................
Exhibit # 3 Declaration of Newly Non-Resident, Kurt Kolb, regarding

Automated Voter Harvesting, ..............................................
Exhibit # 4 Frederick and Carroll County Grant Contracts, with Terms ...........
Exhibit # 5 Howard County, List of Payments of Exact Money Dollars

Received in Grants from Chicago Charity,
Center for :Tech and Civic Life, (CTCL) $ 688,226, distributed
in Same Amount, $ 688,226, to List of about 730 Named Persons
also Furnished from disbursement Records of Howard County ................
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__________________________________________________
)
Lois Ann Gibson, et al )
)
V. )
)
A RICO Enterprise and the State of Maryland, et al, )
__________________________________________________)
EMERGENCY MOTION FOR A TEMPORARY RESTRAINING ORDER AND

PRELIMINARY INJUNCTION PREVENTING DESTRUCTION OF EVIDENCE
Plaintiffs hereby request an extraordinary forthwith emergency Temporary
Restraining Order to require, permanent preservation of evidence of the election ballots,
envelopes and all related election records, both financial and operative, related to the
Presidential Election of 2020, under the provisions of 52, U.S.C § 20,701 and as extended
by this Honorable Court pursuant to the rulings in this case.
This Motion requests that this Order be extended, as necessary to remain in
effect subsequent to the expiration time effective on September 3, 2022, pursuant to the
provisions 52 U.S.C § 20,701, and this Motion pursuant to F.R. Civ. Rule 65(b)(2).
This Motion also requests the Hearing on the Preliminary Injunction be held
as soon as possible after the completion of the first round of about 3 depositions notified
pursuant to F.R. Civ. P. 30 (b) 6.
The accompanying Memorandum of Points and authorities supports the
entry of this Order.
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Lewis T. Porter, Electronic Signature,
Plaintiff/ Investigator, Chairman/Secretary 20-20 Watch
Lewis T. Porter, June 28, 2022
Walter T. Charlton, Electronic Signature, June 27, 2022

DC Bar # 186940,
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Case 1:22-cv-01642-SAG Document 2-1 Filed 07/05/22 Page 1 of 9
ATTACHMENT A
DRAFT V- 9 TEMPORARY RESTRAINING ORDER
UNITED STATES DISTRICT COURT FOR

THE DISTRICT OF MARYLAND
____________________________________________
)
) Case _____________
V. )
)
A RICO Enterprise and )
the State of Maryland, et al )
____________________________________________ )
EMERGENCY TEMPORARY RESTRAINING ORDER

AND, NOTICE OF APPLICATION OF 52 U.S.C. § 20,701
NOTICE TO DEFENDANTS AND OTHERS:
(1) Defendants and Other Are notified, that Preventing Destruction of
Election Materials and Financial Records for 22 Months, is already prohibited, to
September 3, 2022; Defendant and Others are hereby Notified and Ordered to preserve all
such materials, for an additional 14 days beyond September 3, 2022, or as Further
Extended by this case by Order. The Court finds that it has jurisdiction to act pursuant to
Federal Rule of Civil Procedure, 65, to enforce 52 U .S. C. § 20,701 and 6 U.S.C. § 451,
as well as the factual evidence, mostly in documentary form, cited in the Verified
Complaint. Immediate and irreparable harm is likely to occur because the likely
perpetrators of election fraud are alleged to be the same persons as some of the
defendants herein. Therefore, destruction of election materials protected by 52 U.S.C. §
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20,701 and other cited statutes is likely unless protected from the very beginning. The
chief executives of each defendant organization are hereby notified that any destruction
that occurs, or indeed has already occurred are their responsibility as an aider and abettor,
if they know and/or participate of any such destruction.
The request under this TRO is inter alia, to hold in place the voter
information and documents associated that “maintain the status quo ante” in this dispute.
Further, this request for preliminary injunction specifically to preserve evidence that
would otherwise by Notice be destroyed.1
EVIDENTIARY CONSIDERATIONS
The Court has considered the verified complaint, and verified allegations
contained in accompanying verifications and declarations, with verified evidentiary
attachments. Among other things applicable to 21 Maryland Counties and Baltimore City
are that requests for public information, made in the normal course of routine
verifications by plaintiff's herein. Those documents obtained from defendants have
disclosed alleged fraudulent activities in the financing and false reporting of payments.
The allegation is that those disbursements as reported by the county do not
correspond to the valid purpose required by both the election law and IRS Regulations.
Therefore, they are alleged to be other than the purported politically neutral election
donations and expenses as required by the election law. In fact, based on collateral
1
Quotes are from Federal Civil Rules Handbook 2022, Baicker-McKee Janssen -
Thomson Reuters, Page 1326-1327 excerpts from authors commentary on Rule 65.
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evidence, plaintiffs allege that at least some of the persons receiving these funds were
illicit workers who were couriers of fake ballots.
Plaintiffs request that permission be granted to verify this allegation by
depositions of key performers identified by a list of admitted recipients of election funds
by the county receiving about $688,000 from an alleged co-conspirator. If this allegation
proves correct, and is extended to other counties receiving such funds, not only is the
allegation of voter fraud confirmed, but allegations of a RICO entity will be confirmed
beyond any reasonable denial.
Because the methodology is practical, affordable and will cause virtually no
damage or cost to the defendants, unless they are deemed innocent of these allegations,
this request is GRANTED.
However, plaintiffs are admonished to keep expenses to the defendant at a
minimum until such time as these crucial allegations are confirmed.
OTHER EVIDENCE
The list of recipients of the grant funds disbursements (Exhibit 5) contains
many, in fact the great majority, of payments in round dollar amounts. Plaintiffs allege
that this fact corresponds to the purported practice of paying ballot fabricators/ couriers of
fake ballots $5.00 or $10.00 each.
The purpose of the request for immediate subpoena issuance and Rule
30 (b) (6) depositions is to verify in detail these striking allegations before the time for
hearing of the requested Preliminary Injunction.
This allegation also, if proven to be true, in the depositions would be yet
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another example of why the Emergency TRO and request for immediate limited discovery
is reasonable. Again in both of these instances the weight of cost and damages for
allowance favors plaintiff’s request. The value to the American voter is incalculable as to
compared to the potential damage to the defendants.
DIRECT EVIDENCE
Two eyewitness verified reports allege ballot stuffing into two of the Eight
Frederick County unguarded and non-operational, but purportedly under camera
surveillance, Drop-Boxes.
Further supplemental evidence is submitted as follows: At a subsequent
public hearing, the Election Board admitted that surveillance cameras associated with the
8 the drop- boxes in the Frederick were not owned or controlled by the County, and never
examined. Accordingly, it is admitted that no security over the “live” ballots existed.
Under these circumstances, verified as to have occurred, the Court is
inclined to recognize that a valid and important emergency situation exists.
EMERGENCY TEMPORARY RESTRAINING ORDER
The Court finds that: In the event the existing protected voting materials
and records are destroyed, no such repair or evidence of inadequate systems for use to
repair future procedures in elections are possible. The next cycle of elections is about to
begin, and the expiration date for the 2020 materials preservation is about to expire, on
or about September 3, 2022. Thereby, the timing of this lawsuit, and the need for
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preservation has now become an emergency matter.
Unless protected from the unlawful practices outlined herein with
specificity, it is virtually inevitable that irreparable harm and loss of essential evidence
will occur resulting in violations of Federal Statutes. More importantly, any hope for
restoring any semblance of a correct and verified vote is gone.
Accordingly, it is hereby Ordered That:
1. Beginning today July ____, 2022 all persons, whether employed by any one of the 21
counties and Baltimore City who are defendant herein, and therefore being personally
subjected to litigation on this point, or private persons having access to protected
materials, shall refrain from any act that obscures, hides, or destroys, or delays production
of protected election materials, whether before the cutoff date under current federal law
or there after so long as this temporary restraining order, as extended by Order of Court,
remains in force, subject to further Order of Court.
2. A Temporary Restraining Order shall be granted pursuant to Federal Rule of Civil
Procedure, 65(b); subject an evidentiary hearing at a Preliminary Injunction hearing
pursuant to Federal Rule of Civil Procedure 65 (a), which shall be scheduled for the
________ day of July 2022, or as rescheduled by the Court;
3. Permission is hereby granted to Plaintiffs, to conduct discovery limited to subpoenas
for documents and things, and no more than 10 depositions with document subpoenas
pursuant to Federal Rule of Civil Procedure 30(b)(6) or as expanded further by this Court.
4. The topic scope of such subpoenas shall include but not be limited to, election
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materials or financial records and systems used by each deponent or agent thereof, as
election records and materials of all kinds, including election envelopes and financial
records, including and not limited to records of agents or employees earnings or contract
payments to those persons or corporations or informal entities in elections which include
the Precedential Elections of 2016 and 2020; At Footnote 2, citing Dominion Video
Satellite, Inc. v. EchoStar Satellite Corp. 269 F.3rd 1149, 1154-55 (10 Cir. 2001). It is
anticipated that deponents pursuant to the Cited Rule, F.R,Civ.P 30(b)(6), may include,
Counties or Election Jurisdictions and Contractors therewith, including its own
employees, to produce Election Materials and Financial Records Regarding Election cash
or services received, and expenses or cash disbursements paid including IRS records for
each contractor or election employee within 3 days after notice or service of this Case or
as requested by a contemporaneous subpoena upon that Defendant.
5. The Court finds that no bond is necessary in this matter as there is little likelihood of
substantial damage or harm, but rather likely to be, absent unlawful violations of this
Order, a mere continuation of the status quo.
6. Forthwith service of process and notification of this order by email or first class mail,
shall be accomplished by Plaintiffs. and the filing of this lawsuit suit shall occur either by
electronic notice and/or mail notification, to registered agents for corporations, absent any
objection to service of process by this means by any one of these government entities or
private parties.
SERVICE OF PROCESS ON DEFENDANTS
In the event of any objection of this means of service of process, and for
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other defendants in this case, for example the grantor, the regular service of process shall
be followed, except that, the grantor shall be notified by email service along with the
notification of the 20 counties and Baltimore city.
The Court has weighed the inconvenience or expense resulting from
enforcing the requested restraining order against the benefits and breaches of applicable
law preventing such destruction, and finds that the potential of harm, and dangers of
irreparable harm and damages resulting from preserving the status quo of these materials
is negligible while the benefits resulting from a full disclosure of all applicable facts
completely outweighs the possibilities of damages to the custodians of such evidence at
this time. The Court finds no Bond is necessary under these circumstances.
Protection of Innocent Election Workers
However, the Court finds that the 760 named person may, and likely does
include innocent persons as well as perpetrators of the frauds alleged, and violators of
existing Federal Code. Accordingly, the names appearing on Exhibit 5, shall be accepted
by the Court, provisionally, and redacted in all notices and service of process, pending the
results of the F. R. Civ P. Rule 30(b)(6) depositions completion. The Court shall likely
reconsider the publication(s) of defendant’s names after the more complete evidentiary
facts are known.
Accordingly, Exhibit 5 shall be filed under seal, subject to disclosure to
Counsel, marked under seal, with admonitions that all names initially shall be kept
confidential. Further, the Court Orders, that, upon completion of the initial 30(b)(6)
deposition, a report be rendered to serve the Court as guidance as to the extent of
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necessary depositions, and the assessment of costs to finance said depositions and
document production.
This Court Grants this Motion, By separate Orders:
(1) This Temporary Restraining Order is Granted.
(2) Permission to take the first 30(b)(6) deposition with subpoenas as appropriate
is granted. The purposes of the questioning and documents acquired are to be limited by
the judgment of the Plaintiff’s counsel to carefully consider the relevance of the
information sought to inquiries likely to disclose unlawful acts, and refrain from
unwarranted political fishing expeditions; or those designed to identify corrections to
obviously deficient, and/or to identify the same alleged practices with means to facilitate
correction of those practices that are expected to be utilized in upcoming elections in the
future.
So Ordered:
The Court finds that Federal law, (52 U.S.C. § 20,701) prohibits destruction
of election materials for 22 months, expiring in this instance on or about September 3,
2022. And it is further alleged that there is a danger that materials subject to the
provisions of that Statute, are being destroyed or have been destroyed in contravention of
the above federal code section and/or others.
And it is further found by this Court that a danger that destruction of the
materials which would be invaluable in the crafting of preventative measures in upcoming
elections in the future shall be destroyed either before or after the federal cutoff date of
September 3, 2022.
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SO ORDERED:
_______________________________ July ___ 2022.
Judge, United States District Court for the District of Maryland
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UNITED STATES DISTRICT COURT FOR

THE DISTRICT OF MARYLAND
____________________________________________
)
) Case _____________
V. )
)
A RICO Enterprise and )
the State of Maryland, et al )
____________________________________________ )
MEMORANDUM OF POINTS AND AUTHORITIES IN SUPPORT OF

EMERGENCY TEMPORARY RESTRAINING ORDER (TRO) AND
PRELIMINARY INJUNCTION
Initially, in the Complaint in this case, and in the associated Motion for a
TRO, plaintiffs allege various violations of election laws which may have criminal as
well as civil violations applicable to presently unknown defendants. Many of these are
County and City employees who may or may not be aware of the serious nature of the
allegations which also may or may not apply to them. For this reason, plaintiffs suggest
an expanded Notice of the ramifications of this filing and the Court’s Order be widely
distributed. The following Notice is respectfully suggested.
NOTICE TO DEFENDANTS AND OTHERS:
(1) Defendants and Others, whom may be complicit or may become
complicit during the pendency of this Temporary Restraining Order (TRO) are hereby
notified of the protection of all election materials, broadly construed by 52 U.S.C.
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§20,701.
Each County employee, contractor or other person are hereby notified, that
Preventing Destruction of Election Materials and Financial Records for 22 Months, is
already prohibited by Federal Law, to September 3, 2022; Defendants and Others are
hereby Notified and Ordered to preserve all such materials of an additional 14 days
beyond September 3, 2022, or as further extended in this case by this TRO.
LIKELIHOOD OF PREVAILING IN COMPLAINT
Plaintiff’s Exhibits Number 2.1, 2.2, and 2.3, 3, 4, and 5 accompanying the
Complaint in this case are incorporated by reference to this memorandum of points and
authorities.
To conform to the requirements of F.R.Civ.P. Rule 65 the following
comments apply to the injunctive relief requested in this case in the pending motions.
For more than 10 years, Lewis T. Porter, has been obtaining various types
of evidence including that listed herein. In addition, several eyewitnesses have produced
evidence which leads to the production of great volumes of evidence of the unlawful
actions complained herein. Some of that evidence is known and some is unknown at this
point. But the known relevant evidence is substantial enough to indicate that there is little
doubt of the existence of unlawful actions by the defendants. That evidence has been
particularized in the exhibits hereto as listed below:
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Exhibit #1 - List of 21 counties requesting and receiving Grant Contracts
(for the distribution of $6,245,797 million) from a Chicago organization purporting to be
for non political lawful purposes with a contract, on information and belief with each
county subject to identical or similar restrictions. Even without using the subpoena
process to date, substantial systemic deficiencies appear.
In addition, lists each County receiving election aid grants from CTCL and
the amount of that County’s Grant were obtained from public sources. By a separate
document, the contract with each county details what the purported story is for that Grant
for that County. However, comparison to actual expenditures in three counties examined
discloses that the purported expenditures do not track with the qualifying reasons
required. Plaintiffs shall prove by a selected sample that the pattern of unlawful acts is
uniform or at least similar for all grants received by Maryland counties, or alternatively
that some counties violated the law and some did not. Known violations, however have
already been discovered.
Exhibits #2.1, 2.2, and 2.3, are declarations and affidavit of eye witnesses to
the ballot stuffing process which occurred in Frederick County, Maryland. It is expected
that similar events occurred in each of the other counties using the ballot drop box
process. It is also expected that a substantial number of employees of Howard County,
Frederick County and Carroll County will be identified as couriers, i.e., “the Mules”.
By the time set for the preliminary injunction hearing it is expected that a
substantial number of witnesses, both adverse and friendly with documentation will be
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developed on this point, thereby essentially proving this one critical element of Plaintiffs
Case. It is also expected that the RICO allegation in this Case, and the Voter Fraud
allegation in this Case will be demonstrated by clear and convincing evidence. This
process will lay the ground work for correction for the entire vote system process, at least,
for the State of Maryland and in other jurisdictions.
Exhibit #3 - Declaration of Mr. Kurtis S. Kolb, (Exhibit # 3) is a recent
development of apparent harvesting of voters records where a departing voter had moved
to Florida from Carroll County, Maryland. His voter’s record was undeleted by a forgery
utilizing the ERIC system resulting in an extra voter’s record, available in the next
election. The voter disclosed the forgery to the authorities in Carroll County and it is
presently being investigated as an identity theft.
The ERIC system, on information and belief, is a system that has been
corrupted throughout the entire country. The ERIC system allows nefarious persons
having control via conspiratorial conduct with co-conspirators in other states to obtain
information regarding departing voters. That information including arriving and
departing voters in collaborating corrupted states allows fraudulent fabrication of genuine
voter information used to create false ballots on no longer resident voters. By this
automated process, hundreds of thousands of opportunities to create a database of false
votes has become available. This information from this one voter in Carroll County is to
the effect that this system, ERIC, of automated fraudulent conduct, is in active use in both
Maryland and Florida.
Investigation via Rule 30 (b)(6) is also requested as applicable to this
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matter.
Exhibit #4 and #5 - Frederick, Carroll, and Howard Counties were selected
for examination as to Election financing and voting controls applicable therein. The two
contract forms from Center for Tech and Civil Life (CTCL) for acceptance of a grant,
with conditions, appear to be identical in format, i.e., “boilerplate forms” indicating
widespread use. And each contain innocuous statements as to the use of the grant funds
for specific purposes designed to track the restraints of the voter laws and the IRS Code
for 501 ( c) (3) organizations, which is actual are unmonitored and false. In other words
intentional torqueing of this Country’s tax and voting laws. This is plaintiff’s allegation
based upon a consistent but growing information, and evidentiary database.
Howard County furnished information regarding financial matters, but
refused to produce the forms listed above which on information and belief would apply to
it. Those Howard County forms will be requested by subpoena and deposition if
approved by the Court prior to the hearing on the Preliminary Injunction.
This apparent and alleged, RICO Enterprise, CTCL furnished all of the
grant funds received by Maryland Counties for a total of $6,245,797 Exhibit #1.
It appears from documents received (Exhibit “#4), contracts substantially
identical in format and content, limit the use of funds to specific mandatory uses which
must be reported back to the grantor, or refunded back to the Grantor. No example of a
“Grant Refund” has been disclosed.
First, Howard County did not furnish the requested Contract known to exist
with CTCL as apparently was the standard procedure. A Rule 30(b)(6) deposition for
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knowledgeable persons to explain these inconsistencies, and the recipients of the
$688,226.00 of funds by this County shall be a good start toward unraveling what actually
occurred. (To this end, see Exhibits 4 and 5).
IMMEDIATE AND IRREPARABLE HARM
Ballot distribution in Maryland as the beginning of the election process for
the upcoming cycle has already begun in the Primaries. The ballots are being distributed
and the Maryland legislature has recently approved the expansion, over republican
opposition, of the ballot drop box locations.
On information and belief, all of these locations are without any substantial
numeric control or chain of custody, video surveillance, or quality control at all.
Therefore, to the extent any of the revaluations occurring in this lawsuit as to the
“presence of fraud” in the election process will unquestionably create immediate and
irreparable harm to the election process, the credibility of the State of Maryland, and trust
of all voters within Maryland and elsewhere.
Accordingly, the Temporary Restraining Order followed by the Preliminary
Injunction after an interval allowed for the additional expected detailed evidence to the
scope and magnitude of such similar event in Maryland are completed should be granted.
EVOLVING NATIONAL INFORMATION
Evolving National information in three separate sets of disclosures, one
regarding payments of couriers, a documentary entitled “2000 Mules”, regarding evidence
of transporting fake ballots and a second; manipulation of machine totals by foreign
sources by Dinesh D’Souza; and a third involving recent audit reports in Maricopa
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County, Arizona, involving disclosure of the methodologies for ballot fabrication and
harvesting all linked to the information disclosures to date in Plaintiff’s Exhibits #1-5.
It is expected that by the time of the subpoena and deposition process is completed
and presented in the hearing on the preliminary injunction incontrovertible evidence will
support all of plaintiff’s allegations of material unlawful actions corrupting the Maryland
voting process and election results.
This process and analysis is an absolute necessity for elimination of corruption in
the Maryland Voting Process and driving election results in all future elections.
DRAFT-EMERGENCY TEMPORARY RESTRAINING ORDER
The Court has considered the verified complaint, and verified allegations
contained in accompanying verifications and declaration, with verified evidentiary
attachments. Among other things that are applicable to 20 Maryland Counties and
Baltimore City, are that requests for public information made in the normal course of
routine verifications by plaintiff's herein have disclosed alleged fraudulent activities in the
financing and false reporting of payments are not of purported politically neutral election
donations and expenses.
Inquiries were made utilizing both informal requests for information and
P. I. A. requests pursuant to Maryland State Voter laws.
Two eyewitness verified reports allege ballot stuffing into two of the Eight
unsecure Frederick County Drop-Boxes. In addition, all of the Frederick County Drop
Boxes are without functional video or monitored surveillance cameras. In effect there for
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the entire Frederick County is no “effective chain of custody.” About 760 persons in
another County, Howard, received suspicious paychecks, or other cash disbursements
(Exhibit 5) to them, alleged to be for, at least in part, for unlawful purposes. The great
majority of payments received were in round dollar amounts apparently piece work
payments.
Coupled with this observation is the purported, but as yet unverified alleged
payments of round amounts of $ 5.00 per Ballot deposited into drop- boxes in the past
two elections in Maryland, drop-box payments for stuffing. The purported purpose of
the request for immediate subpoena issuance and depositions is to verify in detail these
striking allegations before, the time for hearing of the requested Preliminary Injunction.
and associated depositions.
Purportedly the “mules”, a term coined in the past Presidential Election,
received some part of the funds financed by this methodology. Plaintiffs seek to issue
subpoenas via 30(b)(6) and conduct immediate depositions, using the data-base of the
about 760 persons working in one County, Howard, which adjoins Frederick County.
Also, under this theory, such facts are supported by verified events. In
adjoining Frederick County, one stuffing event was witnessed by a person trained as an
election judge. Therefore, is a reasonable probability exists that the perpetrators of the
observed “Stuffing” came from persons based in the adjoining County, Howard.
Plaintiffs propose to depose a reasonable sample of the about 760 admitted payees of the
“cash paid” election workers as to the work they performed.
Further supplemental evidence is submitted as follows: At a subsequent
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public hearing, the Election Board admitted that surveillance cameras associated with the
8 the drop- boxes in the Frederick were not owned or controlled by the County, and never
examined. Accordingly, it is admitted that no security over the “live” ballots existed.
Under these circumstances, verified as to have occurred, the Court is
inclined to recognize that a valid and important emergency situation exists.
THE ALLEGATIONS ARE SUPPORTED

BY A VERIFIED COMPLAINT AND DECLARATIONS:
Verified and documented voters information for County and Baltimore
financial records, including both financial information regarding Grants, the lack of a
chain of custody by election authorities of ballots, envelopes, and no drop box
surveillance controls existed. And said unlawful activities have allegedly been
continually discovered and thereafter brought to the attention of election authorities in
various jurisdictions for nearly the past 10 years. But nothing of consequence was ever
done by any County to correct the clearly inadequate chain of custody, which is
essentially non-existent regarding election ballots, envelopes and payments to persons
who appear to be paid persons, paid with donations by outside sources, in the case of
Maryland in 20 Counties and Baltimore City, for a total of 21 out of a total of 24
jurisdictions.
The time frame of this alleged RICO Enterprise includes the past
presidential election cycle, the 2020 election, and the 2016 cycle as well. Said practices
are continuing and increasing as evidenced by the recent escalation of the use of drop-
boxes. Drop-Boxes are admitted by the election boards, openly, to have virtually no
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effective control over the chain of custody or monitored surveillance cameras in the three
Counties for which detailed questioned were posed to election board management.
Among the defendants, those for which a Temporary Restraining Order
(TRO) is sought, are 21 separate organizations, all voting jurisdictions in Maryland who
have accepted outside grants from one Chicago Organization. Plaintiffs are seeking at
this time to both warn the defendants of impending enforcement of existing Federal Laws
for which violations apparently already have occurred, and also immediate access to
evidence via subpoenas of selected documents indicative of election fraud to use that
information to prevent re-occurrence of this unlawful practices.
Plaintiffs seek permission for extending of the non-destruction period and
an evidentiary hearing several weeks hence to obtain additional first hand evidence to be
presented at the hearing on a Preliminary Injunction. The additional evidence obtained
during the interim between the Temporary Restraining Order to prevent further evidence
destruction and the several week hence hearing on the Preliminary Injunction shall be
used to finalize and further detail the evidence. Indeed, Plaintiffs suggest that evidence
does now demonstrate, election fraud, massive in quantity and obvious in clarity.
Plaintiffs aver, based upon long and detailed evidence over a decade of
observation, and hundreds of transactions, with names of recipients, shall demonstrate
ballot harvesting on a large scale.
Defendants are alleged to be clearly violating election laws. Violations
have been identified in prior elections, authorities have been notified, questions have been
asked and remain unanswered it is alleged that massive fraud and miscounting has been
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ignored or denied. It is further alleged that changes in the number of Drop Boxes, with
virtually no surveillance, chain of custody or count control is to be greatly expanded by
the new scheme for Maryland. Defendants have allegedly obfuscated, destroyed, and
delayed production of evidence of violations, as a consistent practice over the past 10
years, but never corrected. If these allegations are even half-true, massive damage, with
irrevocable harm has happened in Maryland and shall be expected to create large scale
constitutional violations of both Maryland and Federal election, and RICO Enterprise
law.
Plaintiffs argue, that because of the seriousness of the alleged violations,
and also the penalties, the allegations of the likelihood of destruction or obstruction of the
furnishing of documents is not just great, but virtually inevitable absent Court
intervention, which includes a requested notice of the impending legal action. These
matters are unquestionably both subject to the jurisdiction of this Court and clear
violations of Constitutional rights of not just each plaintiff, but each voter where such
type of similar violations took place.
Plaintiffs allege that recent public disclosures describe and identify forensic
procedures which provide for the first time, the practical mechanism to verify misconduct
and identify corrective measures as well as punish the wrongdoers. The future corrective
measures, once the violations are known become for the first time possible. For this
reason, identification of both violations and violators of 52 U. S. C. § 20,701 can be
located from existing election records.
But if those records are destroyed, no such repair of inadequate systems are
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possible. The next cycle of elections is about to begin, and the expiration date for the
2020 materials preservation is about to expire, on or about September 3, 2022. Thereby,
the timing of this lawsuit, and the need for preservation has now become an emergency
matter.
Unless protected from the unlawful practices outlined herein with
specificity, it is virtually inevitable that irreparable harm and loss of essential evidence
will occur resulting in violations of Federal Statutes. More importantly, any hope for
restoring any semblance of a correct and verified vote is gone.
Further, a specific order is deemed necessary to every Marylander or out of
state entity who is, a named defendant in this Civil Action, or is contemplating in the
future a participation in such nefarious activities as described in the filed Complaint in
this case.
Wherefore, immediate and irreparable harm is reasonably expected. It is
alleged with specificity that Grants to all of the 21 Jurisdictions now being sued, were
received and limited to use for nonpolitical purposes. But that in fact, some of that grant
money was used for political and likely, unlawful purposes.
It is alleged that a list of about 760 different persons in one County alone,
actually received Grant funds, admitted to be such and furnished to this Court as evidence
herein. But that evidence needs to be further fleshed out to separate the law violators
from the, perhaps innocent, and non-political county election workers. Bribes appear to
have occurred, dependant entirely upon the nature of the work performed by each
separate individual of about 760 different persons. The evidence as to the nature of their
work, either lawful or unlawful, dependent upon that question, is to be determined with
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specificity prior to the evidentiary hearing for the Preliminary Injunction.
Protection of Innocent Election Workers
However, the Court finds that the 760 named person may, and likely does
include innocent persons as well as perpetrators of the frauds alleged, and violators of
existing Federal Code. Accordingly, the names appearing on Exhibit 5, shall be accepted
by the Court, provisionally, and redacted in all notices and service of process, pending the
results of the F. R. Civ P. Rule 30(b)(6) depositions completion. The Court shall likely
reconsider the publication(s) of defendant’s names after the more complete evidentiary
facts are known.
Accordingly, Exhibit 5 shall be filed under seal, subject to disclosure to
Counsel, marked under seal, with admonitions that all names initially shall be kept
confidential. Further, the Court Orders, that, upon completion of the initial Rule 30(b)(6)
deposition, a report be rendered to serve the Court as guidance as to the extent of
necessary depositions, and the assessment of costs to finance said depositions and
document production.
This Court is Requested to Grant this Motion, By separate Orders:
(1) This Temporary Restraining Order should be Granted.
(2) Permission to take the first five 30(b)(6) depositions with unlimited subpoenas
duces tecim as appropriate, is granted. The purposes of the questioning and documents
acquired are to be limited by the judgment of the Plaintiff’s counsel to carefully consider
the relevance of the information sought to inquiries likely to disclose unlawful acts, and
refrain from unwarranted political fishing expeditions; or those designed to identify
corrections to obviously deficient, and/or to identify the same alleged practices with
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means to facilitate correction of those practices that are expected to be utilized in
upcoming elections in the future.
So Ordered:
Also, the Court should find that a Federal law document protection
provision, (52 U.S.C. § 20,701) prohibits destruction of election materials for 22 months,
expiring on or about September 3, 2022. And it is further alleged that there is likely and
eminent danger that material evidence subject to the provisions of that Statute, are being
destroyed or have been destroyed in contravention of the above federal code section
and/or others.
And it is further found by this Court that there is an eminent danger that
materials which would be invaluable in the crafting of fraud preventative measures in
upcoming elections shall be destroyed either before or after the federal cutoff date of
September 3, 2022.
DRAFT TEMPORARY RESTRAINING ORDER
Beginning today July 4, 2022 all persons, whether employed by any one of
the 21 counties and Baltimore City who are defendant herein, and therefore being
personally subjected to litigation on this point, or private persons having access to
protected materials, shall refrain from any act that obscures, hides, or destroys, or delays
production of protected election materials, whether before the cutoff date under current
federal law or thereafter so long as this temporary restraining order, as extended by Order
of Court, remains in force, subject to further Order of Court.
The Court has weighed the inconvenience or expense resulting from
enforcing the requested restraining order against the benefits and breaches of applicable
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law preventing such destruction, and finds that the potential of harm, and dangers of
irreparable harm and damages resulting from preserving the status quo of these materials
is negligible while the benefits resulting from a full disclosure of all applicable facts
completely outweighs the possibilities of damages to the custodians of such evidence at
this time.
Accordingly, the Court should grant the request for a Temporary
Restraining Order and Preliminary Injunction Hearing. A Draft Order for the TRO is
attached pursuant to the Rule 65 (b).
1. A Temporary Restraining Order shall be granted pursuant to Federal Rule of Civil
Procedure, 65(b); subject an evidentiary hearing at a Preliminary Injunction hearing
pursuant to Federal Rule of Civil Procedure 65 (a), which shall be scheduled for the
________ day of July 2022, or as rescheduled by the Court;
2. Permission is hereby granted to Plaintiffs, to conduct discovery limited to subpoenas
for documents and things, and no more than 10 depositions with document subpoenas
pursuant to Federal Rule of Civil Procedure 30(b)(6) or as expanded further by this Court.
3. The Court finds that no bond is necessary in this matter as there is little likelihood of
substantial damage or harm, but rather likely to be, absent unlawful violations of this
Order, a mere continuation of the status quo.
4. Forthwith service of process and notification of this order by email or first class mail,
shall be accomplished by Plaintiffs. And the Complaint and associated Temporary
Restraining Order, and Notice and related materials, constituting this action shall occur
either by electronic notice and/or mail notification, to registered agents for corporations,
absent any objection to service of process by this means by any one of these government
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entities or private parties. If objection occurs, the provisions of the Service of Process
Rules for that defendant shall be followed by plaintiffs.
5. In the event of any objection of this means of Service of Process, and for other
Defendants in this case, for example the Grantor, the regular Service of Orocess shall be
followed, except that, the grantor shall be notified by email service along with the
notification of the 20 counties and Baltimore city.
CERTIFICATION PURSUANT TO Rule 65 (b)(B)
Plaintiffs Attorney Certifies that no efforts were made to give Notice since
cooperation on such matters has been attempted for years by Plaintiff’s and the
information requests have uniformly been rejected. Further, no Notice should be required
because (1) the Federal Code already requires adherence, and (2) supervisory personnel
who are not part of the fraudulent process should be provided a fair warning to not
become involved in unlawful acts currently in process, before any specific warning is
given to the actual perpetrators who may now be in the process of acts that violate the
protection code, that protection efforts are being implemented by this motion.
RESPECTFULLY SUBMITTED:
Walter T. Charlton, Electronic Signature, July 4, 2022

DC Bar # 186940,
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IN THE UNITED STATES DISTRICT COURT.

LOIS ANN GIBSON, et al., *

Plaintiffs, *
v. CIVIL NO. GLR-22-1642
*
FREDERICK COUNTY, MARYLAND, et *

al.,
Defendants. *
* * * * * * * ·* * * * *
ORDER
Presently pending before the Court is Plaintiffs' Motion for a Temporary Restraining Order
("TRO"). (ECF No. 2.) That Motion seeks to require Defendants to preserve certain statutorily
protected materials for an additional fourteen days and to permit Plaintiffs to engage in expedited
document and testimonial discovery. (Id at 1, 5.) For the following reasons, Plaintiffs' Motion
(ECF No. 2) is DENIED.
I. Temporary Restraining Order
Under Federal Rule of Civil Procedure 65(b), a Court may issue an ex parte TRO "only if
[ ] specific facts in an affidavit or a verified complaint clearly show that immediate and irreparable
injury, lpss, or damage will result t~ the movant before the adverse party can be heard in
opposition." Here, Plaintiffs Motion avers· exactly the opposite, namely that they will suffer no
harm for nearly two months~ven absent a TRO. Specifically, Plaintiffs seek a TRO prohibiting
the destruction of election materials covered by 52 U.S.C. § 20701. (ECF No. 2 at 1.) However,
as Plaintiffs acknowledge, § 20701 already requires retention of these documents "for a period of
twenty-two months from the date of [various federal elections]" which Plaintiffs assert requires
JA112
retention of the documents they seek until at least September 3, 2022. (ECF No. 2-1 at 1.)1 Indeed,
Plaintiffs appear to concede that their goal in ~eeking a TRO is not to immediately avert harm, but
to add an additional fourteen days to the§ 20701 period. (Id.)
To the extent that Plaintiffs allege immediate harm, it is limited to the bald assertion "on
information and belief' that Defendants are presently destroying the relevant materials in violation
of§ 20701. (ECFNo. 1 ~ 19.) This unadorned accusation plainly fails the Rule 65(b) requirement
of proof by "specific facts." See in re Kunst/er, 914 F.2d 505, 515 (4th Cir. 1990) (emphases in
original) ("[Rule 65(b)] requires that "specific facts" be "shown" to the court with the request for
relief. We agree with the district court that the appellants' request for relief and their indication
that they were not 'in a position to make the showing required by Rule 65(b)' without later
discovery indicates an unacceptable level of pre-filing investigation."). In addition to being
evidentiarily unsupported, Plaintiffs' accusations of spoliation are particularly implausible given
that any person who "willfully steals, destroys, conceals, mutilates, or alters any record or paper
required by section 20701 of this title to be retained and preserved" already faces significant
criminal penalties. See 52 U.S.C. § 20702. In short, Plaintiffs have failed to meet threshold
requirements for the entry of an ex parte TRO. While the Court takes no position at this time on
Plaintiffs' potential entitlement to other forms of preliminary relief, such relief must be sought
after notice to Defendants.
II. Expedited Discovery
In addition to a TRO, Plaintiffs Motion also requests that the Court grant them extensive
authority to immediately begin conducting discovery. (See ECF No. 2-2 at 13 (requesting
1 Moreover, once Defendants have notice ofthis lawsuit, retention of these documents would also appear to be required
by every litigant's "duty to preserve material evidence." Silvestri v. Gen. Motors Corp., 271 F.3d 583, 591 (4th Cir.
2001).
2·
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"[p]ennission to take [] five 30(b)(6) depositions with unlimited subpoenas duces tecim [sic] as
appropriate").) Despite the breadth of this request, it appears that the purpose of this discovery is
only to gather additional evidence needed to substantiate claims for further preliminary relief at a
preliminary injunction hearing. (Id at 7 ("It is expected that by the time of [sic] the subpoena and
deposition process is completed and presented in the hearing on the preliminary injunction ....").)
Given that the Court has denied Plaintiffs' request for a TRO, and therefore has not set a
preliminary injunction hearing, it would appear that Plaintiffs' request for expedited discovery is
moot. See Fed. R. Civ. P. 65(b)(3) ("If the [TRO] is issued without notice, the motion for
preliminary injunction must be set for hearing at the earliest possible time[.]").
To the extent this aspect of Plaintiffs' Motion is not moot, it is not properly before the
Court. As the Fourth Circuit has explained, "[e]x parte proceedings are the exception, not the rule,
and the Civil Rules do not denominate discovery motions as 'ones which may be heard ex parte."'
In re Pruett, 133 F.3d 275, 279 n.8 (4th Cir. 1997). Indeed, those Rules explicitly require notice
to the opposing party before utilizing the discovery options Plaintiffs request. See Fed. R. Civ. P.
30(b)(l) ("A party who wants to depose a person by oral questions must give reasonable written
notice to every other party."); Fed. R. Civ. P. 45(a)(4) ("If the subpoena commands the production
of documents, electronically stored information, or tangible things or the inspection of premises
before trial, then before it is served on the person to whom it is directed, a notice and a copy of the
subpoena must be served on each party."). Accordingly, to the extent that Plaintiffs continue to
seek expedited discovery, the Court cannot and will not entertain such requests without first
hearing from Defendants.
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Ill. Conclusion
. In sum, Plaintiffs' unilateral attempts to obtain extraordinary relief from this Court are
procedurally improper because they either (1) fail to establish threshold requirements for such
relief or (2) seek relief that cannot be granted ex parte. While the Court takes no position on the
ultimate merits of Plaintiffs' requests, those merits can only be resolved after the adversarial testing
typically required by our judicial system. For these reasons, Plaintiffs' Motion for a TRO (ECF
No. 2) is DENIED.
DATED this -1z._ day of July, 2022.
COURT: "1,{ . r::3~
JA115
In the
UNITED STATES DISTRICT COURT

Plaintiffs, *
*
v. * CIVIL NO. GLR-22-1642
*
FREDERICK COUNTY, MARYLAND, et al., *
Defendants. *
* * * * * * * * * * * * * * * * * * * * * * *
Plaintiffs’ Rule 59 (e) Motion to Alter and Amend the Denial of a TRO
or Alternatively, For an Expedited Hearing or Trial On a Preliminary Injunction
To Avoid Immediate, Vital and Irreparable Harm from Per Se Election Fraud
I. Introduction
The Honorable Court, Chief Judge, James K. Bredar, in a well reasoned and
unquestionably correct decision based upon information and evidence available at that
time, July 6th, 2022, denied Plaintiffs Motion for extraordinary relief, a TRO for
additional protection for election materials. Federal law already protects such materials
for 22 months.
That ruling was based upon two grounds as summarized following:
1. Notification to adverse parties and/or Service of Process to the defendants was
incomplete at that time.
2. Federal protective law prevented destruction of evidence until about September
3, 2022 and that date was not yet past. Therefore there was no need for further protection
or irreparable harm.
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II. Extraordinary Events of the Past Few Days, Ongoing Vote-Trafficking,

Creation of Fake Data-Bases-Suborning, Fabrication and Fraud
In Maryland and in, At Least 43 Other States:
However, on July 19, 2022 in Timonium, Maryland an expert Information
Technology scientist, Dr. Douglas G Frank, presented his findings regarding the
Maryland election system. Also, Dr Frank explained how Maryland’s system compared
to the other 43 states he has examined to date regarding voting system integrity. His
presentation was the 43rd such examination and report, with a presentation regarding the
accuracy and integrity of elections in the United States of America covering the years
since about 2000.
Dr. Frank’s conclusions were both amazing and concerning. He reported
that Maryland’s voting system and results were the most skillful and effective of all of the
fraudulent systems examined. The methodology was so similar that the results could be
predicted without any voting at all, and were all similar across the country.
He presented evidence obtained directly from the voting records of the
Maryland State Board of elections. That evidence was corroborated by anecdotal
evidence obtained in this case by plaintiffs. In combination, it is expected that his expert
opinion will fully support allegations of outside influence and massive fraud in Maryland
going back at least to the 2012 elections. That data was analyzed in a overall fashion and
cross correlates to individual anecdotal evidence matters obtained by the plaintiffs in this
case, and hundreds of citizens who had only their own observations supporting their
individual testimonies. Accordingly, there should be no effective challenge to the
authenticity of his data.
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III. A Summary of Dr. Frank’s Expected Testimony
On July 19, 2022 in Timonium, Maryland an expert information technology
scientist, Dr. Douglas G, Frank presented his findings regarding the election system and
voting process in the state of Maryland. His presentation was the 43rd such presentation
regarding elections in the United States of America.
He presented evidence obtained directly from the voting records of the
Maryland State Board of elections so there can be no effective challenge to the
authenticity of his data. That data was analyzed in a overall fashion and cross correlates to
individual anecdotal evidence matters obtained by the plaintiffs in this case, and hundreds
of citizens who had only their own observations supporting their individual testimonies.
Dr. Frank's testimony as an expert witness has been requested in this case
and he has agreed to appear as necessary and appropriate before this Court. His testimony
in sum crosses the boundary from striking to astounding. Based upon the evidence made
available to him for 43 states he determined that virtually all of the States have been
victims of corruption of the most basic records, the voter’s individual records themselves.
The basic scheme began in about the year 2000. Each jurisdiction would
build up a record, stored electronically in each election board’s electronic storage
records, of a secret data base of invalid records, which appeared to be on their face
genuine voter records. Thus, a “piggy bank” of available deceased persons records,
containing many thousands of records became a mobile fraudulent file of voters records.
These false records were moved from secret storage to Maryland election voters records
with impunity by the persons, or other managers who had access to these secret files.
This also was done in coordination with Motor Vehicles Records, and voter’s records to
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build the fraudulently available list of fake voters. Then, by electronic monitoring during
any election send the “needed to win” votes where needed. The fraudulent system also
provided for removal of the fake votes from the voting list immediately following the
vote count so that any audit thereafter would not be able to detect the (previously
removed) fake votes.
The overall mechanism for accomplishing the voting fraud corroborates the
observations made by the plaintiffs in this case, on a detail level. Dr. Frank's conclusion
is that the elections in Maryland have been subjected to vote trafficking, manipulation and
fraud to an extent that is the most skillful and all pervading of all of the 43 states for
which data has been made available to him.
To summarize Dr. Frank's expected specific Maryland findings, within the
context of other anecdotal evidence obtained by plaintiff's herein, shall be as support for
the purpose of preservation of evidence which, although protected by federal law against
destruction, is nevertheless vulnerable because of the extreme prejudice which is expected
to flow from open production of said evidence, the following details are relevant, and
perhaps crucial to a fair outcome in this case.
Exhibits 6 and 7 were obtained by plaintiff's directly from the posted web
page records of the Board of Elections for the State of Maryland. Those exhibits are a
listing by counties of total of "mail in ballot requests by County, as of July 17, 2022",
(Exhibit # 6); and "mail in ballot requests by County election 2020 presidential general
election as of November 3, 2020". These exhibits are significant in that they demonstrate
the existence of data base systems keeping track of election events and the magnitude of
the record count in each of the elections for the presidential election of November 3,
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2020. Exhibit 7 contains the total number of mail in-ballot requests of the Maryland
Election Board, and deliveries to requestors of 1,688,480. In the most recent primary
election as of July 17, 2022 the total number of mail in ballot requests and deliveries was
508,024.
A further observation from these two exhibits standing alone is that the
numbers are large, and therefore capable of being used to influence elections to the extent
any illicit unlawful vote trafficking occurs with in those data files.
Dr. Frank's data report demonstrates and tracks how a large database of
fabricated illicit votes has been used in Maryland since about 2000. The manipulation
created fake votes via fake ballots, and used those fake votes to prevail and obtain
contrived results. The immediate and irreparable harm is that this fraud is still in effect
and expanding, for example by addition of additional elements like ERIC system,
Coordinating voters leaving their vote record behind for fradulent use when they leave
Maryland.
Other anomalies have been disclosed by “canvassing” by election fraud
volunteer workers. Exhibit 8 is a list of about 250 discrepancies in Harford County.
Exhibit 9 is another malfunction in integrity for Harford County, involving the purported
“surveillance cameras” which failed to function to pick-up ballot stuffers because of
cameras incapable of storing images for 22 months.
IV. CONCLUSION
The magnitude and ongoing nature of the Election Fraud System in
Maryland presents this Court with a simple decision. Is the alleged massive scheme a
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matter that requires immediate correction, or not, IF THE ALLEGATIONS ARE
TRUE?
The answer is simple. If true the essence of each resident’s constitutional
rights have not only been violated, but there is a substantial peril that our entire
government is in the process of being taken over by forces we cannot control. This
election is vital, as are all of them, and every small local election is critical as well. This
must be given full and good faith hearing as a matter of utmost Constitutional importance.
This is even more so with respect to Maryland because of the special and unique clause in
the Maryland Constitution establishing the Office of the Maryland State Prosecutor, with
specific Constitutional jurisdiction to investigate vote fraud matters.
But this function of our government has simply failed. Of that, there can be
no question. The result of this analysis is that the Motion for immediate injunctive relief
must be granted. The risks are too large to be ignored. And next the Court should hold
an expedited hearing on the merits of the allegations of the existence and corrections for
the alleged fraud. Any other solution invites, and welcomes disaster of incalculable
magnitude.
V. MEMORANDUM IN SUPPORT OF RULE 59(e)

MOTION TO ALTER AND AMEND THE DENIAL OF A TRO
The Court ruled in its July 6th, denial of Plaintiffs’ alleged class complaint
for injunctive relief contained in the original complaint for a TRO on July 4th, 2022:
“In sum, Plaintiffs' unilateral attempts to obtain extraordinary relief

from this Court are procedurally improper because they either (1) fail to
establish threshold requirements for such relief or (2) seek relief that cannot
be granted ex parte. While the Court takes no position on the ultimate
merits of Plaintiffs' requests, those merits can only be resolved after the
adversarial testing typically required by our judicial system. For these
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reasons, Plaintiffs' Motion for a TRO (ECF No. 2) is DENIED”

(Decision, Case 1;22-cv-01642-GLR Document 4, Page 4 of 4, Signed By
the Court: of July 6, James K. Bredar, :Chief Judge).
Two major changes in facts and circumstances as alleged herein have occurred:
First, all defendants who exist in personal or corporate form have been
notified as of this date, August 2, 2022. And formal service of process is proceeding, but
because of the number of and diversity of the defendants, likely two weeks more will be
required to complete formal service of process. But the defendants have been notified.
Second, new and material evidence of massive systemic fraud has been
uncovered, with data supporting that allegation derived both from the defendant’s own
systems and independently anecdotally corroborated. The evidence supports an allegation
of a conspiracy to subvert the voting process for the entire country, with particular and
clear effects in Maryland.
VI. MANDATORY NATURE OF THE RELIEF REQUIRED:
Plaintiffs hereby submit that this request to alter and amend that Order
should be granted and expedited discovery ordered with a Preliminary Injunction hearing
scheduled accordingly, in about 35 days. The new evidence should be reconsidered,
along with the Expert Opinion, in an adversary hearing on a forthwith basis. Evidence
must be requested, with relief crafted after the Court has heard the required evidence to
its satisfaction. Once the evidence is established as incontrovertibly genuine, amended
relief to result in the interim elections and forthwith relief must follow to prevent the
ultimate collapse of the entire structure of our voting process.
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VII. Memorandum of Points and Authorities in Support of

Rule 59(e) Motion to Alter and Amend Denial of a TRO,
without consideration of or Ruling Upon the Alternate Relief Requested,
Preliminary Injunctive Relief:
1. The procedural flaw as relied upon by the Court in its Order of July 6th, 2022 has now
been Cured. Actual notice substantially occurred on July 27-28, 2022 by email notice to
about 30 named parties, and formal Service of Process using the Waiver Process is
continuing for each of the 21 Voting Jurisdiction sued, and multiple alleged
conspiratorial RICO defendant entities.
2. As to the threshold evidentiary requirements, substantial, material, even mind-
boggling new evidence has been acquired since the filing on July 4th 2022 in this case.
An Amended Complaint is being filed pursuant to Rule of Civil Procedure 15, shortly
following this Motion. That new evidence is both: (a) anecdotal, verified by affidavits or
in documentary form acquired from the files of the Defendant Election Board(s)
demonstrating massive and undeniable continuing immediate and irreparable harm in the
form of intentional falsification of voter data and procedures (Exhibits 3, 6 and 7), and
admissions of surveillance failures and hidden destruction of probative evidence has been
discovered as to the now ongoing election process.
Even more striking and astounding in implications for this lawsuit, is the
public information made available for the first time in Maryland on Thursday, July 21st,
2022. That newly available evidence goes far beyond the scope of protection of the
conventionally described “election documents” (ballots) and voting procedural evidence
under the existing protection of Federal Statutes applicable to the past presidential
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election. As correctly referenced in the Court’s Order of July 6th, federal protection of
those election materials does not expire until September 3, 2022.
But the “election and voter fraud” addressed in this lawsuit goes far beyond
those materials. What has been discovered and what is now believed to be the essence of
the voter fraud, and Maryland and Constitutional Violations which have actually been
occurring, since at least about 2010 is no less than an attempt to subvert our entire voting
process, and it has not only been attempted, but has succeeded. In a presentation on July
21, 2022, in Baltimore County Maryland, the following facts (on information and belief
supportable by affidavit) were revealed. These facts are incorporated into the allegations
of this Motion, and into the First Amended Complaint also filed contemporaneously with
this Motion for 59(e) to Alter and Amend an Order.
Dr. Douglas Frank, named herein as Plaintiffs’s expert witness has
personally received, to this point in time, citizen and voter data pertaining to 43 states. In
all of those 43 States overall pattern of data manipulation is consistent. That data
demonstrates an astounding uniformity in what appears to be, and shall be proven to be so
for Maryland, as well. That scheme and pattern, subject only to minor variations, is
described following. Dr. Frank has agreed to be one of several expert witnesses in this
case. In sum, these revelations of this nation-wide scheme finally explains and ties
together the various anomalies pervading the United States of America’s election process,
overall.
Dr. Frank’s ultimate opinion as to the State of Maryland, to the public
group, of about 150 persons, was words to the effect, after showing graphs based upon
official public records. (As paraphrased by undersigned counsel from his notes).
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Of all of the 43 states whose data I have examined, the State of Maryland
appears to have the most skillfully developed application of the harvesting
of false votes of all of those 43 sets of data.
The fraudulent schemes began about 1996, as gleaned from the data (again as paraphrased
from and proffered from counsel’s notes and recollections):
In essence the elements of the frauds, which explain virtually all verified anomolies
follow:
Second, the evidence of immediate and irreparable harm, both already done,
and continuing is just now recognizable and to what has occurred. For example,
undersigned Counsel only just became aware of the diabolical beauty of the underling
scheme, on July 19th, 2022. The disclosure of the mechanism(s) of the scheme was made
in a public event in Timonium, Maryland in a presentation by an expert in statistical and
election matters, Dr. Douglas G. Frank. Dr. Frank has graciously consented to become
one of several expert witnesses in this case. Dr. Frank’s opinion of the causes and effects
of the about 7 different types of frauds foisted upon the public in recent elections,
pervading in all states was described in detail.
Dr. Frank’s data, so far, has been gathered and subject to analysis by him
from official records in 43 states. The results are consistent, and compelling. Dr. Frank
has agreed to be available as needed by this Court’s hearings.
Plaintiffs herein, through counsel, recognized, for the first time in Maryland
from Dr. Frank’s presentation, and the hundreds of discrepancies and mishandling of
chain of custody, ballot stuffing, and lack of surveillance was the same for Maryland as in
the other 43 States. Also, the veracity of the data presented corresponds neatly with
nearly complete consistently to the observations and documentary evidence already
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available, but not completely understood as to the overall effect and metrology. What
was lacking, both here and in other cases around the Country, into a whole explanation of
incontrovertible individual anomalous election results. To wit, Dr. Frank has developed
an explanatory methodology enabling cause and effect for the entire election process in
all states. As a criminal matter, it is indeed a masterpiece of deception perpetuated acroos
the nation..
At the earliest possible time, plaintiffs seek a full evidentiary hearing, with
acceleration of subpoena and Federal Rule of civil procedure 30(b)(6) invocation by the
Court’s permission, to enable the Court to appreciate and cure the disaster that is in the
process of destruction of our democratic society. A layman’s (undersigned counsel’s)
description of the fraud(s), how they were organized, and what can be done to cure the
situation, once the destruction of documents and electronic files is physically prevented,
is included in the points and authorities outlined below.
This request is timely based upon Rule 59 (e) of the Federal Rules of Civil
procedure. That rule allows such amendment and reconsideration within 28 days of
denial, which occurred on July 6th, 2022. Plaintiffs’ respectfully, and in the name of God,
in whom we trust, pray that this Motion for immediate and/or preliminary injunctive
and/or permanent equitable relief be granted, with forthwith exercise of this Court’s full
power to preserve our union from the powers of evil. A Memorandum of Points and
Authorities follows.
MEMORANDUM OF POINTS AND AUTHORITIES IN

SUPPORT OF RULE 65 INJUNCTIVE RELIEF:
1. About 1996, a group of presently unknown individuals and corporations, foreign and
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domestic, set out to subvert the election process in the United States.
2. To that end they set out to control the “voters election Boards in each state. Over the
next few years, they did so using virtually unlimited funds furnished by the group,
3. Census data was used as a starting point. Also, voters registration data was used.
Also, over the years of building the scheme, other data bases were integrated into a
massive and virtually all encompassing source of citizen and voter information.
4. Files of such data were accumulated nation-wide and distributed on a secret basis to
participating individuals and corporate groups throughout the United States, and
elsewhere. Prominent in the relevant materials were death records, and persons moving
out of a particular voting jurisdiction (i.e. State) into another jurisdiction.
5. Prominent as a systemic identification matter was the creation of an individual “Voter
I.D. Code)”. This number appears on the voters’s receipt, recently used in the Maryland
primary election. That number appears directly under the name of each voter. It is
apparently an independent number, distinct from the Social Security #, or Driver’s
License #, for each Maryland registered voter.
6. Again, starting in about 1996 the foregoing and other databases were "fabricated" from
vulnerable voters records which could be utilized in one state or another in one election or
another as a source of a entirely bogus, counterfeit data set which by all observation and
auditing rules would be essentially invisible. That is using routine data processing
methodologies the entire massive database could be utilized to create a phantom database
from which false and undetectable ballots could be produced.
The only remaining step would be to send such data or bogus votes to the required
location, i.e., a state or voting position judged to be "in trouble" and cured using the false
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vote in the secret file or piggy bank of such data.
7. To complete the cover-up, the official electronic voter data containing the transferred
fake data would be stripped of the false data immediately following the certification of
data by the election boards, thereby purging the historical database of falsities, making the
fraud invulnerable to audit.
8. The beauty of the system is that unless it can be audited in real time with the voter
standing there any normal audit could not catch the inflation of the vote count for the
person supported by the cabal, and further no audit of electronic data could be
successfully performed once the data expungement became an accomplished fact.
9. The existence of this scheme is made strikingly apparent in the anomalous 10%
increase in voter volume, over time, in the online election results reporting. This scheme
also tracks with virtual 100% accuracy all corroborating efforts disclosed in the recent
exemplary efforts widely publicized as "2000 mules" and the independent efforts so
strikingly apparent in the Georgia and Arizona elections as performed by expert witness
and inventor Jovan Hutton Pulitzer and his associates.
CONCLUSION
Accordingly, a temporary restraining order (TR0) should be issued by this
court requiring all evidentiary materials including surveillance tapes all databases
containing citizen information, voter information, decedent's information, and any other
matter relevant to the existence or nonexistence or mobility of any voter alleged to be
eligible in any United States election should be preserved until such time as a grand jury,
a duly elected Congress of the United States, the executive branch of the United States
government and judicial branch of the United States government obtain a consensus that
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the election results and election rolls are free from this decades long corruption process
has been excised for all time.
Verification of Anecdotal Evidence Investigator
Lewis T. Porter
Lewis T Porter, America 20-20 Watch
Verification of counsel
I declare under the penalties of perjury that all attachments to this filing and the data
contained therein, are true and correct to the best of my present knowledge, information
and belief. And further that all statements contained herein are true and correct to the
best of my personal knowledge information and belief.
Walter T. Charlton
Walter T. Charlton, Esq.
CONCLUSION
Following an evidentiary hearing on the merits, a declaratory judgment
should be issued following proceedings incident to a hearing on a preliminary injunctive
relief. Expedited discovery should be ordered to accommodate the impending election
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cycle. However, the instant corruption of the election system in Maryland has created an
apparently unworkable situation. Emergency measures are clearly needed to resolve
scheduling problems incident to a currently unworkable election system. A scheduling
hearing in addition to the hearing on injunctive relief is requested.
Lewis T. Porter, Electronic Signature, Plaintiff/ Investigator,

Secretary Maryland 20-20 Watch
Lewis T. Porter, June 28, 2022, as Amended July 18, 2022, and July 25, 2022
Walter T. Charlton, Electronic Signature, June 28, 2022, And as Amended, July18,
2022, And July 25, 2022,.

DC Bar # 186940, United States District Court, District of Maryland, Bar # 07638
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DISTRICT OF MARYLAND
Chambers of 101 West Lombard Street
GEORGE L. RUSSELL, III Baltimore, Maryland 21201
United States District Judge 410-962-4055
August 5, 2022
MEMORANDUM TO COUNSEL RE: Louis Ann Gibson, et al. v. Frederick

County Maryland, et al.
Civil Action No. GLR-22-1642
Dear Counsel:
Pending before the Court is Plaintiffs’ Rule 59(e) Motion to Alter and Amend the Denial
of a TRO or Alternatively, For an Expedited Hearing or Trial On a Preliminary Injunction To
Avoid Immediate, Vital and Irreparable Harm from Per Se Election Fraud (“Motion to
Reconsider”) (ECF No. 6). 1 The Motion asks the Court to reconsider its Order of July 6, 2022 (the
“July 6 Order”) (ECF No. 4) denying Plaintiffs’ Motion for a Temporary Restraining Order (“TRO
Motion”) (ECF No. 2). For the reasons set forth below, the Motion to Reconsider will be denied.
The Federal Rules of Civil Procedure include three Rules that permit a party to move for
reconsideration. Rule 54(b) governs motions to reconsider interlocutory orders. See Fayetteville
Invs. v. Com. Builders, Inc., 936 F.2d 1462, 1469–70 (4th Cir. 1991). Rules 59(e) and 60(b) govern
motions to reconsider final judgments. Id. Rule 59(e) controls when a party files a motion to alter
or amend within twenty-eight days of the final judgment. Bolden v. McCabe, Weisberg & Conway,
LLC, No. DKC-13-1265, 2014 WL 994066, at *1 n.1 (D.Md. Mar. 13, 2014). If a party files the
motion later, Rule 60(b) controls. Id. . . .
Plaintiffs file their Motion to Reconsider under Rule 59(e). Rule 59(e) authorizes a district
court to alter or amend a prior final judgment. See Katyle v. Penn Nat’l Gaming, Inc., 637 F.3d
462, 470 n.4 (4th Cir. 2011). A federal district judge’s power to grant a Rule 59(e) motion is
discretionary. Robison v. Wix Filtration Corp., LLC, 599 F.3d 403, 411 (4th Cir. 2010). In general,
granting a motion for reconsideration “is an extraordinary remedy which should be used
sparingly.” Pac. Ins. Co. v. Am. Nat’l Fire Ins. Co., 148 F.3d 396, 403 (4th Cir. 1998) (quoting
Charles Alan Wright & Arthur R. Miller, Federal Practice and Procedure § 2810.1, at 124 (2d ed.
1995)). Furthermore, “[a] motion for reconsideration is ‘not the proper place to relitigate a case
after the court has ruled against a party, as mere disagreement with a court’s rulings will not
support granting such a request.’” Lynn v. Monarch Recovery Mgmt., Inc., 953 F.Supp.2d 612,
620 (D.Md. 2013) (quoting Sanders v. Prince George’s Pub. Sch. Sys., No. RWT-08-501, 2011
WL 4443441, at *1 (D.Md. Sept. 21, 2011)).
1
Also pending before the Court is Plaintiffs’ Motion to Correct the Plaintiffs’ Original List
of Defendants’ Receiving Summons As Contained in Complaint Filed July 4, 2022 Omitted In
Error in Filing of Complaint (“Motion to Correct”) (ECF No. 5). For the reasons set forth below,
the Motion to Correct will be granted in part and denied in part.
JA131
“Rule 59(e) motions can be successful in only three situations: (1) to accommodate an
intervening change in controlling law; (2) to account for new evidence not available at trial; or (3)
to correct a clear error of law or prevent manifest injustice.” U.S. ex rel. Carter v. Halliburton Co.,
866 F.3d 199, 210–11 (4th Cir. 2017) (quoting Zinkand v. Brown, 478 F.3d 634, 637 (4th Cir.
2007)). With respect to the third factor, there must be more than simply a “mere disagreement”
with a decision to support a Rule 59(e) motion. Hutchinson v. Staton, 994 F.2d 1076, 1082 (4th
Cir. 1993). “A ‘factually supported and legally justified’ decision does not constitute clear error.”
Jarvis v. Berryhill, No. TMD-15-2226, 2017 WL 467736, at *1 (D.Md Feb. 3, 2017) (quoting
Hutchinson, 994 F.2d at 1081–82). As to the “manifest injustice” standard, courts focus on whether
there was fairness in the administrative process or a denial of due process. Id. (citing Kasey v.
Sullivan, 3 F.3d 75, 79 (4th Cir. 1993)).
In the July 6 Order, the Court denied the TRO Motion upon finding that Plaintiffs had
failed to introduce specific facts demonstrating that irreparable harm was imminent. Specifically,
the Court held:
Under Federal Rule of Civil Procedure 65(b ), a Court may issue an

ex parte TRO “only if [] specific facts in an affidavit or a verified
complaint clearly show that immediate and irreparable injury, loss,
or damage will result to the movant before the adverse party can be
heard in opposition.” Here, Plaintiffs’ Motion avers exactly the
opposite, namely that they will suffer no harm for nearly two
months—even absent a TRO. Specifically, Plaintiffs seek a TRO
prohibiting the destruction of election materials covered by 52
U.S.C. § 20701. (ECF No. 2 at 1.) However, as Plaintiffs
acknowledge, § 20701 already requires retention of these documents
“for a period of twenty-two months from the date of [various federal
elections]” which Plaintiffs assert requires retention of the
documents they seek until at least September 3, 2022. (ECF No. 2-
1 at 1.) 1
1
Moreover, once Defendants have notice of this lawsuit,
retention of these documents would also appear to be required by
every litigant’s “duty to preserve material evidence.” Silvestri v.
Gen. Motors Corp., 271 F.3d 583, 591 (4th Cir. 2001). . . .
To the extent that Plaintiffs allege immediate harm, it is

limited to the bald assertion “on information and belief' that
Defendants are presently destroying the relevant materials in
violation of § 20701. (ECF No. 1 ¶ 19.) This unadorned accusation
plainly fails the Rule 65(b) requirement of proof by “specific facts.”
See in re Kunstler, 914 F.2d 505, 515 (4th Cir. 1990) (emphases in
original) (“[Rule 65(b)] requires that ‘specific facts’ be ‘shown’ to
the court with the request for relief. . . .”). In addition to being
evidentiarily unsupported, Plaintiffs’ accusations of spoliation are
particularly implausible given that any person who “willfully steals,
destroys, conceals, mutilates, or alters any record or paper required
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by section 20701 of this title to be retained and preserved” already

faces significant criminal penalties. See 52 U.S.C. § 20702. In short,
Plaintiffs have failed to meet threshold requirements for the entry of
an ex parte TRO. While the Court takes no position at this time on
Plaintiffs’ potential entitlement to other forms of preliminary relief,
such relief must be sought after notice to Defendants.
(July 6, 2022 Order at 1–2 & n.1, ECF No. 4). Further, the Court held the following with respect
to Plaintiffs’ requested for expedited discovery:
As the Fourth Circuit has explained, “[e]x parte proceedings are the
exception, not the rule, and the Civil Rules do not denominate
discovery motions as ‘ones which may be heard ex parte.’” In re
Pruett, 133 F.3d 275,279 n.8 (4th Cir. 1997). Indeed, those Rules
explicitly require notice to the opposing party before utilizing the
discovery options Plaintiffs request. See Fed. R. Civ. P. 30(b)(l) (“A
party who wants to depose a person by oral questions must give
reasonable written notice to every other party.”); Fed. R. Civ. P.
45(a)( 4) (“If the subpoena commands the production of documents,
electronically stored information, or tangible things or the
inspection of premises before trial, then before it is served on the
person to whom it is directed, a notice and a copy of the subpoena
must be served on each party.”). Accordingly, to the extent that
Plaintiffs continue to seek expedited discovery; the Court cannot
and will not entertain such requests without first hearing from
Defendants.
(Id. at 3).
Plaintiffs ask the Court to reconsider the July 6 Order primarily on two bases: (1)
Defendants now have notice of the lawsuit, and (2) Plaintiffs have uncovered new evidence
demonstrating irreparable harm. (See Pls.’ Rule 59(e) Mot. Alter & Amend Den. TRO
Alternatively Expedited Hr’g Trial Prelim. Inj. Avoid Immediate Vital & Irreparable Harm Per Se
Election Fraud [“Mot.”] at 8, ECF No. 6). At bottom, the new facts presented by Plaintiffs do not
alter the Court’s conclusion that the ex parte relief Plaintiffs seek is unwarranted.
First, the Court notes that over four weeks remain before the date on which the ballots will
allegedly be destroyed. (See Mot. at 9). Second, Plaintiffs provide only a bald assertion that
“[a]ctual notice substantially occurred on July 27-28, 2022 by email notice to about 30 named
parties.” (Id. at 8). Plaintiffs add that “formal Service of Process using the Waiver Process is
continuing for each of the 21 Voting Jurisdiction sued, and multiple alleged conspiratorial RICO
defendant entities.” (Id.). But Plaintiffs have provided no proof of service—or even proof of
notice—to this Court. The Court thus has no way to judge whether notice was effective, much less
whether service was made in accordance with the relevant procedural rules. Third, as noted in the
July 6 Order, Plaintiffs’ notice to Defendants of this action created a duty on the part of Defendants
to preserve material evidence, which would certainly include the ballots that are the subject of this
lawsuit. See Silvestri, 271 F.3d at 591. Fourth, Plaintiffs provide no new evidence in the Motion
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to Reconsider establishing why their concerns about document destruction set to occur on or after
September 3, 2022, are based on anything other than speculation. Indeed, almost all the Motion to
Reconsider, including the description of the findings of a prospective expert witness named Dr.
Douglas Frank, 2 appears to relate to alleged voting fraud that already occurred, not to any
destruction of ballots that may occur in September. Thus, it does not represent new evidence of
immediate and irreparable harm. 3
For all these reasons, the Court will deny the Motion to Reconsider. But even if the Court
were otherwise persuaded by the arguments in the Motion to Reconsider, the Court would deny
Plaintiffs the ex parte injunctive relief they seek based on the doctrine of laches. “The equitable
doctrine of laches applies to deny relief to a plaintiff who, though having knowledge of a claim,
has, to the detriment of the defendant, unreasonably delayed in seeking redress.” Hartjen v. Cross
Med. Prod., Inc., No. MJG-06-2938, 2008 WL 11509383, at *1 (D.Md. July 29, 2008). Laches
requires “(1) lack of diligence by the party against whom the defense is asserted, and (2) prejudice
to the party asserting the defense.” E.E.O.C. v. Propak Logistics, Inc., 746 F.3d 145, 149 n.5 (4th
Cir. 2014). Laches “can be invoked by a court on its own initiative.” Liddy v. Lamone, 919 A.2d
1276, 1282 (Md. 2007). Further, “[a]n injunction is an equitable remedy, and as such, the equitable
defense of laches is applicable.” NACCO Indus., Inc. v. Applica Inc., No. 1:06-CV-3002, 2006
WL 3762090, at *10 (N.D.Ohio Dec. 20, 2006). Here, Plaintiffs urge the Court to grant
extraordinary ex parte relief on the basis of immediate and irreparable harm that will allegedly
take place in early September. But despite their stated fears about this harm, Plaintiffs have allowed
an entire month to pass since initiating this lawsuit without filing proof of service of a single one
of the thirty-plus Defendants they name in the lawsuit. Plaintiffs cannot demand the Court provide
extraordinary ex parte relief while at the same time they drag their feet in prosecuting the lawsuit.
Such behavior exemplifies the “lack of diligence” against which the doctrine of laches guards.
Finally, the Court turns to the Motion to Correct. In it, Plaintiffs ask the Court to issue
summons for four additional Defendants: (1) Maryland State Governor, Larry Hogan, Jr.; (2)
Maryland Attorney General, Brian Frosh; (3) Maryland State Prosecutor, Charlton Howard, III;
and (4) Center for Tech and Civic Life (“CTCL”). Of these, just CTCL is a named Defendant in
this action. (See generally Compl., ECF No. 1). If Plaintiffs wish to add Defendants to this action,
they must do so by amending the Complaint. See generally Fed.R.Civ.P. 15. Accordingly, the
Motion to Correct will be denied as to prospective Defendants Larry Hogan, Jr., Brian Frosh, and
Charlton Howard, III. However, the Motion to Correct will be granted as to CTCL.
Accordingly, Plaintiffs’ Motion to Reconsider (ECF No. 6) is DENIED. Plaintiffs’ Motion

to Correct (ECF No. 5) is GRANTED IN PART AND DENIED IN PART. The Motion to Correct
is DENIED as Defendants Larry Hogan, Jr., Brian Frosh, and Charlton Howard, III. The Motion
2
Plaintiffs do not accompany their description of Dr. Frank’s findings with an expert
report.
3
It is noteworthy that Plaintiffs fail to identify any of the named Defendants who were part
of the group allegedly attempting to undermine the election process. By way of identifying the
wrongdoers purportedly responsible for the election fraud Plaintiffs seek to remedy, Plaintiffs state
in pertinent part only that “a group of presently unknown individuals and corporations, foreign and
domestic, set out to subvert the election process in the United States.” (Mot. at 11–12).
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to Correct is GRANTED as to CTCL. The Clerk is directed to ISSUE summons for CTCL. Despite
the informal nature of this memorandum, it shall constitute an Order of the Court, and the Clerk is
directed to docket it accordingly.
Very truly yours,
/s/
George L. Russell, III
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Lois Ann Gibson, et al and Maryland 20-20 Watch, )

Frederick, Maryland, et al; )
C/O Counsel, and Amicus, P.O Box 370 )
Woodsboro, Maryland, 21798; )
And ) Case No. GLR-22-1642
Class Representatives Pursuant to Federal Rule of )
Civil Procedure 23, and/or Putative Classes of )
similarly situated Voters of Maryland and/or )_
Elsewhere In the United States of America: )
And )
whatever State or County they reside, deprived of )
their Constitutionally Guaranteed, Freedom, Liberty, )
Expression and Right to an Effective Vote by the acts )
or Actions of the Defendants herein; )
)
PLAINTIFFS )
)
V. )
)
The State of Maryland and Several Agencies of the )
State, Including at least the State and County Boards )
of Elections in the Specific Counties Listed herein )
And )
A State and National Rico Enterprise, in Part Located )
in Maryland, and/or doing Business as Part of the )
Commerce in Maryland with Counties, i.e., )
Frederick, Howard County, Carroll Counties, )
Maryland and 18 additional Counties or Voting )
Jurisdictions: )
And )
A Chicago IRS Code §501 (c)(3) Corporation )
And; )
Presently Unknown Defendants, )
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And; )
The State of Maryland Office of the State Prosecutor, )
DEFENDANTS )
)
Notes to the Clerk of this Court, Regarding the Emergency Nature of this Amended
Complaint; the Necessity for forthwith Injunctive and Investigative Relief:
(1) Service of Process for the Multiple Defendants is Proceeding Pursuant to
Applicable State and Federal Rules;
(2) This First Amended Complaint is filed pursuant to Federal Rule of Civil
Procedure 15 (a)(1)(A) in that; on information and belief, no party has been formally
served or filed a responsive pleading to the Complaint, as of the date this First Amended
Complaint is Filed in this Court;
(3) Or Alternatively any such response is within 21 days of such response that has
been filed which is presently unknown to these plaintiffs and their counsel. Accordingly,
this Amendment, relies upon material evidence of the specificity of the Frauds and RICO
conspiracies alleged both foreign and domestic, and may include participants in acts of
war, in attempting to overthrow by fraudulent means the Government(s) of Individual
States and the Government of the United States itself.
(4) Under the RICO statute, with its inherent 10 year statute of limitations on
unlawful acts alleged, the specificity of the frauds is indeed Legion. Therefore all of
these allegations and parties place these plaintiffs squarely before this Court. Each and
every allegation herein, when tried or otherwise proven shall demonstrate the existence of
a Conspiracy to overthrow the lawful government of this Nation, by force, violence,
trickery and corruption of its most basic systems.
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(5) All of these matters reek of immediate and irreparable harm, the most urgent of
which is the failure of some of the conspirators to abide by the Federal protective statute
expiring within about two weeks, September 3rd, 2022. This Note to the Court and the
allegations contained in the Heading for this Case, and in the Body of the First Amended
Complaint, are therefore, respectfully requested to be construed as a request for a Hearing
on a Preliminary Injunction to be convened at the earliest opportunity.
(6) Plaintiffs respectfully request that this case should be on a fast track to a
Hearing on a Preliminary Injunction once notification has occurred, including attempted
service of process. Steps are being taken forthwith by Counsel to serve all necessary
parties within the State of Maryland, and the Chicago corporate defendant.
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FIRST AMENDED COMPLAINT

------------------
I. NATURE OF THIS CASE--A SUMMARY:
A. The background of this case began shortly before the presidential
election of 2016 when a group of concerned citizens formed an informal organization
entitled Maryland 20-20 Watch. Investigations were undertaken, a series of anomalies
and voting practices were noted and reports furnished to Maryland's governmental
officials and the groups investigated with no observable results.
Shortly before the presidential election of November 2020 plaintiff Mrs.
Lois Ann Gibson volunteered to be an election judge. She received the training and was
prepared to serve during the election of November 2020. However, on election day she
became ill and unable to serve. She testified via a declaration:
“on or around November 2, 2020, I Lois Ann Gibson, at approximately

9am, went to the Frederick Board of Elections Office at 340A Montevue
Lane, Frederick, Maryland to return the training manuals. This location had
a Ballot drop Box out front at the end of the building. I witnessed a man
hurriedly stuffing what appeared to be a large number of ballots at least
several dozen from a canvas bag he was carrying to the ballot box.
I asked this person who he was and seemed startled but said he was from
the Post Office and he quickly went back to the vehicle and left. I was
concerned because he did not have any official uniform, badge, or vehicle
and was very anxious. This incident occurred at or before 9am. “ [s].
Later, at a public meeting, with an employee of the Board of
Elections attending, when pointed questions were raised about surveillance
cameras for drop-boxes in Frederic County, an employee of the Board of Elections
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(Anthony) admitted that none of the eight locations for Frederic County Drop-
Boxes had functional surveillance cameras during the 2020 election cycle.
These and many other corroborating and supplementing anomalies of
malfunctions, along with accumulating similar information across the country cause a
surge of investigations some of which were reported in the complaint filed on July 4,
2022. That investigative effort as reported in the complaint also included financial
documents obtained from three counties Frederick, Carol and Howard.
The results of that analysis strongly indicated that the monies obtained as
grants from CTCL were used to influence the elections and likely included payments to
couriers and for the harvesting of ballots unlawfully delivered into drop boxes.
In the meantime similar investigations were occurring all over the country
and the various voter organizations and Maryland counties continued the investigation
process.
On or about July 21, 2022 a game changing revelation occurred in a
meeting of the Baltimore County Republican women's club. At that meeting a renown
physicist and expert witness, Dr. Douglas G. Frank, Exhibit # 10, made a presentation at a
regular club meeting. Dr. Frank presented evidence of voter rolls and voting that
demonstrates the existence of the system by which, nation-wide voters rolls are
fraudulently manipulated. Analysis of 43 states where this appeared to be true was
presented, and one of the most clearly manipulated election states was Maryland.
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That presentation resulted in Dr. Frank agreeing to become an expert
witness in this case and thereby to make available as evidence his evidence and
investigation results. That evidentiary material, up to that point in time, regarding a total
of 43 different states was striking. Systemic intentional voter fraud was demonstrated as
starkly apparent evidence in all of the 43 states examined, including Maryland.
Dr. Frank’s mathematical and statistical analysis is to the effect that since
the turn of the century public, data records regarding population and voter information,
using as a baseline, the United States Census, demonstrates what appears to be, with no
other credible explanation, material manipulation of voting results in all 43 states
examined. Further, the control methodology for achieving the results observed appear
from the data to be virtually the same. The inescapable conclusion is that a massive vote
fraud not only has occurred, but that fact is provable in Court with probative evidence.
His opinion, again based upon essentially incontrovertible data supports the
conclusion that Maryland leads the pack in terms of its success in manipulating vote data
regularly as a systemic fraud. But the most striking evidence of all is the conclusion that
the only practical way to accomplish this result is a database management system, on-line,
in each state being manipulated. If this is true, and it appears to be so, then exposure of
this fact amounts to a disclosure of a massive insurrection against our entire constitutional
framework, and this Country itself.
This case’s anecdotal evidence was then compared to this new evidence.
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Both sets of information corroborate each other set. Therefore, plaintiffs amend their
allegations to include this specific allegation of vote fraud by systemic controls over the
election process, both voting and counting, based upon this new evidence. It is now
alleged that this fraud has occurred in all counties and overall in the 2020 election.
Plaintiffs propose to prove that result by probative evidence presentation to
this Court, and/or at the accelerated hearing on a Preliminary Injunction. But, the
defendants must not be allowed to destroy the evidence contained in paper, electronic and
data base systems, the data itself, with four elements preserved, reports and displays,
controls, storage and retrieval elements. Also, with on-line data control systems, system
and data definitions, and programs preserved.
These materials are in addition to paper ballots and electronic images of the
results of voting and vote counts. From all of these materials a 30(b)(6) deposition or
three, will, plaintiffs allege expose the entire fraudulent scheme. If preservation does not
occur, such exposure of the truth shall not be possible. (Or as a practical Matter very
much more difficult).
This conclusion is further corroborated by the experiences of undersigned
counsel with on-line digital financial and personnel database management systems, and
supports the conclusion that a highly effective database control system allowing the
manipulation of vote counts does in fact exist in the state of Maryland. The effectiveness
of the application of available statistics and the weaknesses, or more correctly the total
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lack of any chain of custody control over ballots or voter identification measures has
allowed and continues to allow a total breakdown in the credibility of Maryland system.
This breakdown in all 43 examined states, including the six swing states examined by Dr.
Frank's methodology supports this conclusion to a high degree of certainty.
Further, this conclusion by Dr. Frank is corroborated by all of the anomalies
known to exist beginning about the turn of the century by Maryland 20-20 Watch and all
of the exhibits one through 11 attached to this first amended complaint.
To further corroborate this opinion and the existing set of evidence to the
point of trial evidence to a certainty of nearly 100% certain all that is necessary, in the
opinion of plaintiff's here in and their counsel is to conduct a short series of 30 B6
depositions with associated subpoenas for documents in the form of the database files
which are known and admitted to exist in the offices of the Maryland State Board of
elections. Also necessary would be depositions of control persons who do the actual
manipulating of the database systems to commit the fraud and the vote counts in
Maryland.
Respectfully, it is imperative to the interests of justice that this Honorable
Court allow the presentation of the above evidence and has coordinated there with issue a
fourth with stay on the destruction of any election materials electronic or otherwise by the
persons who are now known to have committed these horrific breaches of duty and trust
of this state and their country.
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B. CONCLUSION REGARDING INJUNCTIVE RELIEF:
Accordingly, the court should issue the necessary orders setting the date of
the hearing for a preliminary into injunction at the earliest possible moment. In addition
the court should approve at least a truncated discovery scheduling order to include the
issuance of subpoenas duces as needed and preservation of all election records and
materials from November 2020 elections and later until removed by further court order.
II. JURISDICTION:
Plaintiffs in this case filed this action on July 4th 2022 as a Federal Cause of
action in the District of Maryland. They allege Federal Question jurisdiction regarding
wide spread intentional vote fraud in Maryland and elsewhere in the United States of
America. They allege amounting to systemic fraud, in highly similar actions in virtually
every state, and essentially all Counties and Voting Jurisdictions in Maryland. Recent
developments, some of which were unknown at the time of the filing have allegedly
uncovered the virtually identical pattern of data-based computer fraud in each state.
A conspiracy under the RICO statute and other constitutional violations,
including the equal protection of the laws, falsification of State and Federal Voting
records and the magnitude of the claims and due process violations patent in the facts
firmly establish Federal Jurisdiction. The temporal scope of the claims is beginning in
about the year 2000, proceeding through the 2016, and 2020 presidential elections, and
ongoing at the present time.
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The patten of alleged fraud, as demonstrated by both statistics and sworn
anecdotal evidence, is virtually identical in all states. The frauds consist of at least 7
different methods of false voting and manipulation of voting results. A centralized on-
line database management system, and a stash of available false but credible on their face
votes is the heart of the fraudulent state-wide system.
The recently discovered central control mechanism, on-line data-base
manipulation and control of utilizing a repository of pre-selected vulnerable voter
registration “available fake votes”. “Inflating our registration rolls, stuffing phantom
ballots, and then cleaning it up afterwards, its that simple” (Ref. Frank Comment
regarding Idaho voter fraud). Therefore these fake votes, phantom voters, accounts
available for minipulation, is central to the claim of Multi-District fraud upon honest
citizens. Examination of public data in (as of now) 43 states discloses the fraudulent
manipulations.
The pattern is inescapable, amazing, and clear. That central claim, and the
mechanism of the fraudulent actions also provides the key to the methodology as well as
the proof of its existence. The fact of a central control system also, if preservation of the
evidence is required, and a short but targeted discovery is allowed, with subpoenas, shall
provide, by the time set for a preliminary injunction hearing incontrovertible proof of the
truth of the allegations herein.
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III. NECESSITY FOR A PROTECTIVE ORDER
To provide this solution, the Court is requested to reconsider, and hold an
adversary hearing regarding such an emergency Injunctive Order, i.e, that all such
election evidence must be preserved beyond the cut-off date of September 3, 2022. Such
Order is requested for Maryland, and for all other Federal Districts. Otherwise, the Court
can expect the perpetrators of these voluminous frauds will destroy the evidence of their
guilt.
For this reason, a protective order extending the existing deadline during
this pendency of this case is vital, not just for proof of the allegations herein, but for
elimination of the fraud in all future elections. Thereby, elimination of the fraud(s) in this
case provides a just avenue for all-time elimination of such events in our voting history.
by injunctive corrections by this Court. Upon the conclusion of this case, with proper
implementation, the history of such outrageous abuses as outlined herein should be
expected to cease.
IV. DETAILED STATEMENT OF FACTS
1. This filing is believed to be an unprecedented, unique, but likely determinative
of the future of election fairness in for this State.
2. The designation and classification of this case as a potentially multi-district
Federal and Maryland class action appears to be warranted based upon similarity of
claims, and information now available on similarity of methodology of election fraud now
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known to exist in multiple, but likely not in all jurisdictions, in the United States.
3. Accordingly, this case is filed on behalf of all honest American citizens who
have been deprived of their Constitutional freedom and right to a fair election in
Maryland, and elsewhere across America, for now and forever with a hope and trust in
God, that this Country as we know and love it survives.
4. Nation-Wide fraud and money laundering, has undoubtedly occurred and shall,
unless stopped in its tracks, occur again. In the 2020 election, in Maryland, in a series of
Twenty-One fraudulent payments to County Government, through apparently normal
official budgeting receipt channels, payments, disguised as “grants” totaling for the 21
counties, $ 6, 245,797 (million) dollars, monies were “Granted” to 21 Jurisdictions in
Maryland.
5. Apparently through a uniform process by a carefully controlled, “conditional
agreement”, from two documents furnished, the same “Grantor” (CTCL or Grantor) in a
separate “Boiler-Plate” type document for each county of the 21 Counties in Maryland,
through their party controlled leaders, donated a substantial sum of money designated for
particularly defined uses related to the Presidential Election of 2020.
6. Those funds were carefully proscribed to be spent, by the Grantor, and agreed in
writing as a signatory to the Grant Document by the County Management, for a particular
(purportedly) innocuous and perfectly lawful, usage.
7. But, disclosure of the money spent does not conform with the stated purposes.
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The funds were just not spent that way, in fact a large proportion of the funding are
alleged to be for unlawful purposes designed to aid one party, the one party favored by
the Grantor.
8. This allegation, if proven to be true, as it appears from the three County sample
of financial records examined would be a massive violation of election law as well as tax
law, filtering down to every individual who performed any unlawful service.
9. Such violations, by individuals and supervisors would necessarily be in
violation of any of the applicable laws. In addition, all financial officials would be
misreporting budget funds to the extent any misspending or misreporting occurred.
10. The purported purposes, clearly were disguised, designed and incorporated into
the “Grant Agreement Document” strictures to fraudulently protect the tax exempt status
of the Grantor, but ONLY IF, the Grantor’s Agents, or Principal Donors, knew or should
have known that BOTH the Grants and the Facilitators, the Harvesters paid the big money
listed on the disbursement sheets.
11. It appears, and Plaintiffs allege, that these money launders were, either the
couriers who delivered the harvested and created unlawful votes, or they conspired with
the persons who got paid for delivering them to the drop boxes. In either event, these
persons who received the money, and those that handed it out, were in fact unlawfully
biased.
12. Similarly, so were the very agents doing the negotiation, for the Grantors,
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CTCL, and for each receiving County. Implicitly, its management as well as the Grantee
participated in the Tax fraud which are imbedded into this RICO fraud conspiracy
process.
13. In this regard, Plaintiffs seek the immediate permission to conduct at least one
Rule 30(b)(6) deposition from each of the four counties, Frederick, Carroll, Harford and
Howard, on a forthwith basis.
14. Permission is requested to require, immediately upon service, that each County
to furnish the person or persons who negotiated with the Grantor, and those who assigned
personnel and equipment and expended the funds donated including record-keeping on
those expenditures, including personnel for a Rule 30(b)(6) deposition, after responding
to subpoenas for the relevant documents for each county where material deviation from
normal is indicated.
15. It is expected that testimony will be elicited to the effect that the requirements
expected by the Grantor (CTCL) included prohibited practices, and the Grantor’s funding
persons were well aware of the unlawful nature of the actual requirements as
distinguished from the purported fraudulent requirements of the written Grants. This was
because neither the Grantor, nor the Grantee ever expected those “paper” requirements to
be followed.
16. If those requirements were serious, and other than a fraud which they were,
there would have been some follow-up, corrections and corrected reporting on the actual
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incorrect, i.e. overpayments, underpayments or simple reporting errors, or missing a
required limit. It is telling that not only were there none, there were not even any
semblance of any such bookkeeping adjustments.
17. However, after three counties of comparisons, there were no such corrective
actions, not a hint of a single one. This apparent fact demonstrates forcefully the fact of
the subterfuge.
18. In this regard, Plaintiffs request permission to advance and notice several
30(b)(6) depositions, along with necessary subpoenas, forthwith, before the hearing on
the Preliminary Injunction to clarify facts necessary to aid the Court at the time of the
Preliminary Injunction hearing.
19. This information, easily obtained, will demonstrate this key element of the
financial manipulations of each counties record. This is evidence demonstrating the
financing element of the actual vote counting fraud throughout the State of Maryland.
20. As a related but different aspect of the presence of fraud in this entire
situation, those same manipulations were in fact an enabling fraud which violated
Federal Tax law, both individual (as to the contributors and managers of the “purported
charity”, and lack of enforcement by IRS as a federal agency. The truth is, that the
purported tax constraints were nothing but sham requirements designed to facilitate and
hide the real purpose of the alleged charity, vote fraud, paid for by our own Federal
Government via loss of tax revenue by extremely wealthy contributors. The requirements
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were merely a fraud for subverting the legal requirements with camouflage, and the fraud
worked, beautifully.
21. It has been admitted by the Elections Board of Frederick County, by its
chairman, a county employee, that for the past presidential election, there were 8 drop
boxes in Frederick, County and Eight cameras for surveillance.
22. And none were ever monitored (Admission of party opponents in open
meetings).
23. The lead Plaintiff, Ms Gibson, was on election day, a trained Judge of
elections, however, she was ill and therefore could not serve as a judge. She, while
attempting to return election materials to the office before hours, observed and interacted
with a person depositing “dozens of ballots into the drop-box and inquired, “what are you
doing”. The person responded, “I am from the Post Office”, then quickly got in his
vehicle. (Declaration, Lois Ann Gibson) (Exhibit # 2-1). The post office deliveries are
not made into drop boxes, and there is no working surveillance camera at that location, or
any other in Frederick County (Admission of “Anthony” a Election Board employee of
Frederick County in an open public meeting).
24. When later, at a Board meeting, further questioning elicited the responses to
the effect that the video tape cameras were never monitored, so all such events have for
the entire period of drop-box use, apparently been without any intervention, control or
monitoring whatsoever. All of this failure is contrary to the requirements, of the
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Maryland constitution for which the State of Maryland, and the Maryland State
Prosecutor have the duty to monitor fraud and abuse. They failed.
25. An oral admission from the Board of Elections of Frederick County is
believed to report that the surveillance cameras for the eight drop-box locations were
privately owned, privately controlled, and no examination at all has ever been made of the
tapes which would indicate with specificity the identity of the couriers acting as mules for
the fake overrun ballots.
26. This entire subject shall be explored for available probative evidence utilizing
30(b)(6) depositions and subpoenas just as soon as the Court authorizes such usage. The
suggested plan (at this time, subject to change) is to start small to obtain details on the
methodology of the fraud, present the facts at the hearing for a preliminary injunction,
and plan the trial evidence gathering soon thereafter.
27. All of the 21 Counties would be expected to be analyzed for fraudulent drop
boxes and addresses, in detail, with the burden placed upon the County, in each instance
to show a reasonable methodology preventing fraudulent count results. All of this would
be prospectively applied and controlled, with the consequences of the past election to
follow as dictated by the Court to follow in due course thereafter.
28. The accounting records for the three counties examined indicate manipulation
of the county disbursement records to conform to the penny to the grant amounts. As an
accounting matter this item alone renders these figures suspect. These indicators
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cumulatively demonstrate that it is extremely likely that the identity of the recipients of
the funds, which does appear to be recoverable via subpoenas, coupled with a deposition
would indicate with specificity that these particular persons performed at least some of
the fraudulent acts. Those resulting, in counting of inactive voters and deceased voters,
for example, and the electronic manipulation of ballot results.
29. This conclusion conforms to the results observed across the country and the strikingly
similar pattern of the unlawful Corporate Financing of the voter fraud. See below for
confirmation of this actions of the part time workers, paid with the unlawful corporate
money. These actual tasks, as compared to the non-partisan tasks for which they were
purportedly hired shall be gleaned, for those part time workers specifically, one way or
another, by the planned subpoenas and depositions, hopefully as approved by the Court
on an emergency basis prior to the hearing on the Preliminary Injunction.
30. On information and belief, all of the voting machines in Maryland are all under the
control of the Dominion/ES&S Rico Enterprise, rented or owned or otherwise a
controlled system. This system, and management controls are well established to have
online capabilities and manipulation capabilities actually observed as such on multiple
occasions.
31. Repeated inquiries for a description of the chain of custody of ballots removed from
drop boxes (if any exist and subsequent handling) i.e. , placing of ballots into the boxes,
removal from the boxes and forwarded ballots to machine counting or other accumulation
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stations. Control counts apparently for the three counties apparently do not exist.
32. Certainly, no such detailed descriptions of control methodologies have ever been
received in response to inquiries. No response at all has ever been received from the
three counties examined. And again, no surveillance tapes or results have also ever been
described in materials received, and apparently, on information and belief, do not exist.
33. This aspect of the analysis for the three counties is presently being re-verified, and
shall be subject to the subpoena process in the interim between the filing of this complaint
and the requested hearing on the Preliminary Injunction.
34. On information and belief a substantial number of persons received funding from
participation in the collection of ballots from voters, and distribution to drop-boxes. See
testimony of plaintiff Gibson (Exhibit # 2-1) and adjoining County detailed payments,
(Exhibit # 5) , and the newly discovered scheme (Harvesting unused ballots from voters
who have left the state, via the ERIC system, Exhibit # 3).
35. Disbursement records disclose that some individuals received multiple checks or
money orders for paid activities that remain undisclosed in the disbursements record,
despite repeated inquiries. Relatively large sums of money for specific persons who
received more than one check have been observed, without the explanation of duties
required by the Grant Contract. As mentioned earlier, three persons from Howard County
received identical sums of over $ 11,000 each, out of a total of over 800 individual money
distributions to about 730 different persons. Strangely, the great majority of the
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distributions were in round dollar (that is .00) amounts, an indication of piece work
payment, as for example, for a per ballot delivered pay rate (as rumored). This matter
will be verified by a subpoena or deposition in due course.
36. A Federal Rule of Civil Procedure Rule 30 (b)(6) deposition coupled with a
subpoena for disbursement documents is presently being requested to be permitted, one
such subpoena and deposition, for each of the three counties for which the initial
investigation leading to injunctive relief is requested.
37. Similar inquiries are expected based upon the successes to be achieved by this
investigative result during the immediate interim week following filing of this complaint,
as applicable to the remaining 18 Counties receiving Grant funds (Exhibit #1).
38. A substantial equipment expenditure appears in disbursement records for the four
Counties for which expenditure data was only partially acquired. The request for several
subpoenas pursuant to a Rule 30(b)(6) deposition, and equipment disclosures shall
include a production and/or inspection of all such equipment, and also ballots, with
envelopes made available for inspection and copying for test purposes.
39. It is expected that a subpoena for production of all electronic images of voting and
actual paper ballots and envelopes will require a subpoena for leave to examine all ballots
by electronic equipment, likely for all three sample counties.
40. To date requests for such complete production have been resisted, (in two of the three
examined counties) accompanied by a demand for payment for purported retrieval
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expenses.
41. At the hearing for a Preliminary Injunction, a request shall be made for a protective
order requiring production of each and every ballot and envelope as well as electronic
images, to the extent such exist. It is not expected that such production will be on an
emergency basis, but a substantial testing is necessary for a complete analysis of the
allegation that false or duplicate copies of ballots were manufactured as a part of the
alleged fraud. Such forensic testing is now well known to be within the state of the
balloting art and science (Ref. Jovan Hutton Pulitzer, et al).
Three Kinds of Fraud in the Grants
42. The specificity in the three kinds of fraud in the Grants are: (1) To hand out money,
purportedly for a lawful purpose, but as a hidden yet operative part, the real agenda, is to
never countermand, or challenge the misuse and misreporting by the governmental
agency of the actual unlawful use of the funds, and the cover-up of the misuse by
misreporting. The actual use of the funds, that is the actual monies spent from the
disbursement records have been furnished.
Those expenditures do not comport with the purported uses required by the
Contracts. Again, the use of at least one Rule 30(b)(6) deposition as to what was done,
and the associated equipment expenses is expected to elicit details of specific matters
directly related to election ballot and counting fraud. This fact has implications wherever
it has occurred.
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And alleged fraud appears to be identical for all Counties, from the consistency of
the contracts required for rewarding of the Grant(s) across Maryland (See Exhibit # 1, -
grants from same grantor, $ 6. 2 Million). (2) disclosure of tax fraud by those large -
money contributors. (3) the Grantor fund would itself be participating in a tax-fraud and
would lose its exemption from tax laws retroactively, with parallel effects upon its donor
contributors.
43. The purportedly innocuous classification of Grant Use matters are by no means
routine violations or mere error. Such manipulation of decades-old IRS Section 501(c)(3)
principles are: (when demonstrated to have occurred with knowledge or intent as appears
herein) would be in reality intentional violations of Tax law, by both the Grantor and the
Grantor’s principals, those with knowledge, who participated in the tax evasion as well as
the misreporting of fraudulent received funds, with intent to subvert the election laws of
the State of Maryland as well as the Tax Laws applicable to non-profit 501 (c)(3)
organizations (For Example, Defendant CTCL) .
44. The existence of these malfunctions have been disclosed and are alleged in this filing.
Given the apparently reoccurring and casual nature of the misreporting discovered as to
the three Counties investigated, to date but only considered as a voting integrity matter,
the evidence is nevertheless clear.
45. For this reason, all records of all related financial transactions, Grants, reports of
expenditures, 1099 forms for all employees, whether regular or temporary, to deliver and
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pick-up ballots, or otherwise are hard documentary evidence of the intent to use
misstatements of or mislabeling of entries into financial records to cover-up the fraud in
the ballot fabrication and false delivery process.
46. And this process will undoubtedly be repeated in future elections unless it is
corrected forthwith, with this lawsuit.
47. Second, the Grantor, the non-profit organization, would upon demonstration of a
biased, non-qualified for charitable taxable use of Grants, be expected to lose its tax
exempt status under IRS Code Section, 501(c)(3). In this event, where the contributors
conspired with the Grantor, and took tax deductions, they would be expected to be
participating in a tax fraud.
48. If, as reputed, large contributors were involved with knowledge of these improper tax
deductions, those Contributors could be liable for recovery for Tax Fraud, and possible
false claims act liability.
49. This disclosure would be expected to have severe consequences to each of the large
contributors who it appears have funded the unlawful nation-wide constitutional
violations, while being rewarded for their unlawful efforts with large tax deductions, to
which they were not in fact eligible. Such considerations would be a related matter to the
main thrust of these claims of voter fraud.
50. Cleverly, and apparently incorrectly, as if with knowledge of the falsities, the
agreement with each conspiring donee voting jurisdiction (a County, like here Frederick,
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Howard, and Carroll, and presumably 18 others) would have to agree to spend the money
for the legitimate purposes as agreed.
51. If the constraints were not met, as they apparently were not, at least in some
instances, each such failing jurisdiction would purportedly (under the terms of the
contract) have to refund the Grant. Apparently none have done so. Each such instance
would be both a voting law violation, and a tax law violation, and each such fabricated
vote would be a constitutional violation if each plaintiff voter whose vote is negated by
the false uttering procedures.
52. New technology now aids in identifying and proof of the various methodologies to
catalog and prove each type of fraud. This has now become practical, given the
disclosure of the Ballots and Envelopes, to an amazing extent.
53. To the extent each official who disbursed the money and covered up the failure to
spend it as agreed, that person would also be committing, or at least aiding and abetting
the overall tax evasion scheme, for every 1099 error and each tax deduction as well. If
any part of the funds were used for an unauthorized, or unlawful purpose, that County
would be in violation of the Maryland Election law.
54. To the extent this evidence, when placed in good form via, subpoenas and
depositions an election law violation has occurred, and will thus occur again unless this
system is disassembled by legal edict, of one kind or another. This malfunction of the
working persons level within each county government accepting such funds now has
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become clear.
55. To this end, once the equitable relief necessary for corrective action become effective
by Order of the Honorable Court, it appears that corrective action in the form of
legislative actions, or even jury decisions may become necessary as determined according
to Constitutional constrains under the existing Twombly/Iqbal procedural standard,
56. Nevertheless, as to Grant funds received and expended, the evidence clearly shows,
when finally produced, after years of attempting to obtain it, the purposes for which the
money was spent do not conform to the agreed in writing, election neutral purposes.
Testing of actual uses of the funds as comparted to the required partizan neutral
requirement is expected to demonstrate unlawful bias pervading the Grant distribution
process along prohibited partizan lines. And also cover-up of the violations by knowingly
false financial reporting.
57. Thereby, the honest functioning of Maryland’s entire constitutional process is not only
threatened, but virtually guaranteed to fail in the upcoming election as well. All that
must occur to assure this result and to assure the replication from now on, is a simple
expansion and repeat performance of the “Gibson drop-box trick” which is, by all of the
available evidence, now alive and well in Maryland. (See, Exhibit # 2.1. Declaration of
Witness, Lois Ann Gibson).
58. To demonstrate the magnitude and the prevalence of the unlawful practices in
Maryland these Plaintiffs submit herewith both anecdotal and sampling evidence
demonstrating the existence of election fraud. The frauds have occurred, both in the
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biased financing of the election operations, in hiring of personnel and the false and/or
inaccurate reporting of funds spent as received from Grants, and in the misdirection or
obstruction of inquiries regarding expenditures of “Grants”.
59. All but three Counties in Maryland have partaken of the funding by outside
influences, subject to control over the spending. That control, apparently is uniform in
abuse of not conforming to Federal Guidelines, this also being apparently a tongue- in-
cheek, disguise according to the sampling completed as of the date of this filing. The first
three counties for which data has been retrieved and examined. 18 more counties have
received the suspect funds, but expenditures have yet to be analyzed by plaintiffs herein.
See Exhibit # 1 for Total Funding Reported for Maryland, subject to analysis.
$ 6,245,797.
60. The events described in this lawsuit, unless placed under judicial control,
immediately, threaten the stability of the Republic, threaten to destroy all hope of any fair
election process for all time.
61. This filing is also pursuant to the Constitution of the United States of America and
the Constitution of the State of Maryland’s believed to be unique Amendment. That
amendment, established the Maryland Office of the State Prosecutor 1with the jurisdiction
and specific power to investigate election fraud.
That agency has not yet responded to our requests for an investigation
and/or aid in the investigation of the factual underpinnings of these Class Actions.
62. This filing is also, pursuant to federal rule of civil procedure 23, alleging, among
1
Maryland State Prosecutor - Origin & Functions, https://msa.maryland.gov › msa ›
mdmanual › html. The office of State Prosecutor was established by Constitutional Amendment
in 1976 (Chapter 612, Acts of 1976, ratified Nov. 2, 1976). Part of the Constitutional duties of
that Office is to maintain election integrity, free from fraud or political abuse.
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other violations, a RICO conspiracy by multiple parties, alleging fraud, money laundering
and bribery; a conspiracy to violate federal constitutional liberty, due process of law, and
federal and state civil rights (abrogation of voting privileges by fraudulent dilution of
valid votes).
63. This filing is also against the State of Maryland in that the Constitution of the State of
Maryland, in an Amendment thereto established the Office of the Maryland State
Prosecutor, with the specific jurisdiction and authority to investigate Election related
violations of law and fraud. This State failed to carry-out its duty to insure that the voters
systems and function were free from fraud, manipulation and malfunction.
64. Accordingly, the State of Maryland should be held accountable for all expenses of
remedial action with regard to all of the matters herein, and funding of corrective
measures including the attorney’s fees and costs of this litigation and all cures required to
create a workable fraud free system beginning immediately.
65. This prospective loss of the right to vote, is material, genuine, and
undeniable, both as to what has previously occurred, and prospective continuing
irreparable harm absence of the required extraordinary corrective action.
Immediate and Irreparable Harm Has Occurred and is Continuing:
66. Immediate and irreparable harm has already occurred, is continuing, and is, on
information and belief is now being planned by the wrongdoers to be repeated. Thereby
absent extraordinary emergency action by this Court shall not just continue, but to be
exacerbated, and will occur again into the foreseeable future. There is no reason why any
doubt whatever exists as to the likelihood of these fraudulent actions to continue.
67. Need for Injunctive Relief with evidence Protective Orders, Witness Protection
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and mandatory financial and date protection Orders are required to extend the
preservation of evidence to Conform to 52 U.S.C. § 20701 until full knowledge of these
complex facts can be disclosed, corrected and expunged for all time from our
governmental acceptable function.
68. These acts shall continue, as in the normal course, with continuing immediate
irreparable and unconscionable damages, so long as the denials of rights extant in the
occurrences of the past and foreseeable future are not corrected. All of this is contrary to
the contract contained in both the Maryland Constitution, and the Constitution of the
United States of America. The Property, Liberty, and Voting Rights, of each State of their
residency’s guarantees, (for example here) these Plaintiffs, the State of Maryland, and/or
in their respective State (Again Here the State of Maryland) by the events described in
this Complaint for Relief and/or as attached.
NEWLY DISCOVERED EVIDENCE

ADDED IN 1ST AMENDED COMPLAINT
69.. Exhibit # 6 (Attached to the First Amended Complaint).
70. Newly Discovered Evidence, Alleged to be Business Records and An

Admissions of a Party Opponent.
The Maryland Board of Elections, by the release of its records to an apparent
Baltimore Sun reporter, and her reporting on the internet on or about July 11, 2022,
disclosed that it had sent, so far, about a half-million ballots to persons who requested
ballots, issued in the names of purported genuine voters, with the names printed on the
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Ballots, for use in the Maryland State Primaries, which occurred, July 19, 2022.
71.. It is alleged, that it is self-evident that no proper vetting, identification of the
person making the requests, of security, AT ALL could have existed on such a high
volume of requests. Further, as labeled in Exhibit 6, labeled by the defendant Election
Board, About 55,000 of the requests were by July 17, 2022, internet email.
72.. Exhibit #7, Mail In Ballot Requests by County, November 3, 2020. Exhibits 6
and 7, standing alone, demonstrate that there is no chain of custody over election Ballots,
sufficient to guarantee that Maryland Voters will get a secure and non-corrupted election
result without great change.
73. Exhibit # 8 is the results of the Harford County “canvas” demonstrating the
series of anomalies found to exist by investigators, 8/1/22.
74. But this result, a conclusion of no vote security at all does not stand alone.
The expansion of the drop box use and the also admitted (by Frederick County) that the
surveillance cameras at drop boxes ( 8 in the previous election, of 2020, are not owned or
maintained by the County and further none of the cameras were even checked during the
previous election wherein the lead plaintiff herein gave eyewitness testimony of volume
stuffing of drop boxes.
75. It has also been recently discovered that flawed ballots are “re-created”, i.e.
Entirely fabricated on new paper, not by the voter, but by members of the purportedly
unbiased election board or its apparently contract employees by purportedly unbiased
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“election personnel”.
76. Exhibit 9, Surveillance cameras in Harford County did not have the capability
to retain the (tape) footage.
77.. But this process totally by-passes the supposed and lawful essence of the
election process. The vote is not secure, and the result is only exactly what the election
governmental managers want those results to be, a totally fixed election with the sanctity
of a secure secret vote gone, forever or not, depends upon the outcome of this case.
78. Accordingly, the immediate and irreparable harm is occurring, right now by
the creating and distribution of Ballots to anyone requesting a ballot. Exhibit #6 and #7
are compilations of the Requests for Ballots that were made and distributed to those
individuals for the 2022 and 2020 elections to date. This procedure is an outrage
violation of all of the principles of election security and must be an initial effort to
subvert the system. Exhibit # 6, contains data from the account of the Request for ballots
which contain the official records of the Maryland State Board of Elections, as excerpted
from its records, and reported on the internet and in the Baltimore Sun paper on or about
July 11, 2022. The Maryland Election Board are using a totally corrupted non-secure
election system methodology. There is no chain of custody, no validation for active
voters, and the ERIC system for flagging departing Marylanders which triggers the
availability for utilization for a harvested ballot.
79. NOTICE OF INTENT TO REQUEST A CLASS OR CLASSES OF

NAMED CLASS REPRESENTATIVES:
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Approximately one named class representative is expected to be selected to
represent each political subdivision of the State of Maryland, and similarly, for each state,
to act for themselves and a class (or classes) of all other citizens of every qualified vested
voter of Maryland and all other persons, in Districts across the Country, similarly situated,
as a F. R. Civ. P. Rule 23, class and/or, Alternatively an Opt-In collective action, or both.
80. THE CLASS(ES) OF PLAINTIFFS:
This case is a Federal Claim’s Multi-District RICO Federal Rule of Civil
Procedure, Rule 23, Class Action. Also, alternatively, a Collective Action by a large class
group, or alternatively an Opt-In collective action Citizen/Voters.
81. MOTION FOR A PRELIMINARY INJUNCTION; AND/OR RENEWAL OF

MOTION FOR AN EMERGENCY TRO, TO PREVENT SPOILAGE OF
ELECTION CRITICAL ELECTION MATERIALS BY BOARDS OF
ELECTIONS, BOTH COUNTY AND STATEWIDE:
A. Plaintiffs Hereby Request an Extraordinary Emergency Hearing on
Preliminary Injunctive Relief, to Require, Permanent Preservation of Evidence of the
Ballots, Envelopes and All Related Election Records, Both Financial and Operative,
Related to the Presidential Election of 2020, under Penalties of a Finding of Violation of
Felony Spoilation of Federal Election Materials.
B. The revelations contained in this First Amended Complaint, including
the existence of a secret system of databases and database controls for manipulating votes
and vote counts shall be destroyed, unless all such materials existing at the Maryland
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State Board of Elections, and, also to the extent any local county Board of Elections used
such materials.
C. Now, critical facts regarding the alleged existence of an unlawful
database control system operating in the State of Maryland coupled with the service of all
materials upon the State of Maryland, through its Attorney, and the looming cut off date
of September 3, 2022 for destruction of materials from the 2020 election have radically
changed the danger of spoilage. This change in the degree of concern with spoilage has
become, likely critical to this entire case.
D. Without a forthwith Protective Order, reminding Defendants of the duty
to preserve evidence, coupled with extension of the currently effective evidence
preservation date of September 3, 2022 will undoubtedly result in destruction of trial
evidence. That event, if it occurs will likely determinative of an unjust result in this case.
E. That result shall be catastrophic in result, not just unjust. It shall be a
message to all Traitors that they have a defacto license to do whatever the perpetrators of
the frauds herein wish, forever regarding rules of law, and destruction of evidence, with
irrevocable and irrecoverable harm.
F. The evidence of malfunctions will be forever lost from recovery.
Accordingly the preservation Order included in a Temporary Restraining Order should
issue, postponing destruction of all election materials pending further Order of Count.
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82. Linked to the preservation of evidence, and considering the great benefits of
additional, easily obtainable evidence Plaintiffs Request Permission immediately upon
service of process, to Issue 3 to 6 Subpoenas for Documents and 2 Rule 30(b)(6)
deposition notices for each County or voting jurisdiction in Maryland.
This Request for Documentary Evidence Production via Subpoena, and
30(b)(6) testimony supporting document production information, is Intended to Produce
Documents and Testimony which shall, be presented at the Initial Hearing on a
Preliminary Injunction, shall either produce overwhelming and definitive proof of the
actual fraudulent facts and the magnitude thereof or not, in each of these 21 counties and
elsewhere, every voting jurisdiction im Maryland, and likely every State, resulting in the
massive election fraud which, now, has become impossible to deny existed. The use of
the subpoena power of the Court will greatly simplify and clarify the Injunction
presentation and clarify the interests of truth and justice.
A draft Preliminary Injunction Order shall be produced forthwith upon
conclusion of the hearing on a preliminary injunction. The Honorable Court is urged to
use its emergency powers to set this hearing before September 3, 2022 to avert loss of
critical determinative evidence.
In the event this Order is not Granted, all election materials, including
Envelopes and Ballots, and financial records are subject to destruction, pursuant to 52
U.S.C. § 20,701.
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Undersigned Counsel certifies pursuant to F. R. Civ. P. Rule 65 (b)(B) that
in several of the voting jurisdictions, repeated request by Plaintiffs utilizing normal
informal and PIA methods have elicited oral or non responsive answers, strongly
indicating that preservation method are already being violated, or de facto adherence to
that law was never followed in the first instance. Therefore further destruction of key
evidence is likely and expected to occur without, or even in spite of an Injunction Order.
For this reason an injunction should be issued with the normal expiration
date of 90 or 180 days, subject to renewal as per Rule 65.
V. CONCLUSION
A. For all of the above reasons either a expedited hearing on a Preliminary
Injunction should be granted, as needed to extend the statutory destruction date for
Election materials and financial records of September 3, 2022, renewable upon
application, should be granted. Further permission for the issuance of 5 Notices of F. R.
Civ. P.30(b)(6) depositions is granted. Attachment A is a draft Temporary Restraining
Order.
As to the accompanying request for permission to take several Rule
30(b)(6) depositions, the Court should limit quashing of production of materials
requested, incident to reasonable, substantial and material reasons move to quash any
Notice of Deposition upon a demonstration of substantial burdensomeness or other just
cause shown.
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Because of the complexity of the alleged frauds, Plaintiffs expect to detail
the preparation of a proposed draft of the Preliminary Injunction is respectfully reserved
until after the evidentiary heating on the Injunction itself, or as combined with a trial on
the merits.
VI. ADDITIONS TO CONCLUSIONS BASED UPON

NEWLY DISCOVERED EVIDENCE AND
CONCLUSIONS TO BE DRAWN THEREFROM
Exhibit #6 is attached. That information purports to show that the Board
received and responded to requests for official election Ballots. The responses contained
an official ballot with the requestor’s name inserted, ready for filing. Exhibit #6 was
apparently prepared by Board employees, and contains data which appears to admit that
call-in or on-line requests for a Ballot, later to be used by the receiver in the form
furnished by the Board would be eligible for voting, with the voters name already inserted
on the ballot. Presumably some of these would be placed into a drop box. Whether a
correct registered voter or not may have thereby received the Ballot and later present it is
not traceable and allows for uttering of a ballot by Department of Election employees.
This is because there is no control or chain of custody for the ballot itself. This also
explains the source of the hundreds of thousands of ballots known to be false in the 2020
election.
And now it is happening again. Whether or not the requester, he or she, is
an actual qualified voter under the laws of the State is also wide open and unverifiable.
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Once this occurs, no amount of observation or after the vote auditing can
correct the not just flawed results, but an entirely complete and effective corruption of the
election process, system and results. For this reason, a declaratory judgement is necessary
to recapture the integrity of the entire election process in Maryland. And only then can a
secure and valid count be made. This injunctive relief is vital to the survival of every
citizen’s power of the vote, and indeed, our entire system of government.
At the hearing on a preliminary injunction, after a short period of obtaining
Trial Proof if so demonstrated these verified allegations, the system may be, under the
guidance of constitutional constraints entirely correctable. However, if a correction in
system methodology and control does not occur, the absolute corruption of this process
succeeds and our way of life is doomed.
The fabrication of Ballots and lack of security are demonstrated by this
evidence, from the time of the ballot issuance and printing at the very start of the election
process proceeding in each step downstream in the election collection and summarization
process. This entire process creates irreparable harm, the denial of an effective vote by
unsuspecting citizens. Moreover, the greatest part of each aspect of the conspiratorial and
fraudulent conduct has been admitted by the perpetrators. The only real question
remaining is whether or not the Court, here the protectors of citizen’s constitutional rights
will act, or merely allow this disaster to our Republic to unfold to extinction, along with
its honest and law-abiding citizens.
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That process, now firmly imbedded in the election system, in Maryland and
elsewhere, includes the Fabrication of Ballots, Drop Boxes Unattended, and without the
Purported Security of any effective Camera Surveillance and follow up when fraud or
errors occur. During this Entire Process there is no Fair Basis for the Existence of a
Registered Voter. And now, the corrupted Board, allows any person requesting a Ballot,
for any other person, to have their way with the entire State and later, National Election.
Exhibit #6, therefore and the preceding Exhibit #7 should be taken as
verified evidence demonstrating without a shadow of a doubt that the system is wide
open to fraud, malfeasance and error it is self evident that no verifiable or reliable system
can possibly produce reliable and accurate results. This situation is completely
intolerable and unacceptable and must be corrected forthwith for all of the foregoing
reasons.
These records demonstrate that a Mere Request for a Ballot over the
Internet is Enough to receive the right to vote. This shocking fact, standing alone, is
sufficient to corrupt and disqualify integrity of the entire system. And also to demonstrate
the element of immediate and irreparable harm by violating the Constitutional rights of
every citizen in every state and county where applicable. And this false corrupted
security picture is piled upon the also recently discovered Use of a Corrupted ERIC
System to “Harvest” Known Departed or Deceased parties Gleaned from the MVA and
automated residency motor vehicle and other automated citizen records across the United
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States of America.
And now, as new evidence comes the astounding Nation-wide existence of
an intentionally created and usable slush fund of harvested ballots, usable at will from
foreign sources manipulating our election counts, by insertion of these fake vote,
wherever and to whatever extent needed for the perpetrators to falsely prevail. This
fraudulent result simply cannot be allowed to stand.
VII. CLAIMS FOR RELIEF,

LEGAL, EQUITABLE, MANDAMUS AND PUNITIVE:
-----------------------
(AGAINST MARYLAND FOR THE FAILURE TO PROTECT THE

CITIZENRY’S INDIVIDUAL AND COLLECTIVE RIGHTS, CRIMINAL
FORFEITURE’S AGAINST ALL CORPORATE AND INDIVIDUALS WHO
PERFORMED THE FRAUDS OR AIDED AND ABETTED SAME. BOTH
ACTUAL, LEGAL, EQUITABLE AND PUNITIVE):
A. A Declaratory Judgment of a Constitutional And/or Common Law Fraud Is
Hereby Requested from this Court or a Jury, if Applicable.
B. A Jury Trial Is Demanded for All Claims for Which a Jury Demand Is Allowed
by Law, and to Determine the Relief, Both Criminal, Civil, Punitive and Exemplary to Be
Assessed by this Court.
C. These fake and corrupted systems are in use throughout the entire Country.
They must be scrapped and never used again. Replacement should be as soon as possible,
with equitable and truthful systems governed by audited and controlled results free from
-35-
JA173
political taint and controlled and audited by a non-political arm of the Federal Judicial
System.
D. The use of these demonstrated to be dishonest systems and measures, are no
less than Treason, and anathema to our way of life. and, plaintiffs are certain that the
Court, and any jury convened in this State, will agree. Criminal and civil penalties should
be assessed with criminal fines and sentences commensurate with the magnitude of the
wrongs committed, but not less than existing criminal sentencing guidelines, such that no
repetition of this situation will ever again occur in this Country.
VIII. JURY DEMAND
Plaintiffs hereby demand a Jury Trial for all claims, damages and issues, for
which a jury trial is available for any issue of fact or law. Further, Plaintiffs demand a
Grand Jury be convened to investigate and act upon all matters for which the Constitution
of the United States makes such relief available.
IX. DEMAND FOR INJUNCTIVE AND REMEDIAL RELIEF
Plaintiffs demand equitable, legal, remedial and injunctive relief designed
to make all plaintiffs whole and legal relief to punish the wrongdoers, should any RICO
Entity, or a group of them be found to exist by the Court or, if allowable under law, the
Jury, whether civil or criminal. Plaintiffs pray, that the Honorable Court consider the
irreparable harm to the perceived integrity of our Great Nation, and its proud citizens, and
-36-
JA174
their progeny, who will continue to suffer such irreparable harm in the event this Court
fails in its perceived duty by these plaintiffs, and the host of others, born and unborn, who
shall suffer egregious harm if the wrongs merely outlined in this complaint are allowed to
persist and prevail. These facts utterly destroy the rights to freedom and equality of
power flowing from the creator which are the now shaken foundations of our great
Constitution.
X. VERIFICATION
I, Lewis T. Porter, am a named plaintiff in this case, and I am over the age
of 18, a Citizen of the State of Maryland, and otherwise qualified to testify before this
Court; I hereby swear under the penalties of perjury that all of the facts appearing herein,
and as attached to this Complaint, including Exhibits 1-7, but excluding the statistical
materials pertaining to the Expert Population and Data Base testimony, of which I have
no expert knowledge, and Requests for Injunctive relief are true and correct as stated and
each evidentiary attachment hereto is a genuine document to the best of my current,

Lewis T. Porter, June 28, 2022, as Amended July 18, 2022, and August 19, 2022
-37-
JA175
Walter T. Charlton, Electronic Signature, June 28, 2022, And as Amended, July18,
2022, And July 25, and August 19th, 2022,.

DC Bar # 186940,
United States District Court Bar, District of Maryland # 07638
-38-
JA176
INDEX OF ATTACHMENTS
Attachment A- Draft Temporary Restraining Orders (Originals- (Denied)

Included for Information Purposes Only...................................................
Motion for a Preliminary Injunction and Permanent Injunctive

Relief , Deferred Pending Scheduling and Initial Discovery....................
Renewal Request for Emergency TRO, Regarding September 3, 2022

Destruction Deadline for Election Materials and Data Bases................
Exhibit # 1 Grants to 21 Maryland Counties and Baltimore City, ... $ 6, 245,797.
Exhibit # 2 .1 Declaration of Eye-Witness to Ballot Stuffing, Lois Ann Gibson....
Exhibit # 2.2 and 2.3 Declaration of Two Witnesses, ...........................................
Exhibit # 3 Declaration of Newly Non-Resident, Kurt Kolb, regarding

Automated Voter Harvesting, ..............................................
Exhibit # 4 Frederick and Carroll County Grant Contracts, with Terms ...........
Exhibit # 5 Howard County, List of Payments of Exact Money Dollars

Received in Grants from Chicago (Purported 501(c)(3) Charity,
Center for :Tech and Civic Life, (CTCL) $ 688,226, distributed
in Same Amount, $ 688,226, to List of about 730 Named Persons
also Furnished from disbursement Records of Howard County .....
Exhibit # 6 Mail-In Ballot Requests by County, July 17, 2022, 508,024..........
Exhibit # 7 Mail-in Ballot Requests by County, November 3, 2020, 1,688,480...
Exhibit # 8 Verification of Harford County Canvas of 2020, Presidential

General Election, through February 2022...........................
Exhibit # 9, Verification Report, Ballot Images and Fake Surveillance

Camera Report, May 26, 2022............................................
Exhibit # 10 Curriculum Vitae, Dr. Douglas G. Frank.
-39-
JA177
CERTIFICATE OF SERVICE
THESE MATERIALS, BOTH ORIGINAL COMPLAINT AND

MOTIONS FOR INJUNCTIVE RELIEF, BOTH VERSIONS, AND THE
COURT’S ORDER OF JULY 6, 2022. AND THE RULE 59(e) MOTION AND
ORDER, denying that Motion, WERE DELIVERED BY AGAIN TO ALL
DEFENDANTS, EXCEPT CTCL, WHICH WAS MAILED PRIORITY MAIL,
RETURN RECEIPT REQUESTED. ALL STATE AGENCIES WERE SERVED
BY THE APPROVED ELECTRONIC MEANS, for each State agency, ON OR
ABOUT AUGUST 24th , 2022.
Emails to: Brent.Bolea1@Maryland.gov; Michael.Friedman@Maryland.gov;

OAG@OAG.State.Md.US
THE FIRST AMENDED COMPLAINT, AND THE IMBEDDED

RENEWAL OF THE MOTION FOR A TRO, WERE DELIVERED BY
ELECTRONIC EMAIL, ON AUGUST 19, 2022.
Natalie Melendez Abbas.
Natalie Abbas, Paralegal, August 19, 2022.
-40-
JA178
EXHIBIT 1


For Herself and all other similarly situated, )
et al )
)
V ) Case No.
State of Maryland, and 21 Counties Therein )
et al )
________________________________________________)
Alleged Schedule of Contractual Cash Grants from

Center for Tech and Civil Life (CTCL), 2020 Election Cycle
Paid to and Received By Maryland Counties, Allegedly
1
Paid and/or Used For Unlawful And/or Politically Corrupt Purposes
County or City: Amount of Grant
Allegheny County $ 41,475
Anne Arundel County 330,076
Baltimore City 1,147,073
Baltimore County 1,044,824
Calvert County 47,492
Caroline County 19,108
Carroll County 76,536
Cecil County 45,975
1
Source of Payments: www.capitalresearch.org, public information available, Paid by a
purportedly tax exempt IRS Code § 501(c)(3) non-profit politically neutral foundation (CTCL) .
JA179
Charles County 129,030
Dorchester County 22,352
Frederick County 121,975
Garrett County 9,478
Harford County 181,537
Howard County 688,226
Kent County Board of Elections 12,696
Montgomery County 801,913
Prince George's County 1,325,384
Queen Anne's County 22,317
Talbot County 20,650
Washington County 90,512
Wicomico County 67,168
Total All Grants, Maryland $ 6,245,797
Somerset, St Mary’s and Worcester Counties did not participate in this program.
JA180
Declaration of Lois Ann Gibson

June 16, 2022
I here-by declare under the penalties of perjury that my name is Lois

Ann Gibson and am over 18 years of age, and qualified to vote. All of
the information following is true and correct based on my best
recollection.
I trained to become an election judge for the 2020 election, however I

was unable to serve as an election judge due to health issues. This is to
affirm that on or around November 2, 2020, I Lois Ann Gibson at
approximately 9am, went to the Frederick Board of Elections Office at
340A Montevue Lane, Frederick, Maryland to return the training
manuals. This location had a Ballot Drop Box out front at the end of the
building. I Witnessed a man hurriedly stuffing what appeared to be a
large number of ballots at least several dozen from a canvas bag he was
carrying to the ballot box.
I asked this person who he was and seemed startled but said he was
from the Post Office and he quickly went back to the vehicle and left. I
was concerned because he did not have any official uniform, badge, or
vehicle and was very anxious. This incident occurred at or before 9am.
Name: Lois Ann Gibson

Phone: 732-239-0542
Address: 102 Mercer court
Unit 22-2A
Frederick, Maryland
Zip Code: 21701
JA181
May 2, 2022
Frederick County Board of Elections

340A Montevue Lane
Frederick, MD 21701
Receipt for delivery of 5 letters to:
1. Anthony Gutierrez
2. Mary Lou Green
3. Barbara Wagner
4. Shirley McDonald
5. Clifton Mowell
Signature
Print Name - - - - - '~--'--_._,:rtt_· _·';y

_ ;L.tJ ..___ h_~- - - - - -
~ __ Date
JA182
May 17, 2022
~ (2_~c.c'-Qfeo / QeJa.cJed Drive, Frederick,

Md.21702
Frederick County.
On November 3, 2020 I witnessed at the Thomas Johnson High

School open for voting, standing in line with my husband and
right by the ballot box, a man pulled up at the curb and got out
of his vehicle and in his hand was a stack of ballots and put them
in the ballot box. (About a 2 Yz inch stack). I remember this
because we were standing by the box and had to move out of the
way for him to get to the box. I thought that was odd that he had
a great deal of ballots and I commented to my husband standing
beside me that looked very odd to me, he agreed. I never saw
that before at any other voting election where I voted at.
Once inside I thought it was so odd also that people were having
trouble getting their ballots to process into the ballot machine.
Also, I wanted to state that my husband, my daughter and
myself also received 3 ballots each per person through the mail
for the 2020 election.
I am over 18 years of age and I solemnly affirm under the

penalties of perjury and upon personal knowledge that the
contents of the foregoing statement is true, to the best of my
memory recall of that day.
(
- Dated $- I '1- 20~~
JA183
State: )J-...C\. y~(<> fJ d

JA184
EXHIBIT 2.3, DECLARATION OF Jean-Elizabeth-Jenkins-Ellis
I hearby declare under the penalties of perjury that I am over 18 years of age and
the following stated facts are true to the best of my knowledge and belief.
My name is Jean-Elizabeth; .Jenkins-Ellis:. I started working for the Maryland

Election Board in April of 2010. I was hired as a temp employee to test voting
machines. I was hired to work in Washington County, Frederick County and
Westminster County area. I worked early elections and then the primary elections
testing voting machines and then started testing Poll books. I then worked
different precincts on voting day to make sure the machines operated correctly
and fixed any problems that may arise. I worked every presidential election and
one or two government until the 2020 election. The thing that stood out to me
about the testing procedures in 2020 was the use of the router. We have never
tested using the internet. When ever I would work as a greeter at early voting one
of my duties was to let voters know that they had to power off their cell phones.
One of the questions I was always asked was “do our cell phones interfere with
the internet?” I was always told that we did not have internet and that it was a
law in Maryland. In fact voters got so belligerent about the subject that Sherman
Harvey look up the law and rap and had it typed out so that I could give it to voters
that were questioning
On November 3, 2020 I was assigned to 3 precincts in Frederick County to be their

person to call for voting machine and poll book tech support. While at one of the
precincts the poll books started acting up, they had an hourglass just spinning and
nothing that I knew to do worked to reset them so I had to turn them off and
restart them. That was something I’ve never had to do before but it seemed to
work. I made out a report which is something we always did and then handed our
reports in at the end of the day. At the end of the day I handed in my report at the
Frederick office to Barbara but she just tore it up saying that it was nothing and
not anything to worry about.
JA185
DECLARATION OF KURTIS S. KOLB

411 Walnut St #17793
Green Cove Springs, FL 32043
June 23, 2022
I declare under the penalties of perjury that I am over 18 years of age and the facts stated following are true and
correct to the best of my present knowledge, information, and belief.
RE: Voter fraud via Maryland Motor Vehicle Administration records. Carroll County MD Sheriffs Office event
#5221710030.
The following are facts:
1. On Jun 16, 2022 I discovered that my voter registration had been changed, without my knowledge or
consent, from Clay County, FL to Carroll County, MO.
2. Upon discovery I contacted both election offices.
3. Clay County, FL informed me they removed my registration due to notice from The Electronic Registration
Information Center (ERIC) that I had registered to vote in another state.
4. The carroll County, MD office of the Maryland Board or Elections informed me that the attached document
(document source: Maryland Motor Vehicle Administration, or "MVA") had been filed in my name.
5. The attached document ls forged. The signature on the forged document is the signature I used for my
Maryland Driver's License that I signed on December 19, 2016, with a slight digital distortion, apparently
from the copying process.
The following Is my considered opinion, as to the process and meaning of these abnormal events, based entirely on
these happenings, This' process Is a considered methodology to unlawfully obtain, (1) my personal identity information,
and (2) apparently, my voting credentials in Maryland for use other than through my legal right to vote (kno11m as Vote
Harvesting), (3) and Is apparently being done by individuals with access to either the Maryland MVA and/or Maryland
Board of Elections records, or a conspiracy by 2 or more individuals from both agencies along with individuals within
USPS. (4) Both Florida and Maryland election registrations go through the ERIC system and both states receive
notification of any changes. These notifications trigger simple notices to be sent via USPS to a victim's prior MD mailing
address where the trail of notifications concludes and may or may not reach the intended recipierit(s).
JA186
Details:
There are parties l"EFPs» - Election Fraud Personnel) within the Maryland Board of Elections (BoE), Maryland Motor
Vehicle Administration (MVA), and possibly United States Postal Service (USPS) that are actively engaging in identity
theft for the sole purpose of voter fraud. In my case there was notice received via the ERIC (Electronic Registration
Information Center) by both MD and FL BoEs as well as Maryland MVA receiving electronic notice of my change of
residency and FL driver's license. This information was obtained by an EFP member at one or more of these offices and
passed along to another EFP at MVA, The MVA EFP supplied my Personally Identifiable Information (PII) to facilitate
submission of a new, fraudulent Maryland voter application in my name. This, via ERIC, triggered MD BoE to Issue a
new voter registration card to my former Maryland address. What the perpetrators of this crime did not account for is,
even though I am no longer a resident of Maryland, I still have an active mailing address in Maryland. This mailing
address was not a residential forwarding address where an EFP within USPS could intercept the fraudulent notices and
voter registration card and thus, the items were delivered to a PMB (Private Mail Box) to which the EFP had no access.
It is my belief that this process repeats itself with a great number of former Maryland registered voters that move out of
state and either obtain a drivers license in another state and/or register to vote in another state. This is likely affecting
.a significant number of Maryland voter registrations. If my above theory is not correct, I would like to know how my PII
went from MVA records to a voter registration application (see attached) without my request. It would be a simple task
to use this personal information as a source of virtually untraceable votes by dishonest persons. I have notified a
number of a horitles of these events with absolutely no action to date.
'it~ June 23, 2022
JA187
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convieted! ilf a.(cliOny, or if t./have. 1. fonrc comp:let-ed ~nirt1,g .fll r..-:oor&-ordcrod s.t";a~cm.· c of impri1'j.,om .'l;'.:Ht.
~f'hc ~1Qfurm.;11,i~11111ili1 this ~1p:ipX1c.::.Jtim1 •s true to me.be.."il of my kn~}lli.'tirlcdge,. in.ronna1i m1 . i11ru:J bcli:el.
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_.;
JA188
September 25, 2020
Frederick County, Maryland
County Board of Elections
340A Montevue Lane
Frederick, MD 21702
Dear Stuart Harvey,
I am pleased to inform you that based on and in reliance upon the information and materials
provided by Frederick County, the Center for Tech and Civic Life ("CTCL"), a nonprofit
organization tax-exempt under Internal Revenue Code ("IRC") section 501(c)(3), has decided to
award a grant to support the work of Frederick County ("Grantee").
The following is a description of the grant:
AMOUNT OF GRANT: $121,975.00 USD
PURPOSE: The grant funds must be used exclusively for the public purpose of planning and
operationalizing safe and secure election administration in Frederick County in 2020
("Purpose") .
Before CTCL transmits these funds to Grantee, CTCL requires that Grantee review and sign this
agreement ("Grant Agreement") and agree to use the grant funds in compliance with the Grant
Agreement and with United States tax laws and the laws and regulations of your state and
jurisdiction ("Applicable Laws") . Specifically, by signing this letter Grantee certifies and agrees
to the following:
1. Grantee is a local government unit or political subdivision within the meaning of IRC
section 170(c)(l).
2. This grant shall be used only for the Purpose described above, and for no other
purposes.
JA189
3. ,Grantee has indicated that the amou'nt of ttie grant shall be expended on the
following_s_pecific election administration needs: P.oJI worker: r:ecr:uitment funds,
liazard pay, and7or training expenses, Pol ing place rental and cleaning ex enses for
earl voting or Election Day, Vote-by-mailLAbsentee voti g eguigment or supplies,
ancf'Elecflon ac:lministration equipment. Grantee may allocate grant funas among
those neeqs, or: to other: RJ.Jblic P.Ur oses lis ed in the rant a licatiori, itno.ut
further: notice to o permission of CTCL.
4. Grantee shall not use any part of this grant to make a grant to another organization,
except in the case where the organization is a local government unit or political
subdivision within the meaning of IRC section 170(c)(l) or a nonprofit organization
tax-exempt under IRC section 501(c)(3), and the subgrant is intended to accomplish
the Purpose of this grant. Grantee shall take reasonable steps to ensure that any such
subgrant is used in a manner consistent with the terms and conditions of this Grant
Agreement, including requiring that subgrantee agrees in writing to comply with the
terms and conditions of this Grant Agreement.
5. The grant project period of June 15, 2020 through December 31, 2020 represents the
dates between which covered costs may be applied to the grant. The Grantee shall
expend the amount of this grant for the Purpose by December 31, 2020.
6. Grantee is authorized to receive this grant from CTCL and certifies that (a) the receipt
of these grant funds does not violate any Applicable Laws, and (b) Grantee has taken
all required, reasonable and necessary steps to receive, accept and expend the grant
in accordance with the Purpose and Applicable Law.
7. The Grantee shall produce a brief report explaining and documenting how grant funds
have been expended in support of the activities described in paragraph 3. This report
shall be sent to CTCL no later than January 31, 2021 in a format approved by CTCL and
shall include with the report a signed certification by Grantee that it has complied
with all terms and conditions of this Grant Agreement.
8. This grant may not supplant previously appropriated funds. The Grantee shall not
reduce the budget of the County Board of Elections ("the Election Department") or
fail to appropriate or provide previously budgeted funds to the Election Department
for the term of this grant. Any amount supplanted, reduced or not provided in
contravention of this paragraph shall be repaid to CTCL up to the total amount of this
grant.
9. CTCL may discontinue, modify, withhold part of, or ask for the return all or part of the
grant funds if it determines, in its sole judgment, that (a) any of the above terms and
conditions of this grant have not been met, or (b) CTCL is required to do so to comply
with applicable laws or regulations.
dates between which covered costs for the Purpose may be applied to the grant.
CENTER FOR TECH & CIVIC LIFE

233 N. MICHIGAN AVE., SUITE 1800
CH ICAGO, IL 60601
HELLO@TECHANDCIVICLIFE.ORG
PAGE 2
JA190
Your acceptance of and agreement to these terms and conditions and this Grant Agreement is
indicated by your signature below on behalf of Grantee. Please have an authorized
representative of Grantee sign below, and return a scanned copy of this letter to us by email
at grants@tech andcivicl ife. org.
On behalf of CTCL, I extend my best wishes in your work.
Sincerely,
{IW\(1, m,J~O\,
Tiana Epps Johnson
Executive Director
Center for Tech and Civic Life
GRANTEE
By:~
Title: ~otJ u)ra.«_,oa_
Date: q f"J-~ )?P>-0

-;-----7~--
CENTER FOR TECH & CIVIC LIFE

233 N. MICHIGAN AVE., SU ITE 1800
CHICAGO, IL 60601
PAGE 3
JA191
September 23, 2020
Carroll County, Maryland
Board of County Commissioners
Carroll County Office Building

225 North Center Street
Westminster, Maryland 21157
Dear Steven Wantz,
I am pleased to inform you that based on and in reliance upon the information and materials
provided by Carroll County, the Center for Tech and Civic Life ("CTCL"), a nonprofit organization
tax-exempt under Internal Revenue Code ("IRC") section 501(c)(3), has decided to award a
grant to support the work of Carroll County ("Grantee").
The following is a description of the grant:
AMOUNT OF GRANT: $76,536.00 USO
PURPOSE: The grant funds must be used exclusively for the public purpose of planning and
operationalizing safe and secure election administration in Carroll County in 2020 ("Purpose").
Before CTCL transmits these funds to Grantee, CTCL requires that Grantee review and sign this
agreement ("Grant Agreement") and agree to use the grant funds in compliance with the Grant
Agreement and with United States tax laws and the laws and regulations of your state and
jurisdiction ("Applicable Laws"). Specifically, by signing this letter Grantee certifies and agrees
to the following:
1. Grantee is a local government unit or political subdivision within the meaning of IRC
section 170( c)( 1).
JA192
2. This grant shall be used only for the Purpose described above, and for no other
purposes.
3. Grantee has indicated that the amount of the grant shall be expended on the
following specific election administration needs: Ballot drop boxes, Personal
protective equipment {PPE) for staff, poll workers, or voters, Poll worker recruitment
funds, hazard pay, and/or training expenses, Temporary staffing, Vote-by-
mail/Absentee voting equipment or supplies, and Election administration equipment.
Grantee may allocate grant funds among those needs, or to other public purposes
listed in the grant application, without further notice to or permission of CTCL.
4. Grantee shall not use any part of this grant to make a grant to another organization,
except in the case where the organization is a local government unit or political
subdivision within the meaning of IRC section 170(c)(l) or a nonprofit organization
tax-exempt under IRC section 501(c)(3}, and the subgrant is intended to accomplish
the Purpose of this grant. Grantee shall take reasonable steps to ensure that any such
subgrant is used in a manner consistent with the terms and conditions of this Grant
Agreement, including requiring that subgrantee agrees in writing to comply with the
terms and conditions of this Grant Agreement.
dates between which covered costs may be applied to the grant. The Grantee shall
expend the amount of this grant for the Purpose by December 31, 2020.
6. Grantee is authorized to receive this grant from CTC~ and certifies that (a) the receipt
of these grant funds does not violate any Applicable Laws, and (b) Grantee has taken
all required, reasonable and necessary steps to receive, accept and expend the grant
in accordance with the Purpose and Applicable Law.
7. The Grantee shall produce a brief report explaining and documenting how grant funds
have been expended in support of the activities described in paragraph 3. This report
shall be sent to CTCL no later than January 31, 2021 in a format approved by CTCL and
shall include with the report a signed certification by Grantee that it has complied
with all terms and conditions of this Grant Agreement.
8. This grant may not supplant previously appropriated funds. The Grantee shall not
reduce the budget of the County Board of Elections ("the Election Department") or
fail to appropriate or provide previously budgeted funds to the Election Department
for the term of this grant. Any amount supplanted, reduced or not provided in
contravention of this paragraph shall be repaid to CTCL up to the total amount of this
grant.
9. CTCL may discontinue, modify, withhold part of, or ask for the return all or part of the
grant funds if it determines, in its sole judgment, that (a) any of the above terms and
conditions of this grant have not been met, or (b) CTCL is required to do so to comply
with applicable laws or regulations.
CENTEH FOH TECH & CIVIC L!FE

233 N, MICHIGAN AVE., sum 1800
CHICAGO, ll. 60601
PAGE 2
JA193
dates between which covered costs for the Purpose may be applied to the grant.
Your acceptance of and agreement to these terms and conditions and this Grant Agreement is
indicated by your signature below on behalf of Grantee. Please have an authorized
representative of Grantee sign below, and return a scanned copy of this letter to us by email
at grants@techandciviclife.org.
On behalf of CTCL, I extend my best wishes in your work.
Sincerely,
Tiana Epps Johnson
Executive Director
Center for Tech and Civic Life
GRANTEE
Title: President
Date : 10/1/20
CENTER FOR TECH & CIVIC Liff

233 N. MICHIGAN AVE., SUI TE 1800
CHICAGO, IL 60601
PAGE 3
JA194

--;-up -!Yl,:? 7/J A'... e u./ww,, 7J10 ~o ... ~I? wltTc A,,. J11 co
SAP JV Document Posting Date of Original SAP
(Reclass to Grant 4- Document
Original SAP Document 218) Name (Date of Expenses) Amount
102100782 102186253 HOLTON, JAMES 9/11/2020 $ 2,940.19
102100782 102186253 CHEN, SALLY 9/11/2020 $ 2,940.19
102100782 102186253 HOLTON, JONATHAN 9/11/2020 $ 2,940.19
102100782 102186253 SINCLAIR, MORGAN 9/11/2020 $ 1,286.73
102106182 102186253 HOLTON, JAMES 9/25/2020 $ 2,986.21
102106182 102186253 CHEN, SALLY 9/25/2020 $ 2,986.21
102106182 102186253 HOLTON, JONATHAN 9/25/2020 $ 2,986.21
102106182 102186253 MADDEN, VERNETTA 9/25/2020 $ 575.07
102106182 102186253 SINCLAIR, MORGAN 9/25/2020 $ 1,522.31
102106182 102186253 MULLINIX, PATRICK 9/25/2020 $ 1,778.38
102112380 102186253 HOLTON, JAMES 10/9/2020 $ 3,177.97
102112380 102186253 CHEN, SALLY 10/9/2020 $ 3,177.97
102112380 102186253 HOLTON, JONATHAN 10/9/2020 $ 3,177.97
102112380 102186253 VENERABLE, DEVEON 10/9/2020 $ 1,189.87
102112380 102186253 EVANS, MATTHEW 10/9/2020 $ 418.22
102112380 102186253 COUNCIL, ALEXIS 10/9/2020 $ 421.45
102112380 102186253 ROJUGBOKAN, ELIZABETH 10/9/2020 $ 497.75
102112380 102186253 DEDJOE, DARLENE 10/9/2020 $ 254.32
102112380 102186253 WOOTEN, DANIELLE 10/9/2020 $ 225.26
102112380 102186253 SINCLAIR, MORGAN 10/9/2020 $ 1,511.41
102112380 102186253 WILLIAMS, TATIANA 10/9/2020 $ 403.29
102117355 102186253 HOLTON, JAMES 10/23/2020 $ 2,587.37
102117355 102186253 CHEN, SALLY 10/23/2020 $ 2,587.37
102117355 102186253 HOLTON, JONATHAN 10/23/2020 $ 2,587.37
102117355 102186253 MADDEN, VERNETTA 10/23/2020 $ 1,086.33
102117355 102186253 EVANS, MATTHEW 10/23/2020 $ 911.80
102117355 102186253 COMEGYS, CATHERINE 10/23/2020 $ 2,132.69
102117355 102186253 COUNCIL, ALEXIS 10/23/2020 $ 1,046.36
102117355 102186253 ROJUGBOKAN, ELIZABETH 10/23/2020 $ 555.88
102117355 102186253 DEDJOE, DARLENE 10/23/2020 $ 606.75
102117355 102186253 WOOTEN, DANIELLE 10/23/2020 $ 964.61
102117355 102186253 SCALZO, LINDA 10/23/2020 $ 425.09
102117355 102186253 SINCLAIR, MORGAN 10/23/2020 $ 1,140.82
102117355 102186253 MULLINIX, PATRICK 10/23/2020 $ 1,256.54
102117355 102186253 WILLIAMS, TATIANA 10/23/2020 $ 1,157.17
102132138 102186253 MADDEN, VERNETTA 12/4/2020 $ 1,255.26
102132138 102186253 EVANS, MATTHEW 12/4/2020 $ 866.58
102132138 102186253 COMEGYS, CATHERINE 12/4/2020 $ 1,462.36
102132138 102186253 KEENER, DOROTHY 12/4/2020 $ 406.92
102132138 102186253 SCALZO, LINDA 12/4/2020 $ 94.46
102132138 102186253 WILLIAMS, TATIANA 12/4/2020 $ 443.25
1900218384 102141728 AMINACHAL 12/16/2020 $ 1,059.00
1900218385 102141728 WHITE ADAM 12/16/2020 $ 1,505.00
1900218386 102141728 LEEADAORA 12/16/2020 $ 620.00
1900218387 102141728 ADETUNJI ADEDAYO 12/16/2020 $ 174.00
1900218388 102141728 SHUAIB ADESINA 12/16/2020 $ 1,210.00
1900218389 102141728 OLUWABUYI ADEWUNMI 12/16/2020 $ 620.00
1900218390 102141728 INGALLS ALAN 12/16/2020 $ 1,210.00
1900218391 102141728 PROG ALEXANDER 12/16/2020 $ 1,430.00
1900218392 102141728 RIBERO ALEXANDRA 12/16/2020 $ 620.00
1900218393 102141728 MANSARAY ALHASSAN 12/16/2020 $ 1,210.00
1900218394 102141728 STACY ALISA 12/16/2020 $ 1,210.00
1900218395 102141728 HAMILTON ALLISON 12/16/2020 $ 380.00
1900218396 102141728 BETZ AMANDA 12/16/2020 $ 730.00
1900218397 102141728 RAID AMANDA 12/16/2020 $ 72.00
1900218398 102141728 SON AMANDA 12/16/2020 $ 686.00
1900218399 102141728 COOPER AMIRA 12/16/2020 $ 915.00
1900218400 102141728 SMITH AMY 12/16/2020 $ 325.00
1900218401 102141728 BRAXTON ANA 12/16/2020 $ 1,505.00
1900218402 102141728 BRITTON ANDREA 12/16/2020 $ 1,276.00
JA195
1900218403 102141728 LOTZ ANDREW 12/16/2020 $ 620.00

1900218404 102141728 LANDERS ANGELA 12/16/2020 $ 730.00
1900218405 102141728 GBOFFUEH ANITA 12/16/2020 $ 620.00
1900218406 102141728 WOLF ANITA 12/16/2020 $ 620.00
1900218407 102141728 BOWEN ANN 12/16/2020 $ 787.11
1900218408 102141728 WORLEY ANN 12/16/2020 $ 1,047.00
1900218409 102141728 KATZ ANNA 12/16/2020 $ 325.00
1900218410 102141728 CONKLIN ANNE 12/16/2020 $ 620.00
1900218411 102141728 BROOKER-GROGAN ANNITTE 12/16/2020 $ 915 .00
1900218412 102141728 FOSTER ANNIE 12/16/2020 $ 325.00
1900218413 102141728 BOND ANTHONE 12/16/2020 $ 620.00
1900218414 102141728 BURKE ANTHONY 12/16/2020 $ 620.00
1900218415 102141728 JONES ANTHONY 12/16/2020 $ 380.00
1900218416 102141728 BROWN ANTOINITTE 12/16/2020 $ 915.00
1900218417 102141728 PARHAM ANTOINETIE 12/16/2020 $ 620.00
1900218418 102141728 ALOU5YES AN USHA 12/16/2020 $ 325.00
1900218419 102141728 CROPPER APRIL 12/16/2020 $ 620.00
1900218420 102141728 NORTH APRIL 12/16/2020 $ 1,210.00
1900218421 102141728 YOUSUF ARJUMAND 12/16/2020 $ 620.00
1900218422 102141728 BLUME ARLENE 12/16/2020 $ 915.00
1900218423 102141728 WYREARNITTIA 12/16/2020 $ 915.00
1900218424 102141728 ZIA ASAD 12/16/2020 $ 1,095.00
1900218425 102141728 TRIPLED ASHLEY 12/16/2020 $ 620.00
1900218426 102141728 MAJIDASRA 12/16/2020 $ 1,505.00
1900218427 102141728 DUNN AUBREY 12/16/2020 $ 620.00
1900218428 102141728 AVENT AUSTIN 12/16/2020 $ 620.00
1900218429 102141728 AZIZAYMAN 12/16/2020 $ 1,800.00
1900218430 102141728 COHEN BARBARA 12/16/2020 $ 800.00
1900218431 102141728 GOODRIDGE BARBARA 12/16/2020 $ 1,210.00
1900218432 102141728 KELLER BARBARA 12/16/2020 $ 1,049.00
1900218433 102141728 MANSFIELD BARBARA 12/16/2020 $ 1,001.00
1900218434 102141728 MORTON BARBARA 12/16/2020 $ 620.00
1900218435 102141728 RIKARD BARBARA 12/16/2020 $ 1,800.00
1900218436 102141728 KING BARID 12/16/2020 $ 1,210.00
1900218437 102141728 BOWERS BARRY 12/16/2020 $ 957.00
1900218438 102141728 VOHRA BATOOL 12/16/2020 $ 325.00
1900218439 102141728 OLUWABUYI BEATRICE 12/16/2020 $ 620.00
1900218440 102141728 GREEN BELINDA 12/16/2020 $ 1,194.00
1900218441 102141728 YU BERNADETIE 12/16/2020 $ 1,733.00
1900218442 102141728 FARNUM BERTHA 12/16/2020 $ 620.00
1900218443 102141728 HUFNAGEL BEfH 12/16/2020 $ 1,210.00
1900218444 102141728 BEALL BEfHANY 12/16/2020 $ 1,210.00
1900218445 102141728 KHOKHAR BILAL 12/16/2020 $ 1,210.00
1900218446 102141728 FELIX BISHOP 12/16/2020 $ 842.00
1900218447 102141728 EVANS BLANCHE 12/16/2020 $ 806.00
1900218448 102141728 AGNEW BONNIE 12/16/2020 $ 1,059.00
1900218449 102141728 HERRIOTT BONNIE 12/16/2020 $ 325.00
1900218450 102141728 WAITSMAN BONNIE 12/16/2020 $ 1,276.00
1900218451 102141728 LIEBERMAN BRAD 12/16/2020 $ 325.00
1900218452 102141728 BONDHUS BRADLEY 12/16/2020 $ 620.00
1900218453 102141728 LANCE BRADLEY 12/16/2020 $ 600.00
1900218454 102141728 GRIMES BRANDI 12/16/2020 $ 600.00
1900218455 102141728 HAGEN BRIAN 12/16/2020 $ 620.00
1900218456 102141728 SHARKEY BRIAN 12/16/2020 $ 620.00
1900218457 102141728 GRAY BRIDGITTE 12/16/2020 $ 325.00
1900218458 102141728 PRESS BRUCE 12/16/2020 $ 620.00
1900218459 102141728 SEMMEL CAITLYN 12/16/2020 $ 380.00
1900218460 102141728 TOBEY CARA 12/16/2020 $ 695.00
1900218461 102141728 WICHERS CARALYN 12/16/2020 $ 620.00
1900218462 102141728 FLECK CARL 12/16/2020 $ 1,080.00
1900218463 102141728 KOEHLER CARL 12/16/2020 $ 366.00
1900218464 102141728 OTUBU CARLA 12/16/2020 $ 325.00
1900218465 102141728 BOLAR CARLIN 12/16/2020 $ 915.00
1900218466 102141728 WILSON CARMELITA 12/16/2020 $ 1,210.00
1900218467 102141728 CARPENTER CARMEN 12/16/2020 $ 915.00
JA196
1900218468 102141728 COGEN CAROL 12/16/2020 $ 325.00

1900218469 102141728 REYNOLDS CAROL 12/16/2020 $ 620.00
1900218470 102141728 ROEDER CAROL 12/16/2020 $ 620.00
1900218471 102141728 STEERE CAROLE 12/16/2020 $ 1,210.00
1900218472 102141728 DAVID CAROLYN 12/16/2020 $ 915.00
1900218473 102141728 STALLINGS CAROLYN 12/16/2020 $ 325.00
1900218474 102141728 TAYLOR CAROLYN 12/16/2020 $ 915.00
1900218475 102141728 FRAZIER CATHERINE 12/16/2020 $ 620.00
1900218476 102141728 SCHEIDEGGER CATHY 12/16/2020 $ 81.00
1900218477 102141728 ELLIS CECILE 12/16/2020 $ 620.00
1900218478 102141728 BROWN CEDRIC 12/16/2020 $ 39.00
1900218479 102141728 FERGUSON CELESTINE 12/16/2020 $ 325.00
1900218480 102141728 JONES-CAMERON CELINE 12/16/2020 $ 620.00
1900218481 102141728 FRITH CHAR 12/16/2020 $ 325.00
1900218482 102141728 DAVIS CHARLES 12/16/2020 $ 784.00
1900218483 102141728 DRYDEN CHARLOTE 12/16/2020 $ 372.00
1900218484 102141728 LUTTON CHARLOTTE 12/16/2020 $ 1,210.00
1900218485 102141728 BUTCHER CHAUNCY 12/16/2020 $ 462.62
1900218486 102141728 KNOXBROWN CHELSEY 12/16/2020 $ 1,800.00
1900218487 102141728 MCNITT CHERIE 12/16/2020 $ 1,210.00
1900218488 102141728 ADAMS CHERYL 12/16/2020 $ 1,642.00
1900218489 102141728 CHAMBERS CHESTER 12/16/2020 $ 620.00
1900218490 102141728 OBIOHA CHISOMAGA 12/16/2020 $ 915.00
1900218491 102141728 ANGEL CHLOE 12/16/2020 $ 380.00
1900218492 102141728 DICK CHRIS 12/16/2020 $ 1,210.00
1900218493 102141728 WILCOX CHRIS 12/16/2020 $ 1,194.00
1900218494 102141728 MORRIS-WINTERS CHRISTAL 12/16/2020 $ 33.00
1900218495 102141728 DAVIES CHRISTIAN 12/16/2020 $ 325.00
1900218496 102141728 KIRCHNER-SULLIVAN CHRISTINA 12/16/2020 $ 1,210.00
1900218497 102141728 LUCHANSKY CHRISTINE 12/16/2020 $ 620.00
1900218498 102141728 HARVEY Christopher 12/16/2020 $ 99.00
1900218499 102141728 MILLER CHRISTOPHER 12/16/2020 $ 325.00
1900218500 102141728 ROHR CINDY 12/16/2020 $ 1,976.94
1900218501 102141728 RECTOR CLARK 12/16/2020 $ 1,505.00
1900218502 102141728 HOLLYWOOD CLAUDIA 12/16/2020 $ 325.00
1900218503 102141728 GAINES CLEMENS 12/16/2020 $ 915.00
1900218504 102141728 CUNNINGHAM CLEMON 12/16/2020 $ 1,080.00
1900218505 102141728 BAZELON COLEMAN 12/16/2020 $ 915.00
1900218506 102141728 EISENBEISER COLLEEN 12/16/2020 $ 325.00
1900218507 102141728 PESCATRICE COLLEEN 12/16/2020 $ 325.00
1900218508 102141728 QUINN-HOUSE COLLEEN 12/16/2020 $ 325.00
1900218509 102141728 SULLIVAN COLLIN 12/16/2020 $ 620.00
1900218510 102141728 ASH CONNOR 12/16/2020 $ 620.00
1900218511 102141728 ROSE CONNOR 12/16/2020 $ 620.00
1900218512 102141728 CONLEY COURTNEY 12/16/2020 $ 620.00
1900218513 102141728 PARKS COURfNEY 12/16/2020 $ 325.00
1900218514 102141728 PASTERNAK COURTNEY 12/16/2020 $ 915.00
1900218515 102141728 SNYDAL CRAIG 12/16/2020 $ 1,210.00
1900218516 102141728 WOODS CRAIG 12/16/2020 $ 915.00
1900218517 102141728 SOVEREIGN CRISTINA 12/16/2020 $ 1,210.00
1900218518 102141728 COBB CRYSTAL 12/16/2020 $ 574.00
1900218519 102141728 BERNICK CYNTHIA 12/16/2020 $ 1,000.66
1900218520 102141728 CARRINGTON CYNTHIA 12/16/2020 $ 953.00
1900218521 102141728 GUTIERREZ CYNTHIA 12/16/2020 $ 1,544.00
1900218522 102141728 RIEDY CYNTHIA 12/16/2020 $ 915.00
1900218523 102141728 CAMPBELL DALE 12/16/2020 $ 915.00
1900218524 102141728 HASSANEIN DALIA 12/16/2020 $ 915.00
1900218525 102141728 HAYNES-POWELL DANA 12/16/2020 $ 325.00
1900218526 102141728 HEIDEBRECHT DANA 12/16/2020 $ 686.00
1900218527 102141728 FRITZ DANIEL 12/16/2020 $ 915.00
1900218528 102141728 FURMAN DANIEL 12/16/2020 $ 1,210.00
1900218529 102141728 JACOB DANIEL 12/16/2020 $ 1,615.00
1900218530 102141728 MCGUIRE DANIEL 12/16/2020 $ 620.00
1900218531 102141728 TAYLOR DANIEL 12/16/2020 $ 325.00
1900218532 102141728 COHEN DANIELLE 12/16/2020 $ 2,379.00
JA197
1900218533 102141728 DELOATCH DANIELLE 12/16/2020 $ 1,505.00

1900218534 102141728 NOEL DARCELL 12/16/2020 $ 66.00
1900218535 102141728 HOWARD DARIL 12/16/2020 $ 620.00
1900218536 102141728 HATION DARLENE 12/16/2020 $ 734.00
1900218537 102141728 HARRIDAY DARRYL 12/16/2020 $ 1,505.00
1900218538 102141728 PITISDARWIN 12/16/2020 $ 1,265.00
1900218539 102141728 ALT DAVID 12/16/2020 $ 1,210.00
1900218S40 102141728 COHEN DAVID 12/16/2020 $ 123.00
1900218541 102141728 EGERTON DAVID 12/16/2020 $ 380.00
1900218542 102141728 KLABANOFF DAVID 12/16/2020 $ 620.00
1900218543 102141728 MARLOWE DAVID 12/16/2020 $ 1,S05.00
1900218544 102141728 RIDDLER DAVID 12/16/2020 $ 325.00
1900218545 102141728 VOREL DAVID 12/16/2020 $ 1,210.00
1900218546 102141728 ZINNER DAVID 12/16/2020 $ 2,156.00
1900218547 102141728 GARDNER DAVIS 12/16/2020 $ 45.00
1900218548 102141728 ELDRIDGE DAWNIELLE 12/16/2020 $ 1,505.00
1900218549 102141728 CLARKE DEBORAH 12/16/2020 $ 1,505.00
1900218550 102141728 JASKULEK DEBORAH 12/16/2020 $ 915.00
1900218551 102141728 LATIIMER DEBORAH 12/16/2020 $ 620.00
1900218552 102141728 LAVINE DEBORAH 12/16/2020 $ 2,095.00
1900218553 102141728 MACUCH DEBORAH 12/16/2020 $ 915.00
1900218554 102141728 ROSQUIST DEBORAH 12/16/2020 $ 1,210.00
1900218555 102141728 YOUNG DEBORAH 12/16/2020 $ 978.00
1900218556 102141728 BELLAMY DEBRA 12/16/2020 $ 620.00
1900218557 102141728 EWERT DEBRA 12/16/2020 $ 243.00
1900218558 102141728 HENSGEN DEBRA 12/16/2020 $ 915.00
1900218559 102141728 PALMER DEBRA 12/16/2020 $ 620.00
1900218560 102141728 FELIX DEIDRE 12/16/2020 $ 984.00
1900218561 102141728 CITRO DEIRDRE 12/16/2020 $ 1,913.04
1900218562 102141728 BRANCH DELMA 12/16/2020 $ 1,353.00
1900218563 102141728 BARR DENEE 12/16/2020 $ 915.00
1900218564 102141728 FORD DENISE 12/16/2020 $ 620.00
1900218565 102141728 RILEY DENISE 12/16/2020 $ 620.00
1900218566 102141728 THOMPSON DENISE 12/16/2020 $ 1,210.00
1900218567 102141728 OZKOK DENIZ 12/16/2020 $ 1,210.00
1900218568 102141728 HATION DENNIS 12/16/2020 $ 734.00
1900218569 102141728 WRIGHT DENYSE 12/16/2020 $ 1,700.00
1900218570 102141728 SUSINI DEVIN 12/16/2020 $ 560.92
1900218571 102141728 GARDNER DIANA 12/16/2020 $ 1,208.00
1900218572 102141728 HALL DIANA 12/16/2020 $ 1,324.00
1900218573 102141728 SMITH DIANA 12/16/2020 $ 1,210.00
1900218574 102141728 MINNI DIANE 12/16/2020 $ 325.00
1900218575 102141728 CHOI DIANNE 12/16/2020 $ 325.00
1900218576 102141728 PARIKH DILIP 12/16/2020 $ 620.00
1900218577 102141728 SHAHMOHAMMADI DINA 12/16/2020 $ 325.00
1900218578 102141728 DAVENPORT DONORA 12/16/2020 $ 380.00
1900218579 102141728 LYMAN DONNA 12/16/2020 $ 325.00
1900218580 102141728 SANGER DONNA 12/16/2020 $ 180.00
1900218581 102141728 FELIX DONOVAN 12/16/2020 $ 915.00
1900218582 102141728 RAUSCH DORIS 12/16/2020 $ 147.00
1900218583 102141728 LADD DOUGLAS 12/16/2020 $ 325.00
1900218584 102141728 KASSMAN DREW 12/16/2020 $ 325.00
1900218585 102141728 ASH DUNCAN 12/16/2020 $ 325.00
1900218586 102141728 SWAN EARNESTINE 12/16/2020 $ 620.00
1900218587 102141728 KEBEDE EDEN 12/16/2020 $ 462.62
1900218588 102141728 WARNER EDWARD 12/16/2020 $ 620.00
1900218589 102141728 AVENT EDWIN 12/16/2020 $ 915.00
1900218590 102141728 FOSTER EILEEN 12/16/2020 $ 1,101.00
1900218591 102141728 STURGILL EILEEN 12/16/2020 $ 1,210.00
1900218592 102141728 HADE ELEANOR 12/16/2020 $ 1,422.00
1900218593 102141728 ROBERSON ELISA 12/16/2020 $ 915.00
1900218594 102141728 CARSON ELIZABETH 12/16/2020 $ 999.00
1900218595 102141728 EDWARDS ELIZABETH 12/16/2020 $ 915.00
1900218596 102141728 HUMPHREY ELIZABETH 12/16/2020 $ 1,047.00
1900218597 102141728 JONES ELIZABETH 12/16/2020 $ 1,210.00
JA198
1900218598 102141728 LIEDAHL ELIZABETH 12/16/2020 $ 620.00

1900218599 102141728 MCDONALD ELIZABETH 12/16/2020 $ 39.00
1900218600 102141728 CALLAHAN ELLEN 12/16/2020 $ 1,210.00
1900218601 102141728 MCKINZIE ELLEN 12/16/2020 $ 620.00
1900218602 102141728 HINSON ELLIOTI 12/16/2020 $ 620.00
1900218603 102141728 LABOONE EMIT 12/16/2020 $ 325.00
1900218604 102141728 SPEIERMAN EMILY 12/16/2020 $ 325 .00
1900218605 102141728 TRAVIS HOWARD EMMA 12/16/2020 $ 380.00
1900218606 102141728 MILLER ERIC 12/16/2020 $ 325.00
1900218607 102141728 ROSE ERIC 12/16/2020 $ 915.00
1900218608 102141728 STAPLETON ERIC 12/16/2020 $ 325.00
1900218609 102141728 JACOB ERIK 12/16/2020 $ 2,257.79
1900218610 102141728 EDWARDS ERIN 12/16/2020 $ 915.00
1900218611 102141728 FURLONG ERIN 12/16/2020 $ 620.00
1900218612 102141728 RITIER ERIN 12/16/2020 $ 325 .00
1900218613 102141728 SMITH ERIN 12/16/2020 $ 325.00
1900218614 102141728 STROMBERG ERIN 12/16/2020 $ 620.00
1900218615 102141728 REEVES ERKA 12/16/2020 $ 1,800.00
1900218616 102141728 ROBERSON ERRIEL 12/16/2020 $ 620.00
1900218617 102141728 GRANT ESTHER 12/16/2020 $ 1,679.00
1900218618 102141728 POLLACK ETHAN 12/16/2020 $ 482.28
1900218619 102141728 GAINES ETHEL 12/16/2020 $ 1,076.00
1900218620 102141728 GARY EVELYN 12/16/2020 $ 1,505.00
1900218621 102141728 WILLIAMS EVELYN 12/16/2020 $ 915.00
1900218622 102141728 BLOOMER EVELYNE 12/16/2020 $ 740.00
1900218623 102141728 ONEAL FAATIMAH 12/16/2020 $ 325.00
1900218624 102141728 ELLIS-BLAIR FAITH 12/16/2020 $ 325.00
1900218625 102141728 GRAY FAITH 12/16/2020 $ 325.00
1900218626 102141728 KHALIL FATMA 12/16/2020 $ 325.00
1900218627 102141728 AHMED FAUZIA 12/16/2020 $ 620.00
\
1900218628 102141728 PRICE FLORENCE 12/16/2020 $ 620.00
1900218629 102141728 WISE FLORINE 12/16/2020 $ 620.00
1900218630 102141728 BACON FOSTENA 12/16/2020 $ 514.00
1900218631 102141728 LOTZ FRANCIS 12/16/2020 $ 620.00
1900218632 102141728 BARNES FREDERICK 12/16/2020 $ 829.00
1900218633 102141728 SHAW FREDERICK 12/16/2020 $ 1,709.00
1900218634 102141728 OTUBU GABRIEL 12/16/2020 $ 325.00
1900218635 102141728 FLEMING GALE 12/16/2020 $ 1,210.00
1900218636 102141728 NASON GEM 12/16/2020 $ 915.00
1900218637 102141728 BROBBEY GEOFFREY 12/16/2020 $ 620.00
1900218638 102141728 WELSH GERALD 12/16/2020 $ 1,430.00
1900218639 102141728 CHARLOT GERARD 12/16/2020 $ 325.00
1900218640 102141728 ADAMS GORDON 12/16/2020 $ 325.00
1900218641 102141728 HEIDEBRECHT GRANT 12/16/2020 $ 686.00
1900218642 102141728 WAGNER GRANT 12/16/2020 $ 915.00
1900218643 102141728 THOMAS GWENDOLYN 12/16/2020 $ 1,210.00
1900218644 102141728 KELLY HANNAH 12/16/2020 $ 325 .00
1900218645 102141728 ALLEN HARRlffiA 12/16/2020 $ 1,210.00
1900218646 102141728 JENNINGS HARTFORD 12/16/2020 $ 620.00
1900218647 102141728 TROTIER HEATHER 12/16/2020 $ 1,505.00
1900218648 102141728 RICHARDSON HEIDI 12/16/2020 $ 325.00
1900218649 102141728 JACKSON HOPE 12/16/2020 $ 620.00
1900218650 102141728 BOOEIAN 12/16/2020 $ 1,224.00
1900218651 102141728 FINCH IDA 12/16/2020 $ 1,210.00
1900218652 102141728 WILLIAMS IDA 12/16/2020 $ 1,210.00
1900218653 102141728 BROWN-FISHKIND !LENE 12/16/2020 $ 674.06
1900218654 102141728 ESSIEN IME 12/16/2020 $ 915.00
1900218655 102141728 JIMENEZ IRMA 12/16/2020 $ 620.00
1900218656 102141728 ALLEN 15AAC 12/16/2020 $ 325.00
1900218657 102141728 RIDGEWAY JACK 12/16/2020 $ 2,331.00
1900218658 102141728 COFSKE JACOB 12/16/2020 $ 620.00
1900218659 102141728 STATON JACOB 12/16/2020 $ 915.00
1900218660 102141728 TROPPMAN JACQUELINE 12/16/2020 $ 1,210.00
1900218661 102141728 PRAYLO-JOHNSON JACQUELYN 12/16/2020 $ 325.00
1900218662 102141728 CUNNINGHAM JAMES 12/16/2020 $ 1,375.00
JA199
1900218663 102141728 EHLE JAMES 12/16/2020 $ 213.00

1900218664 102141728 EWERT JAMES 12/16/2020 $ 380.00
1900218665 102141728 FARINHOLT JAMES 12/16/2020 $ 325.00
1900218666 102141728 FARNUM JAMES 12/16/2020 $ 734.00
1900218667 102141728 HADE JAMES 12/16/2020 $ 1,506.00
1900218668 102141728 KLENDER JAMES 12/16/2020 $ 325.00
1900218669 102141728 PALMJAME5 12/16/2020 $ 915.00
1900218670 102141728 SMITH JAN 12/16/2020 $ 1,210.00
1900218671 102141728 JOHNSON JANE 12/16/2020 $ 325.00
1900218672 102141728 BROENING JANET 12/16/2020 $ 1,038.00
1900218673 102141728 COPPAGE JANET 12/16/2020 $ 325.00
1900218674 102141728 FOLKERTS JANET 12/16/2020 $ 915.00
1900218675 102141728 ROBINSON JANET 12/16/2020 $ 2,095.00
1900218676 102141728 STOCK JANET 12/16/2020 $ 1,210.00
1900218677 102141728 MULUGETA JANICE 12/16/2020 $ 325.00
1900218678 102141728 POLLACK JANINE 12/16/2020 $ 462.62
1900218679 102141728 GBOFFUEH JASAY 12/16/2020 $ 620.00
1900218680 102141728 FIEGELJASON 12/16/2020 $ 380.00
1900218681 102141728 ALLEN JAY 12/16/2020 $ 620.00
1900218682 102141728 RUDZINJAY 12/16/2020 $ 1,210.00
1900218683 102141728 FRESHWATERJAYDEN 12/16/2020 $ 325.00
1900218684 102141728 CURTIN-BROSAN JEAN 12/16/2020 $ 255.00
1900218685 102141728 GAINES JEAN 12/16/2020 $ 915.00
1900218686 102141728 HOLMES JEAN 12/16/2020 $ 915.00
1900218687 102141728 SLATER JEANNE 12/16/2020 $ 915.00
1900218688 102141728 BOWER JEFFREY 12/16/2020 $ 1,615.00
1900218689 102141728 HARTZ JEFFREY 12/16/2020 $ 325.00
1900218690 102141728 MCCONNELLJEFFREY 12/16/2020 $ 620.00
1900218691 102141728 WEBB JEFFREY 12/16/2020 $ 1,029.00
1900218692 102141728 PASTERNAK JENNA 12/16/2020 $ 620.00
1900218693 102141728 HAYASHI JENNIFER 12/16/2020 $ 915.00
1900218694 102141728 JOHNSON JENNIFER 12/16/2020 $ 3,180.00
1900218695 102141728 JONES-BLANCO JENNIFER 12/16/2020 $ 243.00
1900218696 102141728 MANNING JENNIFER 12/16/2020 $ 1,210.00
1900218697 102141728 RICHARDSON JENNIFER 12/16/2020 $ 325.00
1900218698 102141728 scon JENNIFER 12/16/2020 $ 915.00
1900218699 102141728 BURTZLAFF JENNY 12/16/2020 $ 380.00
1900218700 102141728 JUNG JESSICA 12/16/2020 $ 325.00
1900218701 102141728 STEVENSON JEWEL 12/16/2020 $ 915.00
1900218702 102141728 STATON JILL 12/16/2020 $ 915.00
1900218703 102141728 JONES JOAN 12/16/2020 $ 1,505.00
1900218704 102141728 HAWKINS JOANN 12/16/2020 $ 325.00
1900218705 102141728 DOVE JOANNE 12/16/2020 $ 325.00
1900218706 102141728 MILLER JO-ANNE 12/16/2020 $ 1,505.00
1900218707 102141728 POLLACK JOEL 12/16/2020 $ 915.00
1900218708 102141728 BERTULIS JOHN 12/16/2020 $ 1,210.00
1900218709 102141728 BRAXTON JOHN 12/16/2020 $ 1,505.00
,1900218710 102141728 KAGIRI JOHN 12/16/2020 $ 620.00
1900218711 102141728 MOSEMAN JOHN 12/16/2020 $ 380.00
1900218712 102141728 MYERS JOHN 12/16/2020 $ 1,430.00
1900218713 102141728 REID JOHN 12/16/2020 $ 1,393.00
1900218714 102141728 SEGNAJOHN 12/16/2020 $ 357.00
1900218715 102141728 STOCK JOHN 12/16/2020 $ 1,210.00
1900218716 102141728 TAYLOR JOHN 12/16/2020 $ 620.00
1900218717 102141728 WORLEY JOHN 12/16/2020 $ 1,056.00
1900218718 102141728 WOODSON JOHNETIA 12/16/2020 $ 1,505.00
1900218719 102141728 GAINES JOHNEY 12/16/2020 $ 620.00
1900218720 102141728 MONSEIN JONATHAN 12/16/2020 $ 620.00
1900218721 102141728 MICHEL JORDAN 12/16/2020 $ 325.00
1900218722 102141728 GENTILE JOSEPH 12/16/2020 $ 222.00
1900218723 102141728 MCQUAID JOSEPH 12/16/2020 $ 730.00
1900218724 102141728 OBERLY JOSHUA 12/16/2020 $ 325.00
1900218725 102141728 UTMARJOYCE 12/16/2020 $ 620.00
1900218726 102141728 ARRINGTON JUDITH 12/16/2020 $ 66.00
1900218727 102141728 SONGJULIA 12/16/2020 $ 325.00
JA200
1900218728 102141728 MEISINGER JULIANNE 12/16/2020 $ 1,210.00

1900218729 102141728 ASH JULIE 12/16/2020 $ 325.00
1900218730 102141728 RIDDLER JULIE 12/16/2020 $ 325.00
1900218731 102141728 GILL-BEY KADESHA 12/16/2020 $ 1,860.00
1900218732 102141728 SCHUMITZ KALI 12/16/2020 $ 620.00
1900218733 102141728 BORTVEDT ESTRADA KAREN 12/16/2020 $ 1,505.00
1900218734 102141728 JACOB KAREN 12/16/2020 $ 3,070.00
1900218735 102141728 SEVERSON KAREN 12/16/2020 $ 620.00
1900218736 102141728 YAREMA KARLYLE 12/16/2020 $ 1,270.00
1900218737 102141728 CLENDENIN KATALIN 12/16/2020 $ 915.00
1900218738 102141728 ALBERT KATHERINE 12/16/2020 $ 915.00
1900218739 102141728 BODDY-BLUE KATHERINE 12/16/2020 $ 1,347.62
1900218740 102141728 CRAWFORD KATHERINE 12/16/2020 $ 620.00
1900218741 102141728 METHRIC KATHLEEN 12/16/2020 $ 325.00
1900218742 102141728 ORRSON KATHLEEN 12/16/2020 $ 183.00
1900218743 102141728 WOLF KATHLEEN 12/16/2020 $ 620.00
1900218744 102141728 COMISAROW KATHRYN 12/16/2020 $ 620.00
1900218745 102141728 BOSCHULTE KATHRYN WALLACE 12/16/2020 $ 620.00
1900218746 102141728 VANDENBERG KAY 12/16/2020 $ 620.00
1900218747 102141728 THOMPSON KAYDENCE 12/16/2020 $ 915.00
1900218748 102141728 MARSDEN KAYLIN 12/16/2020 $ 620.00
1900218749 102141728 LAVINE KENAI 12/16/2020 $ 1,210.00
1900218750 102141728 KELLY KENNETH 12/16/2020 $ 325.00
1900218751 102141728 WILLIAMS KENNETH 12/16/2020 $ 1,080.00
1900218752 102141728 WINSTON KERRA 12/16/2020 $ 915.00
1900218753 102141728 HARTZ KEVIN 12/16/2020 $ 325.00
1900218754 102141728 MURRAY KEVIN 12/16/2020 $ 620.00
1900218755 102141728 SELOCK KEVIN 12/16/2020 $ 60.00
1900218756 102141728 BOX KHADIJAH 12/16/2020 $ 620.00
1900218757 102141728 WALKER KHARA 12/16/2020 $ 730.00
1900218758 102141728 LEACH KHRISTINE 12/16/2020 $ 1,210.00
1900218759 102141728 FOK KIANA 12/16/2020 $ 915.00
1900218760 102141728 DRAKE KIMBERLEE 12/16/2020 $ 620.00
1900218761 102141728 ADEDOYIN KIMBERLY 12/16/2020 $ 1,399.00
1900218762 102141728 DAVIS KIMBERLY 12/16/2020 $ 325.00
1900218763 102141728 GRIFFITH KIMBERLY 12/16/2020 $ 915.00
1900218764 102141728 OBERLY KIMBERLY 12/16/2020 $ 1,210.00
1900218765 102141728 OBRYANT KIMBERLY 12/16/2020 $ 620.00
1900218766 102141728 ELLIOTI KORNELIA 12/16/2020 $ 620.00
1900218767 102141728 BLOUNT KRISTEN 12/16/2020 $ 325.00
1900218768 102141728 HARPER KYLARR 12/16/2020 $ 1,210.00
1900218769 102141728 MASON KYNDALL 12/16/2020 $ 325.00
1900218770 102141728 ODEN LACHELLE 12/16/2020 $ 620.00
1900218771 102141728 PAYNE-NEWTON LAKECIA 12/16/2020 $ 620.00
1900218772 102141728 JACOB LANCE 12/16/2020 $ 1,025 .00
1900218773 102141728 BROOKS LANGSTON 12/16/2020 $ 1,800.00
1900218774 102141728 ABEDIN LARA 12/16/2020 $ 620.00
1900218775 102141728 ELLETSON LARRY 12/16/2020 $ 2,260.00
1900218776 102141728 CELTNIEKS LARSS 12/16/2020 $ 1,210.00
1900218777 102141728 CAMPBELL LAURA 12/16/2020 $ 1,210.00
1900218778 102141728 SERVICE LAURA 12/16/2020 $ 325.00
1900218779 102141728 SHOVAN LAURA 12/16/2020 $ 620.00
1900218780 102141728 ALBERT LAUREN 12/16/2020 $ 915.00
1900218781 102141728 BRANCH LAUREN 12/16/2020 $ 620.00
1900218782 102141728 BULKA LAURENCE 12/16/2020 $ 1,210.00
1900218783 102141728 FINKELSTEIN LAWRENCE 12/16/2020 $ 325.00
1900218784 102141728 BULKA LEAH 12/16/2020 $ 915.00
1900218785 102141728 POWERS LEIF 12/16/2020 $ 180.00
1900218786 102141728 CABALLERO LEONARD 12/16/2020 $ 1,210.00
1900218787 102141728 COLE LETITIA 12/16/2020 $ 620.00
1900218788 102141728 GEORGE LETITIA 12/16/2020 $ 1,210.00
1900218789 102141728 FAZZARI LINDA 12/16/2020 $ 878.00
1900218790 102141728 FLEISCHER LINDA 12/16/2020 $ 1,435.00
1900218791 102141728 LEVENE LINDA 12/16/2020 $ 620.00
1900218792 102141728 ROSBRUGH LINDA 12/16/2020 $ 915.00
JA201
1900218793 102141728 SEMMEL LINDA 12/16/2020 $ 380.00

1900218794 102141728 LAYTON LIONEL 12/16/2020 $ 915.00
1900218795 102141728 BROWN LISA 12/16/2020 $ 620.00
1900218796 102141728 CHAMPAGNE LANCE LISA 12/16/2020 $ 600.00
1900218797 102141728 COLANGELO LISA 12/16/2020 $ 620.00
1900218798 102141728 CORBITT LISA 12/16/2020 $ 403.64
1900218799 102141728 LOSITO LISA 12/16/2020 $ 915.00
1900218800 102141728 MILES LISA 12/16/2020 $ 620.00
1900218801 102141728 SLOVER LISA 12/16/2020 $ 325 .00
1900218802 102141728 STEPTOE LISA 12/16/2020 $ 620.00
1900218803 102141728 WALKER LISA 12/16/2020 $ 620.00
1900218804 102141728 LAGERA LORENZO 12/16/2020 $ 915.00
1900218805 102141728 BURMAN LORI 12/16/2020 $ 915.00
1900218806 102141728 ESTES LORI 12/16/2020 $ 325.00
1900218807 102141728 KIBLER LOUISE 12/16/2020 $ 620.00
1900218808 102141728 MCCALL LYNDA 12/16/2020 $ 620.00
1900218809 102141728 FOEHRKOLB LYNN 12/16/2020 $ 325.00
1900218810 102141728 WAGNER LYNNE 12/16/2020 $ 915.00
1900218811 102141728 FAN MAGGIE 12/16/2020 $ 325.00
1900218812 102141728 FLEMING MARC 12/16/2020 $ 915.00
1900218813 102141728 TOLSON MARC 12/16/2020 $ 1,505.00
1900218814 102141728 ST LAWRENCE MARCIA 12/16/2020 $ 560.92
1900218815 102141728 AHMED MARIA 12/16/2020 $ 620.00
1900218816 102141728 KING MARIE 12/16/2020 $ 800.00
1900218817 102141728 MEAKIN MARIE 12/16/2020 $ 325 .00
1900218818 102141728 BROOKS MARK 12/16/2020 $ 1,505.00
1900218819 102141728 KAISER MARK 12/16/2020 $ 325.00
1900218820 102141728 MALLARE MARK 12/16/2020 $ 620.00
1900218821 102141728 RASZEWSKI MARK 12/16/2020 $ 620.00
1900218822 102141728 STECKBECK MARK 12/16/2020 $ 915.00
1900218823 102141728 ZIMMERMAN MARK 12/16/2020 $ 210.00
1900218824 102141728 MCINTOSH MARLA 12/16/2020 $ 655.00
1900218825 102141728 DAVIS MARQUITA 12/16/2020 $ 674.00
1900218826 102141728 LEE MARSHALL 12/16/2020 $ 915.00
1900218827 102141728 DOTSON MARTHA 12/16/2020 $ 620.00
1900218828 102141728 LUCHANSKY MARTIN 12/16/2020 $ 620.00
1900218829 102141728 COX MARY 12/16/2020 $ 501 .84
1900218830 102141728 LOUIS MARY 12/16/2020 $ 1,505.00
1900218831 102141728 NEWKIRK MARY 12/16/2020 $ 325 .00
1900218832 102141728 PEROUTKA MARY 12/16/2020 $ 915 .00
1900218833 102141728 RINGSTAD MARY 12/16/2020 $ 1,080.00
1900218834 102141728 VANNEWKIRK MARY 12/16/2020 $ 740.00
1900218835 102141728 HARPER MARYELLEN 12/16/2020 $ 1,780.00
1900218836 102141728 OLIVER MATILDA 12/16/2020 $ 1,210.00
1900218837 102141728 FRANCES MATIHEW 12/16/2020 $ 325.00
1900218838 102141728 PEROUTKA MATIHEW 12/16/2020 $ 915 .00
1900218839 102141728 DONAGHY MAUREEN 12/16/2020 $ 915 .00
1900218840 102141728 scan MCKENZIE 12/16/2020 $ 915 .00
1900218841 102141728 YAKSICH MELANIE 12/16/2020 $ 1,210.00
1900218842 102141728 UTT MELINDA 12/16/2020 $ 1,210.00
1900218843 102141728 FLEMING MELISSA 12/16/2020 $ 915.00
1900218844 102141728 GREENE MELISSA 12/16/2020 $ 138.00
1900218845 102141728 NELMS MELISSA 12/16/2020 $ 1,080.00
1900218846 102141728 ROBINSON MIA 12/16/2020 $ 1,505.00
1900218847 102141728 WALLACE MICAH 12/16/2020 $ 325 .00
1900218848 102141728 BAITY MICHAEL 12/16/2020 $ 675.00
1900218849 102141728 BOSTRON MICHAEL 12/16/2020 $ 1,210.00
1900218850 102141728 KRUEGER MICHAEL 12/16/2020 $ 2,100.00
1900218851 102141728 ROOSA MICHAEL 12/16/2020 $ 1,430.00
1900218852 102141728 SELLNER MICHAEL 12/16/2020 $ 915.00
19002188S3 102141728 WOLF MICHAEL 12/16/2020 $ 620.00
1900218854 102141728 BOGUS MICHELE 12/16/2020 $ 915.00
1900218855 102141728 WELKER MILDRED 12/16/2020 $ 1,505.00
1900218856 102141728 BLOWERS MISTY 12/16/2020 $ 620.00
1900218857 102141728 DROST NANCY 12/16/2020 $ 1,210.00
JA202
1900218858 102141728 PINOS NAPOLEON 12/16/2020 $ 2,130.00

1900218859 102141728 HLASKO NATALIA 12/16/2020 $ 620.00
1900218860 102141728 STUPPARD NATALIE 12/16/2020 $ 620.00
1900218861 102141728 FEINBERG NEAL 12/16/2020 $ 2,095.00
1900218862 102141728 BROWN NICHOLAS 12/16/2020 $ 1,210.00
1900218863 102141728 SINGLETARY NICOLE 12/16/2020 $ 1,210.00
1900218864 102141728 SULLIVAN NICOLE 12/16/2020 $ 600.00
1900218865 102141728 ASHKEBOUSSI NIMA A5HKEBOUSSI 12/16/2020 $ 192.00
1900218866 102141728 HERON NORMA 12/16/2020 $ 325.00
1900218867 102141728 ZUNDEL NORMAN 12/16/2020 $ 397 .00
1900218868 102141728 DERAMO-FLACK PATRICE 12/16/2020 $ 620.00
1900218869 102141728 ALESHIRE PATRICIA 12/16/2020 $ 915.00
1900218870 102141728 CHAMBERS PATRICIA 12/16/2020 $ 620.00
1900218871 102141728 CUMMINGS PATRICIA 12/16/2020 $ 1,560.00
1900218872 102141728 FRANCIS PATRICIA 12/16/2020 $ 1,210.00
1900218873 102141728 MATHEWS PATRICIA 12/16/2020 $ 915.00
1900218874 102141728 MURPHY PATRICIA 12/16/2020 $ 325.00
1900218875 102141728 REGAN PATRICIA 12/16/2020 $ 620.00
1900218876 102141728 WATKINS PATRICIA 12/16/2020 $ 620.00
1900218877 102141728 RASMUSSEN PATRICK 12/16/2020 $ 915.00
1900218878 102141728 RIVERS PAUL 12/16/2020 $ 2,830.00
1900218879 102141728 SEVERSON PAUL 12/16/2020 $ 1,210.00
1900218880 102141728 GORE PAULA 12/16/2020 $ 620.00
1900218881 102141728 ANTHONY PEGGY 12/16/2020 $ 1,505.00
1900218882 102141728 DOLAN PETER 12/16/2020 $ 620.00
1900218883 102141728 KICZA PETER 12/16/2020 $ 1,800.00
1900218884 102141728 LENTOCHA PHILIP 12/16/2020 $ 915.00
1900218885 102141728 SURANA PRATAP 12/16/2020 $ 620.00
1900218886 102141728 MATHAPATI PRATHAM 12/16/2020 $ 325 .00
1900218887 102141728 KAMATH PRIYA 12/16/2020 $ 325.00
1900218888 102141728 YADAV PRIYA 12/16/2020 $ 620.00
1900218889 102141728 COLLINS QUINN 12/16/2020 $ 915.00
1900218890 102141728 FREEDMAN RACHAEL 12/16/2020 $ 325 .00
1900218891 102141728 HAMBERGER RACHEL 12/16/2020 $ 325.00
1900218892 102141728 SCHAAF RACHEL 12/16/2020 $ 620.00
1900218893 102141728 SMITH RACHEL 12/16/2020 $ 1,505.00
1900218894 102141728 BACHUBHAY RAJESHRI 12/16/2020 $ 325 .00
1900218895 102141728 HEIMLICH RALPH 12/16/2020 $ 1,210.00
1900218896 102141728 DOYLE RAYMOND 12/16/2020 $ 1,965.00
1900218897 102141728 LEVESQUE RAYMOND 12/16/2020 $ 915.00
1900218898 102141728 MILLER REBA 12/16/2020 $ 325 .00
1900218899 102141728 DAVIS NORD REBECCA 12/16/2020 $ 192.00
1900218900 102141728 FAIRBANKS REBECCA 12/16/2020 $ 325.00
1900218901 102141728 FECTEAU REBECCA 12/16/2020 $ 325.00
1900218902 102141728 KOSLOVER REBECCA 12/16/2020 $ 915 .00
1900218903 102141728 MAEREGU REBECCA 12/16/2020 $ 1,210.00
1900218904 102141728 NASON REBECCA 12/16/2020 $ 1,210.00
1900218905 102141728 GREEN REGINA 12/16/2020 $ 915.00
1900218906 102141728 LEE REGINA 12/16/2020 $ 586.00
1900218907 102141728 DESROCHER RENEE 12/16/2020 $ 1,210.00
1900218908 102141728 KAISER RICHARD 12/16/2020 $ 1,210.00
1900218909 102141728 KOLESAR RICHARD 12/16/2020 $ 1,505.00
1900218910 102141728 WILLIAMS RICHARD 12/16/2020 $ 1,080.00
1900218911 102141728 OLALEYE RITA 12/16/2020 $ 620.00
1900218912 102141728 BOYLE ROBERT 12/16/2020 $ 915.00
1900218913 102141728 CIBOROWSKI ROBERT 12/16/2020 $ 1,505.00
1900218914 102141728 COKER ROBERT 12/16/2020 $ 800.00
1900218915 102141728 ENGLISH ROBERT 12/16/2020 $ 620.00
1900218916 102141728 HURWITZ ROBERT 12/16/2020 $ 1,210.00
1900218917 102141728 KRATOCHVIL ROBERT 12/16/2020 $ 325.00
1900218918 102141728 NORTH ROBERT 12/16/2020 $ 1,210.00
1900218919 102141728 SCHMIDT ROBERT 12/16/2020 $ 620.00
1900218920 102141728 VOGEL ROBERT 12/16/2020 $ 915.00
1900218921 102141728 ZAHOR ROBIN 12/16/2020 $ 620.00
1900218922 102141728 GUERRASIO ROBYN 12/16/2020 $ 1,210.00
JA203
1900218923 102141728 SHREEVE ROGER 12/16/2020 $ 325.00

1900218924 102141728 THOMPSON ROSETTA 12/16/2020 $ 379.00
1900218925 102141728 ZAGHAB ROXANNE 12/16/2020 $ 249.00
1900218926 102141728 WILLIAMS RUSSELL 12/16/2020 $ 915.00
1900218927 102141728 BLOOM RYAN 12/16/2020 $ 915.00
1900218928 102141728 SERIO SALVATORE 12/16/2020 $ 1,505.00
1900218929 102141728 LADDON SAMANTHA 12/16/2020 $ 1,080.00
1900218930 102141728 FINKELSTEIN SAMUEL 12/16/2020 $ 325.00
1900218931 102141728 NUGENT SANAA 12/16/2020 $ 620.00
1900218932 102141728 PRICE SANDRA 12/16/2020 $ 730.00
1900218933 102141728 ABEDIN SARAH 12/16/2020 $ 915.00
1900218934 102141728 GARIFO SARAH 12/16/2020 $ 325.00
1900218935 102141728 LOPEZ SARAH 12/16/2020 $ 620.00
1900218936 102141728 TAYLOR SARAH 12/16/2020 $ 325.00
1900218937 102141728 MARKARIS SARANTIS 12/16/2020 $ 325 .00
1900218938 102141728 Yoyo Schimri 12/16/2020 $ 132.00
1900218939 102141728 GUZEWICH SCOTT 12/16/2020 $ 620.00
1900218940 102141728 BROWN SEAN 12/16/2020 $ 620.00
1900218941 102141728 PARISI SEBASTIAN 12/16/2020 $ 915 .00
1900218942 102141728 WILLIAMS SEEDA 12/16/2020 $ 325.00
1900218943 102141728 JUNG SEONG 12/16/2020 $ 620.00
1900218944 102141728 VASSEL SHAMOY 12/16/2020 $ 88.98
1900218945 102141728 BLOUNT SHANNON 12/16/2020 $ 620.00
1900218946 102141728 MITCHELL SHANNON 12/16/2020 $ 620.00
1900218947 102141728 MAKLE SHARDAYE 12/16/2020 $ 325.00
1900218948 102141728 FULTON SHARON 12/16/2020 $ 2,081.00
1900218949 102141728 JENNINGS SHARON 12/16/2020 $ 620.00
1900218950 102141728 RAHAMAN SHEIK 12/16/2020 $ 620.00
1900218951 102141728 KERSEY SHERRI 12/16/2020 $ 325.00
1900218952 102141728 CRAWFORD SHERRY 12/16/2020 $ 677.00
1900218953 102141728 SUCKLAL SIRINA 12/16/2020 $ 915 .00
1900218954 102141728 CARRASCO SOFIA 12/16/2020 $ 325.00
1900218955 102141728 BANKOLE SOLOMON 12/16/2020 $ 391.00
1900218956 102141728 UMEOZULU SOMACHUKWU 12/16/2020 $ 620.00
1900218957 102141728 KANG SOOYOUNG 12/16/2020 $ 620.00
1900218958 102141728 RAMESH SRUTHI 12/16/2020 $ 325.00
1900218959 102141728 SWEET STACEY 12/16/2020 $ 183.00
1900218960 102141728 SPEIERMAN STACI 12/16/2020 $ 915.00
1900218961 102141728 BOGENSCHUTZ STAR 12/16/2020 $ 620.00
1900218962 102141728 HOLEMAN STEPHANIE 12/16/2020 $ 325 .00
1900218963 102141728 MUMMERT STEPHANIE 12/16/2020 $ 325 .00
1900218964 102141728 SMITH STEPHANIE 12/16/2020 $ 915.00
1900218965 102141728 SMITH STEPHANIE 12/16/2020 $ 1,320.00
1900218966 102141728 JA5KULEK STEPHEN 12/16/2020 $ 915.00
1900218967 102141728 LIBERATORE STEPHEN 12/16/2020 $ 2,456.00
1900218968 102141728 SINGER STEPHEN 12/16/2020 $ 1,080.00
1900218969 102141728 PHURROUGH STEVE 12/16/2020 $ 114.00
1900218970 102141728 COOPERSTEIN STEVEN 12/16/2020 $ 620.00
1900218971 102141728 DRAKOS STEVEN 12/16/2020 $ 620.00
1900218972 102141728 MADEWELL STEVEN 12/16/2020 $ 492.11
1900218973 102141728 CLAIRMONT SUSAN 12/16/2020 $ 1,375.00
1900218974 102141728 MORIARTY SUSAN 12/16/2020 $ 915.00
1900218975 102141728 ROSENQUIST SUSAN 12/16/2020 $ 620.00
1900218976 102141728 ROSENVOLD SUSAN 12/16/2020 $ 620.00
1900218977 102141728 SELAYA MILLARD SUSAN 12/16/2020 $ 505 .00
1900218978 102141728 BRIGGS SUZANNE 12/16/2020 $ 915.00
1900218979 102141728 THOMAS SYDNEY 12/16/2020 $ 1,210.00
1900218980 102141728 OLDENBURG SYLVAN 12/16/2020 $ 620.00
1900218981 102141728 POWELL TAMMY 12/16/2020 $ 325.00
1900218982 102141728 REDDICK LOCKETT TAMMY 12/16/2020 $ 1,210.00
1900218983 102141728 PHILLIPS TARA 12/16/2020 $ 325.00
1900218984 102141728 WILLIAMS TATIANNA 12/16/2020 $ 1,210.00
1900218985 102141728 REDMILES TAYLOR 12/16/2020 $ 325.00
1900218986 102141728 BEECROFT ABU TERESA 12/16/2020 $ 1,505.00
1900218987 102141728 POTTER TERRAN 12/16/2020 $ 620.00
JA204
1900218988 102141728 HANDS TERRI 12/16/2020 s 620.00

1900218989 102141728 SCHAD TERRI 12/16/2020 s 1,378.00
1900218990 102141728 LAZAROU THEODORE 12/16/2020 s 325.00
1900218991 102141728 ERICSON THOMAS 12/16/2020 s 380.00
1900218992 102141728 HUMPHREYS THOMAS 12/16/2020 s 1,505.00
1900218993 102141728 PIRRITANO THOMAS 12/16/2020 s 970.00
1900218994 102141728 STATON THOMAS 12/16/2020 s 620.00
1900218995 102141728 MILLER THOMASINA 12/16/2020 $ 620.00
1900218996 102141728 FLYNN TIMOTHY 12/16/2020 s 380.00
1900218997 102141728 METHRICTIMOTHY 12/16/2020 $ 325.00
1900218998 102141728 STATON TIRE 12/16/2020 s 915.00
1900218999 102141728 THOMPSON TOMI 12/16/2020 $ 915.00
1900219000 102141728 ALLEN TOMMIE 12/16/2020 $ 1,505.00
1900219001 102141728 TIFFANY TONYA 12/16/2020 $ 2,060.00
1900219002 102141728 HALL TRACY 12/16/2020 $ 1,210.00
1900219003 102141728 MULINAZZI TRAJAN 12/16/2020 $ 915.00
1900219004 102141728 GOSS TROY 12/16/2020 s 686.00
1900219005 102141728 STATON TYLEEN 12/16/2020 $ 915.00
1900219006 102141728 ONEAL TYRA 12/16/2020 $ 1,080.00
1900219007 102141728 ACHUKO UCHECHI 12/16/2020 s 186.00
1900219008 102141728 BARNARD VALERIE 12/16/2020 $ 325.00
1900219009 102141728 BOYD VALERIE 12/16/2020 $ 147.00
1900219010 102141728 LAWSON VANGELA 12/16/2020 $ 915.00
1900219011 102141728 GAINES VEOLA 12/16/2020 $ 1,505.00
1900219012 102141728 ADLER VERONICA 12/16/2020 s 620.00
1900219013 102141728 DAVIS VERONICA 12/16/2020 $ 1,637.00
1900219014 102141728 KOCH VERONICA 12/16/2020 $ 1,210.00
1900219015 102141728 FRAZIER VICTOR 12/16/2020 s 325.00
1900219016 102141728 OWENS VICTORIA 12/16/2020 $ 325.00
1900219017 102141728 RAVEN VIKKI 12/16/2020 $ 915.00
1900219018 102141728 KIRK VIRGINIA 12/16/2020 $ 620.00
1900219019 102141728 BAIR VIVIAN 12/16/2020 $ 620.00
1900219020 102141728 GENTILE VIVIANE 12/16/2020 $ 219.00
1900219021 102141728 FINEGAR WAYNE 12/16/2020 $ 458.00
1900219022 102141728 POWELL WESLEY 12/16/2020 $ 325.00
1900219023 102141728 KNIGHT WILLIAM 12/16/2020 $ 750.00
1900219024 102141728 NEUMANN WILLIAM 12/16/2020 $ 730.00
1900219025 102141728 RILEY WILLIAM 12/16/2020 $ 325.00
1900219026 102141728 WHEELER WILLIAM 12/16/2020 s 620.00
1900219027 102141728 PEPPERS WILMA 12/16/2020 $ 915.00
1900219028 102141728 GRANT WINSTON 12/16/2020 $ 325.00
1900219029 102141728 WATSON ZANA 12/16/2020 $ 325.00
1900219030 102141728 RODRIGUEZ ADA GUISELLE 12/16/2020 $ 1,210.00
1900219031 102141728 PATEL AKSHAYKUMAR 12/16/2020 $ 620.00
1900219032 102141728 BATES AMANDA 12/16/2020 $ 620.00
1900219033 102141728 WEINSCHENK ANNE 12/16/2020 $ 620.00
1900219034 102141728 ADEDAPO BABATUNDE 12/16/2020 $ 325.00
1900219035 102141728 CARRIER! BERNADITTE 12/16/2020 $ 1,546.00
1900219036 102141728 AIDOO BERNICE 12/16/2020 $ 1,068.00
1900219037 102141728 GRAHAM BEVERLY 12/16/2020 $ 2,095.00
1900219038 102141728 OZOMAH BOB 12/16/2020 $ 620.00
1900219039 102141728 ASIFAT KAREEM BOONYAMIN 12/16/2020 $ 325.00
1900219040 102141728 $PESICK BRITIANI 12/16/2020 $ 1,560.00
1900219041 102141728 KING BRUCE 12/16/2020 $ 2,130.00
1900219042 102141728 FULTON CARMEN 12/16/2020 $ 325.00
1900219043 102141728 PATIERSON CASSANDRA 12/16/2020 $ 1,210.00
1900219044 102141728 SKIPPER CHRISTIAN 12/16/2020 $ 1,505.00
1900219045 102141728 BEECHER CHRISTINE 12/16/2020 $ 1,080.00
1900219046 102141728 CUNNINGHAM CHRISTINE 12/16/2020 s 915.00
1900219047 102141728 CUMMINGS CHRISTOPHER 12/16/2020 $ 1,210.00
1900219048 102141728 LEWIS CHRISTY 12/16/2020 $ 620.00
1900219049 102141728 MILNOR-DUNBAR CRISTINA 12/16/2020 $ 325.00
1900219050 102141728 EDWARDS DANA 12/16/2020 $ 1,505.00
1900219051 102141728 MARONE DANIELLE 12/16/2020 $ 1,505.00
1900219052 102141728 BULLOCK DAVID 12/16/2020 $ 1,810.00
JA205
1900219053 102141728 LLANOS DEBRA 12/16/2020 $ 325.00

1900219054 102141728 HINSON ELIZABETH 12/16/2020 $ 325.00
1900219055 102141728 VAINIERI EMILY 12/16/2020 $ 620.00
1900219056 102141728 TILLERY ERIKA 12/16/2020 $ 915.00
1900219057 102141728 MCCLURE ERIN 12/16/2020 $ 1,210.00
1900219058 102141728 KELLY GABRIELLE 12/16/2020 $ 1,338.00
1900219059 102141728 SANTOS GAYLYN 12/16/2020 $ 620.00
1900219060 102141728 ONYAH IRINE 12/16/2020 $ 620.00
1900219061 102141728 FELICE JACINTA 12/16/2020 $ 325.00
1900219062 102141728 MADDEN JADE 12/16/2020 $ 1,445.92
1900219063 102141728 PIERRE JEAN 12/16/2020 $ 915.00
1900219064 102141728 BOLSTER JEFFREY 12/16/2020 $ 1,210.00
1900219065 102141728 SCHWARTZ JENNIFER 12/16/2020 $ 620.00
1900219066 102141728 WAFER JOHN 12/16/2020 $ 1,619.00
1900219067 102141728 ODUM JOSEPH 12/16/2020 $ 325.00
1900219068 102141728 DAVIS JUDITH 12/16/2020 $ 1,210.00
1900219069 102141728 SKIPPER KARA 12/16/2020 $ 1,505.00
1900219070 102141728 FOSTER KAREN 12/16/2020 $ 915.00
1900219071 102141728 NEMEC KARLA 12/16/2020 $ 325.00
1900219072 102141728 MEEHAN KATHERINE 12/16/2020 $ 620.00
1900219073 102141728 FOWLKES KATRINA 12/16/2020 $ 325.00
1900219074 102141728 DAVIS KIMBERLY 12/16/2020 $ 915.00
1900219075 102141728 SMITH KORI 12/16/2020 $ 2,555.00
1900219076 102141728 ARAMAN MICHAEL 12/16/2020 $ 1,210.00
1900219077 102141728 BROWN MICHELLE 12/16/2020 $ 915.00
1900219078 102141728 MEHMOOD MOHSIN 12/16/2020 $ 1,505.00
1900219079 102141728 ENGLISH PATRICIA 12/16/2020 $ 325.00
1900219080 102141728 GIBSON PATRICIA 12/16/2020 $ 1,800.00
1900219081 102141728 EZE PAULINE 12/16/2020 $ 1,505.00
1900219082 102141728 BOX PAULINE 12/16/2020 $ 1,505.00
1900219083 102141728 EDOHO-EKET RACHEL 12/16/2020 $ 325.00
1900219084 102141728 THUR REBECCA 12/16/2020 $ 1,265.00
1900219085 102141728 LAWRENCE ROBERTA 12/16/2020 $ 1,577.00
1900219086 102141728 JONES SHANNON 12/16/2020 $ 325.00
1900219087 102141728 ANDERSON SHARONLEE 12/16/2020 $ 998.00
1900219088 102141728 CLOUD SHERELLE 12/16/2020 $ 1,210.00
1900219089 102141728 CARRINGTON SHIRLETIA 12/16/2020 $ 1,505.00
1900219090 102141728 DANIELS SONTIA 12/16/2020 $ 325.00
1900219091 102141728 GAYMON TIA 12/16/2020 $ 620.00
1900219092 102141728 SION TIFFANY 12/16/2020 $ 325.00
1900219093 102141728 OPARINDE TOLULOPE 12/16/2020 $ 325.00
1900219094 102141728 DULA TRACI 12/16/2020 $ 915.00
1900219095 102141728 PATEL VANLILABEN 12/16/2020 $ 915.00
1900219097 102141728 CASILLAS VERGIN IA 12/16/2020 $ 915.00
1900219098 102141728 COLEY VIOLET 12/16/2020 $ 1,505.00
102137545 102186253 VENERABLE, DEVEON 12/18/2020 $ 930.10
102137545 102186253 MADDEN, VERNETTA 12/18/2020 $ 941.00
102137545 102186253 EVANS, MATIHEW 12/18/2020 $ 241.14
102137545 102186253 COMEGYS, CATHERINE 12/18/2020 $ 906.49
102148247 N/A FULTON,SHARON 12/29/2020 $ 60.34
102148247 N/A FULTON,SHARON 12/29/2020 $ 258.04
102148247 N/A LAVINE,DEBORAH 12/29/2020 $ 60.76
102148247 N/A LAVINE,DEBORAH 12/29/2020 $ 259.78
102148247 N/A RIVERS,PAUL 12/29/2020 $ 92.22
102148247 N/A RIVERS,PAUL 12/29/2020 $ 394.32
102148247 N/A SMITH,KORI 12/29/2020 $ 74.10
102148247 N/A SMITH,KORI 12/29/2020 $ 316.82
102148247 N/A ROHR,CINDY 12/29/2020 $ 57.34
102148247 N/A ROHR,CINDY 12/29/2020 $ 245.14
102148247 N/A JACOB,ERIK 12/29/2020 $ 65.48
102148247 N/A JACOB,ERIK 12/29/2020 $ 279.96
102148247 N/A DOYLE,RAYMOND 12/29/2020 $ 56.98
102148247 N/A DOYLE, RAYMOND 12/29/2020 $ 243.66
102148247 N/A COHEN,DANIELLE 12/29/2020 $ 69.00
102148247 N/A COHEN,DANIELLE 12/29/2020 $ 295.00
JA206
102148247 N/A CITRO,DEIRDRE 12/29/2020 $ 55.48

102148247 N/A CITRO,DEIRORE 12/29/2020 $ 237.22
102148247 N/A JACOB,KAREN 12/29/2020 $ 89.04
102148247 N/A JACOB,KAREN 12/29/2020 $ 380.68
102148247 N/A KRUEGER,MICHAEL 12/29/2020 $ 60.90
102148247 N/A KRUEGER,MICHAEL 12/29/2020 $ 260.40
102148247 N/A LIBERATORE,STEPHEN 12/29/2020 $ 71.22
102148247 N/A LIBERATORE,STEPHEN 12/29/2020 $ 304.54
102148247 N/A KING,BRUCE 12/29/2020 $ 61.78
102148247 N/A KING,BRUCE 12/29/2020 $ 264.12
102148247 N/A TIFFANY,TONYA 12/29/2020 $ 59.74
102148247 N/A TIFFANY,TONYA 12/29/2020 $ 255.44
102148247 N/A GRAHAM,BEVERLY 12/29/2020 $ 60.76
102148247 N/A GRAHAM,BEVERLY 12/29/2020 $ 259.78
102148247 N/A FEINBERG,NEAL 12/29/2020 $ 60.76
102148247 N/A FEINBERG,NEAL 12/29/2020 $ 259.78
102148247 N/A JOHNSON,JENNIFER 12/29/2020 $ 92.22
102148247 N/A JOHNSON,JENNIFER 12/29/2020 $ 394.32
102148247 N/A BOWER,JEFFREY 12/29/2020 $ 63.94
102148247 N/A BOWER,JEFFREY 12/29/2020 $ 273.42
102148247 N/A ROBINSON,JANET 12/29/2020 $ 60.76
102148247 N/A ROBINSON,JANET 12/29/2020 $ 259.78
102148247 N/A ZINNER,DAVID 12/29/2020 $ 62.52
102148247 N/A ZINNER,DAVID 12/29/2020 $ 267.34
102148247 N/A ELLETSON,LARRY 12/29/2020 $ 65.54
102148247 N/A ELLETSON,LARRY 12/29/2020 $ 280.24
102148247 N/A PINOS,NAPOLEON 12/29/2020 $ 82.08
102148247 N/A PINOS,NAPOLEON 12/29/2020 $ 350.92
102148247 N/A RIDGEWAY,JACK 12/29/2020 $ 67.59
102148247 N/A RIDGEWAY,JACK 12/29/2020 $ 289.03
102177421 102142967 HENDLEY,KELLIE A 12/31/2020 $ 325.00
102177421 102142967 HENDLEY,KELLIE A 12/31/2020 $ 4.71
102177421 102142967 HENDLEY,KELLIE A 12/31/2020 $ 20.15
102177421 102142967 KELLY,ROBERTA I 12/31/2020 $ 1,910.00
102177421 102142967 KELLY,ROBERTA I fl.',,,,, 12/31/2020 $ 27.70
102177421 102142967 KELLY,ROBERTA I ,.f 1. 1 )~ 12/31/2020 $ 118.42
102177421 102142967 LIBERATORE,FAYE / , I I ,t·~ l. • I 12/31/2020 $ 2,456.00
,
102177421 102142967 LIBERATORE,FAYE :\_ ... ~ ' a' ! V ,J# f 12/31/2020 $ 35.61
102177421
102177421
102177421
102142967
102142967
102142967
LIBERATORE,FAYE
THEWES,DONNA K I ..., n/1''~ ~
THEWES,DONNA K I ~ . ,,1
~-
: 1ir- I'' 'r/ , ~' . r~
/ ,, r ,.'/" 12/31/2020
I - .,t,,•.
12/31/2020
12/31/2020
$
$
$
152.27
326.92
4.74
102177421 102142967 THEWES,DONNA K ~ ,;• . iJI'/
102177421
102177421
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BALCERZAK,AN N
BALCERZAK,AN N
"
(/., ii, /
I\ , ,/ /
12/31/2020
12/31/2020
12/31/2020
$
$
$
20.27
250.00
3.63
I,
102177421 102142967 BALCERZAK,ANN 12/31/2020 $ 15.50
102177421 102142967 RANKIN,RAYMOND 12/31/2020 $ 250.00
102177421 102142967 RANKIN,RAYMOND 12/31/2020 $ 3.63
102177421 102142967 RANKIN,RAYMOND 12/31/2020 $ 15.50
102177421 102142967 MCDANIEL,HOLLY K 12/31/2020 $ 620.00
102177421 102142967 MCDANIEL,HOLLY K / 12/31/2020 $ 8.99
102177421 102142967 MCDANIEL,HOLLY K , k:"' I 12/31/2020 $ 38.44
102177421 102142967 SAYERS,MARGERY ,\I ., ' ,{ 12/31/2020 325.00
102177421 102142967 SAYERS,MARGERY
/
,.,
- {'-.,' ~ /" 12/31/2020
$
$ 4.71
102177421 102142967 SAYERS,MARGERY - ~ f I '·,,.,j-;I' 12/31/2020 $ 20.15
102177421 102142967 JEFFERS,EDDIE B ')' . . l)· 12/31/2020 $ 915.00
,/ ,,
. ~ .f />
102177421
102177421
102177421
102142967
102142967
102142967
JEFFERS,EDDIE B
JEFFERS,EDDIE B
BUTLER,DIANE L l
'.I'' . .-.
. ('- I ,
. L, /
12/31/2020
12/31/2020
12/31/2020
$
$
$
13.27
56.73
250.00
102177421 102142967 BUTLER,DIANE L I h'\)' 12/31/2020 $ 3.63
102177421 102142967 BUTLER,DIANE L I I 12/31/2020 $ 15.50
102177421 102142967 CUNNINGHAM, DEVON 12/31/2020 $ 325.00
102177421 102142967 CUNNINGHAM, DEVON 12/31/2020 $ 4.71
102177421 102142967 ROJUGBOKAN, ALYCE ELIZABETH 12/31/2020 $ 1,800.00
102177421 102142967 ROJUGBOKAN, ALYCE ELIZABETH 12/31/2020 $ 26.10
102177421 102142967 ROJUGBOKAN, ALYCE ELIZABETH 12/31/2020 $ 111.60
JA207
102177421 102142967 SCALZO,LINDA M 12/31/2020 $ 1,441.00

102177421 102142967 SCALZO,LINDA M 12/31/2020 $ 20.89
102177421 102142967 SCALZO.LINDA M 12/31/2020 $ 89.34
102177421 102142967 MADDEN,VERNITTA 12/31/2020 $ 2,095.00
102177421 102142967 MADDEN,VERNITTA 12/31/2020 $ 30.38
102177421 102142967 MADDEN,VERNITTA 12/31/2020 $ 129.89
102177421 102142967 MICHELS COMEGYS, CATHERINE A 12/31/2020 s 1,210.00
102177421 102142967 MICHELS COMEGYS, CATHERINE A 12/31/2020 $ 17.55
102177421 102142967 MICHELS COMEGYS, CATHERINE A 12/31/2020 s 75.02
102177421 102142967 KEEHNER,DOROTHY 12/31/2020 $ 2,720.00
102177421 102142967 KEEHNER,DOROTHY 12/31/2020 s 39.44
102177421 102142967 KEEHNER,DOROTHY 12/31/2020 $ 168.64
102177421 102142967 WEIST,DENISE L 12/31/2020 s 1,080.00
102177421 102142967 WEIST,DENISE L 12/31/2020 $ 15.66
102177421 102142967 WEIST,DENISE L 12/31/2020 s 66.96
102177421 102142967 WILL.MICHAEL A 12/31/2020 $ 325.00
102177421 102142967 WILL,MICHAEL A 12/31/2020 s 4.71
102177421 102142967 WILL,MICHAEL A 12/31/2020 s 20.15
Total $ 688,226.00
JA208
f=: 'I llli b ti- +f- (c
' • •. ,.· - ~ - ' "" , ·· . • • ,,.-, . .:, ' , •. •- ,, . ,· "'' _i c~~
HOW THE BALLOTS WILL BE DELIVERED
COUNTY
AGENT FAXED IN PERSON MAILED OTHERS WEB DELIVERY TOTAL
Allegany 2 0 178 3,569 1 228 3,978

Anne Arundel 8 6 302 41,191 3 6,544 48,054
Pg: 218 of 482
Baltimore City 1 7 18 43,877 0 5,835 49,738

Baltimore County 6 15 31 64,205 4 8,147 72,408
Calvert 2 0 27 7,630 0 914 8,573
Caroline 0 1 7 1,166 0 74 1,248
Carroll 1 2 33 12,497 1 1,486 14,020
.Cecil 1 0 16 5,211 0 549 5,777
Charles 0 3 20 10,542 1 1,239 11,805
Filed: 07/31/2023
Dorchester 7 0 30 1,858 1 98 1,994
JA209
Frederick 1 4 36 20,681 0 2,733 23,455
Garrell 4 0 26 1,512 1 97 1,640
Harford 3 2 53 15,835 1 1,823 17,717
Howard 17 0 107 26,849 1 4,727 31,701
Kent 1 0 12 1,578 0 138 1,729
Montgomery 28 10 1,129 96,349 12 17,942 115,470
Prince George's 32 5 402 57,923 1 6,950 65,313
Queen Anne's 3 0 7 3,142 0 341 3,493
Saint Mary's 6 0 177 6,366 0 753 7,302
Doc: 44
Somerset 0 0 3 935 0 42 980

Talbot 3 3 38 2,991 0 346 3,381
Washington 2 0 39 7,750 0 596 8,387
Wicomico 11 0 59 5,286 0 434 5,790
USCA4 Appeal: 23-1369
Worcester 1 0 4 3,763 0 303 4,071

TOTAL 140 58 2,754 442,706 27 62,339 508,024
Mail-in Ballot R
Election: 202o Presi:e~~:sts by County
c:'
I- '(._ trJ I
.
fJ /,f :#:: 7
As of· No General Election
. vember 3, 2020
HOW THE BALLOTS WILL BE DELIVERED Ballot Delivery Method
COUNTY
AGENT FAXED IN PERSON MAILED WEB DELIVERY TOTAL - WEB DELIVERY

Allegany 129 4 393 8,867 529 9,922 L,J MAILED
- IN PERSON
Anne Arundel 157 24 959 145,325 17,616 164,081
Pg: 219 of 482
- FAXED
Baltimore City 4 25 473 144,490 14,293 159,285 AGENT
Baltimore County 229 47 1,109 212,293 22,477 236,155
Calvert 56 0 625 19,988 1,865 22,534
Caroline 3 2 21 3,893 287 4,206
Carroll 26 20 143 35,758 3,175 39,122 0 20 40 60 80 100
Cecil 0 0 174 14,391 1,459 16,024
Allegany i;..
- __ , •.. _
Charles 36 28 106 40,695 4,298 45,163 Anne Arundel
Filed: 07/31/2023
M - ·
Baltimore City _ _ ___ _ __ _
Dorchester 47 0 147 4,843 300 5,337
Baltimore County IMm ·0
JA210
Frederick 73 8 212 62,217 6,535 69,045 Calvert i;;:' _ -~ ~ --~- A
Garrell 16 0 93 3,668 281 4,058 Caroline ""
Carroll
Harford 73 7 990 48,965 4,886 54,921 Cecil !iii. - - - - 11~ - - - ···
Howard 67 6 345 95,201 12,294 107,913 Charles l:'=J _ ...YI
Dorchester ,,,.... - •·
Kent 2 0 42 3,992 287 4,323 Frederick
Montgomery 339 62 3,990 332,796 41,226 378,413 Garrett "" . ,
Harford _ _ .~9 ___ .... I
Prince George's 487 2 3,208 240,519 24,435 268,651 Howard _ 88 _ __
Queen Anne's 11 7 82 8,988 962 10,050 Kent
Montgomery --="92- --.:-.-
Bf . .::=...:;..'"00"
.1
Doc: 44
Saint Mary's 35 1 2,283 19,654 1,840 23,813 Prince George's 90 1

Somerset 2 0 18 2,641 148 2,809 Queen Anne's .-.- _ - 8~ . - . 1 ..
Talbot 28 2 300 8,554 832 9,716
Saint Mary's 83 a
Somerset ·94 - - - _:
Washington 98 1 219 22,335 1,803 24,456 Talbot 88 --.- ,~oJ
Washington - · --- - '
Wicomico 45 2 377 15,502 1,229 17,155
Wicomico :Jm ""
v,
Worcester 12 0 36 10,430 850 11,328 Worcester ~ :_.......-~n'"'............._.,._.. , ,
TOTAL 1,975 248 16,345 1,506,005 163,907 1,688,480
Exhibit #8 - Verification of Harford County Canvas of 2020 Presidential General Election

Canvas performed from December 2021 through February 2022
Attached Press Release - June 2022
I hereby declare under penalties of perjury that the attached document is an authentic document and
is true and correct to the best of my present knowledge, information, and belief. I am a citizen of the
United States of America and over 18 years of age and therefore qualified to make this declaration
under oath.
Dale E. Livingston
David Kane
Janis Katsu
Kathy McGill
Dawn Villani
Christina Trotta-Pecora
Michelle Willoughby
Mary Ellen Clancy
Michele Murray
Karen (Kay) Novak
Sandy Duncan
Bill Love
David Tritt
David Morsberger
William Martino
Yvette Martino
Michael Fletcher
JA211
PRESS RELEASE
MEDIA CONTACT: Dave Tritt

443-752-2082
freestatelibertyaction@gmail.com
WE THE PEOPLE of Harford County Find Voters in 52 Empty/ Abandoned Addresses

Among Other Anomalies
Harford county- For Immediate Release: Based on the findings of numerous voting anomalies discovered during
an independent investigation by WE THE PEOPLE of Harford County and the Maryland Voter Integrity Group, it is
essential that before the July 2022 primary the county voting rolls are updated by the removal of voters who are
deceased, have moved to another county/state or have been inactive for two general elections.
During the independent review, the groups investigated 1,509 addresses. Of those, 442 were amenable to
answering questions regarding voting in the 2020 presidential election. As a result, 277 anomalies were discovered
as follows:
* 52 addresses were empty or abandoned property- 3.4%

* 151 voters had moved - 5.20%
* 15 people were unknown to the residents - 5.16% (phantom registrations)
* 4 addresses were businesses, not residences
* 1 non-citizen who voted
* 8 voters were deceased
* 6 voters did not appear on the voter information we had for those residences
• l1 voters live out of State
* 19 voters did not live here in 2020
* 7 voters voted elsewhere
* 3 residences received ballots for people who did not live there
"Especially important to note are the 151 voters who no longer lived at the addresses provided as they have
moved and the 52 abandoned properties that had recorded votes from those locations although all of these
anomalies shall not be tolerated or ignored. It is vital that the election boards clean up out voter rolls in effort to
maintain the integrity of our elections. The voters of Harford County and throughout Maryland deserve no less/'
said Robyn Sachs, Chait of the Maryland Voter Integrity Group.
This maintenance process Is required under federal and Maryland law. Election security should always be a top
priority. Accurate and up-to-date voter rolls are vital to secure elections, and voters should have the opportunity
to update their information. Accurate voter rolls ensure a smooth process at the polls and helps with costs as clean
and up·to·date information gives the county election board a better idea of how many ballots will be needed,
staffing, etc.
Additionally, "Mail in Ballotsll should be limited to the elderly, infirmed and military. As well we request a
requirement to show ID to vote. These organizations implore the Harford County Democrat Central Committee to
join in this effort to keep our voter rolls updated.
## END of RELEASE##
JA212

Allison W. McCord, President
Joseph N. Price, Vke President
Stephanie L. Taylor James C. Richardson, Secretary
Director Michael A. Dykes, Member
Vacant, Member
Kimberley H. Slusar
Deputy Director Brian K. Young, Es q., Board Counsel
May 26, 2022
Dawn Villani for We the People,
This letter is in response to the document that Janis Katsu you dropped off at our office on May 9, 2022.
I am going to list out your requests and address them individually.
1. Request of the ballot images from the 2020 Presidential General Election form tabulators used
at all Early Voting sites, all Election Day precincts, and tabulators used to tabulate all mail-in
ballots.
These images have been uploaded to Microsoft OneDrive and are available for
download until Friday June 17, 2022 . The images can be
found !ill.Rs://marylandstateboard-
my.sharepoint.com/personal/traceye hartman elections maryland gov/ Jayouts/15/onedrive.
aspx?id=%2Fpersonal%2Ftraceye%5Fhartman%5Felections%5Fmaryland%5Fgov%2FDocuments
%2Fmd%5F13%5Fharford%5F2020pg%2Ezip&parent=%2Fpersonal%2Ftraceye%5Fhartman%5Fe
lections%5Fmaryland%5Fgov%2FDocuments&ga=1 . If you have trouble viewing the ballot
images from the link , please contact Tracey Hartman with the Maryland State Board of
Elections at traceye.hartman@rnaryland.gov.
2. Request for a copy of the following reports from ClearBallot- Comparison of Votes Cast report,
the Comparison Ballots Cast with Precincts report, the Comparison of Cards Cast report.
You can access these report through this link -

https://elections.maryland.gov/voting system/ballot audit plan automated .html
3. Request for video surveillance camera footage of all drop boxes used during the 2020
Presidential General Election during each Early Voting Day and location and also any drop boxes
used on Election Day.
We do not have the footage from the 2020 election. The cameras that were used did not have
the capability to retain the footage.
Drop box locations:

a. Harford County Board of Elections, 133 Industry Lane, Forest Hill, 21050
b. McFaul Activity Center, 525 W. MacPhail Road, Bel Air, 21014
c. Edgewood Rec Center, 1980 Brookside Drive, Edgewood, 21040
d. Jarrettsville Fire Hall, 3825 Federal Hill Rd, Jarrettsville, 21084
e. Aberdeen Activity Center, 7 Franklin Street, Aberdeen, 21001
133 INDUSTRY LANE, FOREST HILL, MD 21050 • PHONE 410-638-3565 • FAX 410.638.3310 • HYuser dial 711
• EMAIL elections@harfordcountyrnd.gov • WEB www.harfordvotes.gov
JA213
Case 1:22-cv-01642-SAG Document 9-11 Filed 08/20/22 Page

F,IJ~_C2 of BOA1'D
.JJQN 2
Allison W. McCord, President
Joseph N. Price, Vice Pres ident
Stepl1anle L. Taylor James C. Richardson, Secretary
Director Mtchael A. Dykes, Memb er
Vacant, Member
Kimberley H. Slusar
Deputy Director Brian K. Young, Esq., Board Counse l
Resp~
Stephanie Tayl~;-)
(
Director
c. Allison McCord, Board President
133 INDUSTRY LANE, FOREST HILL, MD 21050 • PHONE 410-638-3565 • FAX 410.638.3310 • TTY user dial 711
• EMAIL elections@harfordcountymd.gov • WEB www.harfordvotes.gov
JA214
Dr. Douglas G. Frank, President http ://too lsforanalysis. com/douglas .htm I

Evhlb/1 I CJ
Expert
Consultation
[ Home ] [ Consultation ] [ Laser Micror-robes ] [ Force A1:mlicators ] [ Bowling Devices ] [ Friends of
PAI ] [ Contact Us ]
Douglas G.
Frank, Ph.D.
Doug@ToolsForAnalxsis.com
Education
Dr. Frank
received a B .A.
in Chemistry
from Westmont
College in
Santa
California. He
qualified for his
doctorate at the
University of
California, Santa
Barbara before
transferring to the
University of Cincinnati in 1986 as part of the Ohio Eminent Scholar program.
In 1990, he received a Ph.D. in Surface Analytical Chemistry. After graduating,
he formed "ADAM Instrument Company, Inc.," named for the new surface
analysis technique he discovered during his graduate studies. The "ADAM"
technique brought him international acclaim, and his work was featured in
1 of 4 8/17/2022, 7:06 AM
JA215
Dr. Douglas G. Frank, President http://toolsforanalysis.com/ douglas .htm I

several scientific books and international journals, including cover articles in
Science and Naturwissenschaften. He has over 50 scientific publications, and is
internationally regarded as an expert in Auger spectroscopy.
Corporate Consulting - Research & Development

Dr. Frank's scientific reputation gained him introductions to several U.S.
companies, where he learned to apply his scientific and computer expertise to
real-life research and development challenges. He specializes in the development
of custom control and analytical solutions, and has invented several instruments
for surface OP-tical characterization, P-recision force aP-P-lication, and soil analysis
by means of portable electron microscopy and spectroscopy.
Corporate Consulting - Systems Integration and

Automation
Dr. Frank's scientific, electronic, instrumental, and software expertise make him
an asset in situations requiring systems integration. His combination of skills
makes him especially suited for the preparation and development of 'intelligent'
user-friendly software that allows straightforward operation and control in
complicated manufacturing and analytical environments. Sometimes, he is
retained to provide only the intelligent software 'glue' that holds an integrated
system together. Other times, the broader resources of PAI are brought to bear,
allowing a prototype design and development solution to be expedited.
Some recent consulting projects include:

• Precision motion control and integration of multi-axis industrial
manufacturing devices;
• Design, manufacture, and construction of industrial research instruments;
• Design, manufacture, and integration of industrial quality control
instrumentation;
• Software integration of multiple devices for new analytical instrumentation;
• System design and software development for remote access to precision
motion control;
• Development and manufacturing of precision measurement devices and
layout tools for the bowling industry.
SELECTED BIBLIOGRAPHY
1. pH and Potential Dependence of the Electrical Double Layer at Well-Defined Electrode
Surfaces: Cs+ and Ca2+ at Pt(111)(2?3x2?3)R30°-CN-, Pt(111)(?13x?13)Rl4°-CN- and Pt(lll)
2 of4 8/17/2022, 7:06 AM
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Dr. Douglas G . Frank, President http://toolsforanalysis.com/douglas.html

(2x2)-SCN-. Douglas G. Frank, James Y. Katekaru, Stephen D. Rosasco, Ghaleb N. Salaita,
Bruce C. Schardt, Manuel P. Soriaga, Donald A. Stern, John L. Stickney and Arthur T. Hubbard,
Langmuir 1, 587 (1985).
2. Films Formed on Stainless Steel Single-Crystal Surfaces in Aqueous Solutions: Studies of the
(100) Plane by LEED, Auger Spectroscopy and Electrochemistry. Douglas G. Frank, Victor K. F.
Chia, Mark Schneider and ArthurT. Hubbard, Langmuir 3, 860 (1987).
3. Imaging Surface Atomic Structure by Means of Auger Electrons. Douglas G. Frank, Nikola
Batina, Teresa Golden, Frank Lu, and Arthur T. Hubbard, Science 247, 182 (1990).
4. Direct Imaging of Surface Atomic Structure by Angular Distribution Auger Microscopy
(ADAM): The Bare Pt(l 11) Surface. Douglas G. Frank, Nikola Batina, James W. McCargar and
Arthur T. Hubbard, Langmuir 5, 1141 (1989) .
5. Auger Emission Angular Distributions from a Silver Monolayer in the Presence and Absence
of an Iodine Overlayer: Evidence for the Predominance of Inhomogeneous Inelastic Scattering of
Auger Electrons by Atoms. Douglas G. Frank, Oliver M.R. Chyan, Teresa Golden and Arthur T.
Hubbard, J. Phys. Chem. 98, 1895 (1994).
6. Direct Imaging of Epitaxial Layers by Angular Distribution Auger Microscopy. Douglas G.
Frank, Frank Lu, Teresa Golden and Arthur T. Hubbard, Mater. Res. Soc. Bull. 15, 19 (1990).
7. Imaging Surface Atomic Layers by Means of Auger Electrons (cover article). Nikola Batina,
Oliver M. R. Chyan, Douglas G. Frank, Teresa Golden and Arthur T. Hubbard,
Naturwissenschaften 77, 557 (1990).
8. Direct Imaging of Thin Film Atomic Structure by Angular Distribution Auger Microscopy
(ADAM). Douglas G. Frank, Teresa Golden, Oliver M.R. Chyan and Arthur T. Hubbard,
Proceedings of the 5th International Conference on Solid Films and Surfaces, Applied Surface
Science 48/49, 166 (1991).
9. Imaging Monolayer Structure by Means of Auger Electrons. Douglas G. Frank, Oliver M. R.
Chyan, Teresa Golden and Arthur T. Hubbard, J. Vac. Sci. Technol. AlO, 158 (1992).
10. Auger Electron Angular Distributions from Al(l 00): Resolution of an Apparent
Contradiction. Oliver. M.R. Chyan, Douglas G. Frank, Charles A. Doyle and Arthur T. Hubbard,
J. Vac. Sci. Technol. All, 2659 (1993).
11. Angular Distribution Auger Microscopy. Douglas G. Frank and Arthur T. Hubbard, in the
"Concise Encyclopedia of Materials Characterization", R.W. Cahn, Ed. (Pergamon Press, Oxford,
1993), p. 34.
12. Auger Electron Angular Distributions from Pt(l 11): The Effect of Adsorbed Iodine
Monolayers. Charles A. Doyle, Oliver M. R. Chyan, Douglas G. Frank and Arthur T. Hubbard,
Surf. Int. Anal. 21, 123 (1994).
13. Electrode Reactions of Well-Characterized Adsorbed Molecules. Curtis Shannon, Douglas G.
Frank, and Arthur T. Hubbard, Ann. Revs. Phys. Chem. 42,393 (1991).
14. Probing Three Distinct Iodine Mono layer Structures at Pt(l 11) by Means of Angular
Distribution Auger Microscopy (ADAM): Results Agree with Scanning Tunneling Microscopy.
Douglas G. Frank, Oliver M.R. Chyan, Teresa Golden and Arthur T. Hubbard, J. Phys. Chem. 97,
3829 (1993).
15. Angle-Resolved Auger Electron Spectroscopy. Douglas G. Frank in The Handbook of
Surface Imaging and Visualization, A. T. Hubbard, Ed. (CRC Press, 1996).
16. LEED Pattern Directory. Douglas G. Frank in The Handbook of Surface Imaging and
Visualization, A. T. Hubbard, Ed. (CRC Press, 1996).
17. Comparison of an Electron-Atom-Scattering Description with Gas-Phase Scattering Data for
He, Ne, Ar, Kr, and Xe. Douglas G. Frank and Arthur T. Hubbard, J. Phys. Chem. A 101, 894
(1997).
[ Home ] [ Consultation ] [ Laser Micro2robes ] [ Force Ai:;mlicators ] [ Bowling Devices ] [ Friends of
3 of 4 8/17/2022, 7:06 AM
JA217
Dr. Douglas G. Frank, President http://toolsforanalysis.com/ douglas .html

PAI ] [ Contact Us ]
©2009 Precision Analytical Instruments, Inc.

Revised 1/5/2009
4 of 4 8/17/2022, 7:06 AM
JA218
EXHIBIT # 10 A
Description of the Specificity Requirements of Both the Rico Statute, and the
Common Law Requirements of the Elements of Fraud under Federal Law and the
Maryland Common Law Definitions. (Emphasis Added, highlighting where relevant.
109. RICO Charges (Per Internet, From Department of Justice Archives)
“It is unlawful for anyone employed by or associated with any enterprise engaged in, or the
activities of which affect, interstate or foreign commerce, to conduct or participate, directly or
indirectly, in the conduct of such enterprise's affairs through a pattern of racketeering activity or
collection of unlawful debt. 18 U.S.C.A. § 1962(c) (West 1984). The Racketeer Influenced and
Corrupt Organization Act (RICO) was passed by Congress with the declared purpose of seeking
to eradicate organized crime in the United States. Russello v. United States, 464 U.S. 16, 26-27,
104 S. Ct. 296, 302-303, 78 L. Ed. 2d 17 (1983); United States v. Turkette, 452 U.S. 576, 589,
101 S. Ct. 2524, 2532, 69 L. Ed. 2d 246 (1981). A violation of Section 1962(c), requires (1)
conduct (2) of an enterprise (3) through a pattern (4) of racketeering activity. Sedima, S.P.R.L. v.
Imrex Co., 473 U.S. 479, 496, 105 S. Ct. 3275, 3285, 87 L. Ed. 2d 346 (1985).
A more expansive view holds that in order to be found guilty of violating the RICO statute, the
government must prove beyond a reasonable doubt: (1) that an enterprise existed; (2) that the
enterprise affected interstate commerce; (3) that the defendant was associated with or employed
by the enterprise; (4) that the defendant engaged in a pattern of racketeering activity; and (5) that
the defendant conducted or participated in the conduct of the enterprise through that pattern of
racketeering activity through the commission of at least two acts of racketeering activity as set
forth in the indictment. United States v. Phillips, 664 F. 2d 971, 1011 (5th Cir. Unit B Dec.
1981), cert. denied, 457 U.S. 1136, 102 S. Ct. 1265, 73 L. Ed. 2d 1354 (1982).
An "enterprise" is defined as including any individual, partnership, corporation, association, or

other legal entity, and any union or group of individuals associated in fact although not a legal
entity. 18 U.S.C.A. § 1961(4) (West 1984). Many courts have noted that Congress mandated a
liberal construction of the RICO statute in order to effectuate its remedial purposes by holding
that the term "enterprise" has an expansive statutory definition. United States v. Delano, 825 F.
Supp. 534, 538-39 (W.D.N.Y. 1993), aff'd in part, rev'd in part, 55 F. 3d 720 (2d Cir. 1995),
cases cited therein.
"Pattern of racketeering activity" requires at least two acts of racketeering activity committed
within ten years of each other. 18 U.S.C.A. § 1961(5) (West 1984). Congress intended a fairly
flexible concept of a pattern in mind. H.J., Inc. v. Northwestern Bell Tel. Co., 492 U.S. 229, 239,
109 S. Ct. 2893, 2900, 106 L. Ed. 2d 195 (1989). The government must show that the
racketeering predicates are related, and that they amount to or pose a threat of continued criminal
activity. Id. Racketeering predicates are related if they have the same or similar purposes, results,
participants, victims, or methods of commission, or otherwise are interrelated by distinguishing
characteristics and are not isolated events. Id. at 240, 109 S. Ct. at 2901; Ticor Title Ins. Co. v.
Florida, 937 F. 2d 447, 450 (9th Cir. 1991). Furthermore, the degree in which these factors
JA219
establish a pattern may depend on the degree of proximity, or any similarities in goals or
methodology, or the number of repetitions. United States v. Indelicato, 865 F. 2d 1370, 1382 (2d
Cir.), cert. denied, 493 U.S. 811, 110 S. Ct. 56, 107 L. Ed. 2d 24 (1989).
Continuity refers either to a closed period of repeated conduct, or to past conduct that by its
nature projects into the future with a threat of repetition. H.J., Inc., 492 U.S. at 241-42, 109 S. Ct.
at 2902. A party alleging a RICO violation may demonstrate continuity over a closed period by
proving a series of related predicates extending over a substantial period of time. Id. Predicate
acts extending over a few weeks or months and threatening no future criminal conduct do not
satisfy this requirement as Congress was concerned with RICO in long-term criminal conduct. Id.
As to the continuity requirement, the government may show that the racketeering acts found to
have been committed pose a threat of continued racketeering activity by proving: (1) that the acts
are part of a long-term association that exists for criminal purposes, or (2) that they are a regular
way of conducting the defendant's ongoing legitimate business, or (3) that they are a regular way
of conducting or participating in an ongoing and legitimate enterprise. Id.
When a RICO action is brought before continuity can be established, then liability depends on
whether the threat of continuity is demonstrated. Id. However, Judge Scalia wrote in his
concurring opinion that it would be absurd to say that "at least a few months of racketeering
activity. . .is generally for free, as far as RICO is concerned." Id. at 254, 109 S. Ct. at 2908.
Therefore, if the predicate acts involve a distinct threat of long-term racketeering activity, either
implicit or explicit, a RICO pattern is established. Id. at 242, 109 S. Ct. at 2902.
The RICO statute expressly states that it is unlawful for any person to conspire to violate any of
the subsections of 18 U.S.C.A. § 1962. The government need not prove that the defendant agreed
with every other conspirator, knew all of the other conspirators, or had full knowledge of all the
details of the conspiracy. Delano, 825 F. Supp. at 542. All that must be shown is: (1) that the
defendant agreed to commit the substantive racketeering offense through agreeing to participate
in two racketeering acts; (2) that he knew the general status of the conspiracy; and (3) that he
knew the conspiracy extended beyond his individual role. United States v. Rastelli, 870 F. 2d
822, 828 (2d Cir.), cert. denied, 493 U.S. 982, 110 S. Ct. 515, 107 L. Ed. 2d 516 (1989).”
JA220
EXHIBIT # 10 B
In, Boyle v. United States, 556 U.S. 938 (2009), the Supreme Court ruled, inter alia:
“Held:
1. An association-in-fact enterprise under RICO must have a "structure," but the pertinent jury
instruction need not be framed in the precise language Boyle proposes, i.e., as having "an
ascertainable structure beyond that inherent in the pattern of racketeering activity in which it
engages." Pp. 4-12.
(a) In light of RICO's broad statement that an enterprise "includes any ... group of
individuals associated in fact although not a legal entity," §1961(4), and the requirement that
RICO be "liberally construed to effectuate its remedial purposes," note following §1961, Turkette
explained that "enterprise" reaches "a group of persons associated together for a common
purpose of engaging in a course of conduct," 452 U. S., at 583, and "is proved by evidence of an
ongoing organization, formal or informal, and by evidence that the various associates function as
a continuing unit." Ibid. Pp. 4-5.
(b) The question presented by this case is whether an association-in-fact enterprise must
have "an ascertainable structure beyond that inherent in the pattern of racketeering activity in
which it engages." Pet. for Cert. i. This question can be broken into three parts. First, the
enterprise must have a "structure" that, under RICO's terms, has at least three features: a purpose,
relationships among the associates, and longevity sufficient to permit the associates to pursue the
enterprise's purpose. See Turkette, 452 U. S., at 583. The instructions need not actually use the
term "structure," however, so long as the relevant point's substance is adequately expressed.
Second, because a jury must find the existence of elements of a crime beyond a reasonable doubt,
requiring a jury to find the existence of a structure that is ascertainable would be redundant and
potentially misleading. Third, the phrase "beyond that inherent in the pattern of racketeering
activity" is correctly interpreted to mean that the enterprise's existence is a separate element that
must be proved, not that such existence may never be inferred from the evidence showing that
the associates engaged in a pattern of racketeering activity. See ibid. Pp. 6-8”. ...
JA221

________ __
Lois Ann Gibson, et al, Frederick, Maryland, and Maryland )
20-20 Watch, a Maryland unincorporated association, )
for themselves and as class representatives, for all others )
similarly situated, civil rights deprived and/or injured )
persons, in whatever state or County they ) Case No. GLR-22-1642
reside, class members in this RICO Multi-District )
Rule 23 Class Litigation )
)
PLAINTIFFS )
)
V. )
)
The State of Maryland, And Several Agencies of the )
State of Maryland, et al, including )
the Maryland State Prosecutor, )
and )
presently unknown )
Others in Unknown Locations )
and )
An Unnamed and Unidentified, Rico Enterprise Located )
in Maryland and/Chicago, and Elsewhere in the United )
States, defendant Center for Tech and Civic Life (CTCL )
)
DEFENDANTS )
)
MOTION FOR A TEMPORARY RESTRAINING ORDER,

PRELIMINARY INJUNCTION
AND ACCELERATION OF TRIAL ON THE MERITS
-------------------------
AND SEPARATE
-i-
JA222
MOTION TO ACCEPT THIS CASE AS A MULTI-DISTRICT

LIGATION CASE BECAUSE OF MANY HUNDREDS OF
SIMILARLY SITUATED VOTING CONSPIRACY CASES
AND
THE NATIONWIDE EFFECTS OF THE RICO ALLEGED

FRAUD RESULTING FROM AND BASED UPON
NINE OR MORE VIRTUALLY IDENTICAL FRAUDULENT
===========================
ACTIVITIES,
SOME OR ALL OF WHICH MEET THE RICO ACT
DEFINITIONS OF RICO CRIMINAL ACTS
CREATING IMMEDIATE AND IRREPARABLE HARM
===========================
RELIEF REQUESTED
(PURSUANT TO FEDERAL RULE OF CIVIL PROCEDURE 65
(a)(d) AND (e), BECAUSE OF THE VIRTUAL CERTAINTY OF
IMMEDIATE AND IRREPARABLE HARM
AND CONTRARY-WISE
NO HARM AT ALL IN THE EVENT OF FINDING OF THE
DEFENDANTS’ INNOCENCE OF WRONGDOING
i.e. THE RESULTS WOULD BE UNCHANGED
AND THE UPSET MINOR;
INVOCATION OF THE FEDERAL POWER OF THE COURTS
TO PRESERVE THE UNION SHOULD BE IMMEDIATE AND
MASSIVE CONTROL OF THE VOTER SUMMATION PROCESS
UNDER CONTROL OF FEDERAL MASTERS AND U .S.
MARSHALS PURSUANT TO INSURRECTION PROCEDURES
AND CONSTITUTIONAL AUTHORITY)
=======================
-ii-
JA223
MOTION FOR A TEMPORARY RESTRAINING ORDER

AND PRELIMINARY INJUNCTION
I. SUMMARY OF THE SITUATION, II. THE RELIEF

REQUESTED, AND III. THE CURE:
I. SUMMARY OF THE CRUCIAL SITUATION:

A. Whether or not the “fix was in” in the current election depends upon facts not yet
available from observers of the present election. Certainly, the early calling of the votes,
based upon unsecured drop-box and mail ballots unverified counts raises a huge red flag.
Now, at 9:50 pm on election night, when voting closed at 8:00 pm and 2% of the votes
have been reported. and none of the “live” voting has been reported is hugely suspect for
the RICO fraud to be implicated. See RICO fraud observed in the Election of 2020,
declaration of eyewitness Gibson, to insecure non-surveillanced drop-box stuffing.
Exhibit 2.1 filed in this case July 4, 2022.
B. The Vote System in Maryland is Fatally Flawed, Easily Corrupted by Forgeries and
Cheating and lack of any meaningful data controls at all, and Must be Scrapped:
The system design of Maryland dominion machine type Voting system is fatally
flawed ab initio. The following listed defects are fatal to a reliable, audit-able and hack-
resistant system. The existing system used in Maryland in the current election, in each
instance, contains an inherent fatal flaw. That flaw is that the voter’s identification is
separated from the paper vote ballot (or electronic scan), or electronic image, or voter
historical record, This means that the chain of custody is nearly irrevocably lost for
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JA224
purposes of double-checking or audit, or fraud at the moment of separation. The chain of
custody is irrevocably broken.
Proof of the falsity and unreliability of system results were proven in past elections
in a very recent study made of incorrect claims of reliability by Linda Lamone,
Administrator of the Maryland Board of Elections Administrator on the most recent
previous elections. This analysis can be repeated and presented as trial evidence for the
current election in the event the District Court grants this motion for injunctive relief, and
Orders production of the relevant records, first for Maryland and along with that, results
of some of the systemic inaccuracies for the entire country.
C. Exhibit A attached is the letter of October 14, 2022 from Linda Lamonee, Esq,
administrator to citizen claiming accuracy of prior system results, and denying access to
Maryland voter records for verification and chain of custody purposes.
D. Exhibit B is a partial systemic comparison of move-in and move-out dates which
invalidate the accuracy of Maryland records over the last two election cycles. many
hundreds of logical impossibilities are disclosed. These errors refute the claims of Ms
Linda Lamone (Lamone) one way or another.
E. Either the logic impossibilities were undetected data errors, or they were
intentional. If intentional, a pattern of RICO transactions, to benefit a particular group of
voters occurred. In any event, if the same nation-wide pattern is disclosed as appears
likely from this partial sample intentional torqueing of election results has occurred, and
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JA225
will likely surface in the current data.
F. Conclusion:
In Any Event, the Loss or Non-existence of Chain of Custody

of Voter Validity for Each Vote Document, Electronic Image Is Fatal to Validity
As Well as Accountability for Vote Totals and Summaries.
Once the physical presence of the voter is separated from the vote ‘image in
process”, or the physical ballot from its envelope in a Mail-In situation, and all variations
of this even, the image in process is fair game for tampering, or nefarious conduct of all
kinds under the existing systems now in use in Maryland and many states. There is no
hope for salvaging the existing, control free, non audit-able system.
G. What must be done is to scrap the entire system, clean up the flawed data and
install up to the minute, banking type digital controls over voter records and on-line
verifiable by each voter as a permanent new record available at all times, even after the
vote, but secret to each voter and not the opposition data miners.
For the current crisis, this election must be subject to the old fashioned hand count
of paper ballots with criminal penalties imposed upon all forgers and manipulators
convicted of election and/or election fraud. A detailed listing of types of fraud now
known to have occurred in past elections:
(1) online connections and pre-programming of machine parameters render the machine
and all of its results subject to machine manipulation or predetermined results without any
possible controls by system managers or local political officials. This system is simply
-2-
JA226
subject to fraud by nefarious operators and even foreign hackers, or party control through
its own managers, at will. This vulnerability is even more so with the now well
established corruption of federal agencies, for example the FBI.
(2) the owners of the machines and renters of the machines are known foreign dominated
entities. Use of these suppliers by individual state audit committees is an axiomatic recipe
for disaster.
(3) no chain of custody over any vote or subsequent audit of vote results as possible
because of the inherent flaw in the system of removing by separation the envelopes with
the identification of the voter from the purported ballot its self.
(4) paper ballot chain of custody is also lost by the same separation of envelopes and
ballots when any person can request a ballot be sent to them by mail or even created by
himself from the Internet. From that point forward there is no possibility of verification of
whether this particular ballot is being submitted by a citizen, a non citizen or even was no
citizen at all as merely a trigger with a ballot count in the machine. In other words there is
no methodology possible to authenticate the results reported by an from a machine.
(5) witnesses and admissions from multiple counties are to the effect that drop boxes lack
any mechanism of effective surveillance as to the materials deposited therein. The result
is that there is no chain of custody at all for these materials and further missions have
been made to the effect that signatures are never challenged. Therefore in essence the
entire process coming from drop boxes which increase in usage contain nonexistent
-3-
JA227
controls over even the mere existence of any voter at all. One result is that throughout the
nation "over counts" exist where the number of votes counted exceed the number of
registered voters.
(6) Comparisons of Addresses contained in the “Moved Out of Maryland” dates with
“votes cast” voting dates and “deaths” and “votes cast” dates before move in dates are
expected to exceed the same number (thousands) in the previous election. Access to this
data for this election via subpoenas and 30(b)(6) depositions is requested.
(7) Monies paid for couriers and testimony regarding duties of election records,
paralleling Exhibit 7, 730 persons paid as couriers by CTCL is requested.
(8) the comparisons of the information in plaintiff's exhibit number two demonstrates
several thousand verified impossible valid votes (both before or after redicency expired in
Maryland), This is either wrong data (inaccuracies) or RICO, i.e. fraudulent voting. But
these thousands of instances cannot be valid votes. And the numbers will get larger when
more states are thus compared. situations with specifics arising from the last several
elections. This test needs to be made as to this election and all subsequent.
(9) accordingly, the Board of elections for Maryland and each other state utilizing the
same methodology should be required to authenticate using the comparison methodology
before any certification of any voting results anywhere in the country should be allowed
by relaxing the restrictions contained in the requested order of prohibition hereto and
herein.
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JA228
(10) All mail-in ballots which lack a chain of custody and signature verification, and
otherwise not verified must be stricken.
(11) It is imperative that Voter I.D. Numbers be kept associated with the on-line vote
images to forestall fake ballots, like any
II. RELIEF REQUESTED:
A. The court, and the Multi-District Panel is hereby requested via an identical version of
this Motion, pursuant to Section V. of the Federal Rules of Civil Procedure, and Federal
Code 28 U.S.C.A. § 1407, to issue a forthwith applicable temporary restraining order
(TRO) followed immediately with a Motion for a Preliminary Injunction applicable to all
of the many hundreds of civil actions now occurring1 and in process of preventing any
state agency from declaring a winner to any election, federal or state which is scheduled,
to occur on or after, November 8, 2022, until such time as the election process
verification, “assumed to be in the demonstrated presence of RICO fraud”, in any
applicable State, is concluded.
This assumption should begin with the state of Maryland because of well
established evidence of fraudulent activities now appearing in the record of this case in
Exhibits previously filed, and supplemented herein.
This presumption is required based upon just five Exhibits proffered as evidence,
1
See Exhibit 5, listing prepared about a week ago from available public sources.
-5-
JA229
until declared free of taint by the Federal Court.
Those Exhibits are:
1. Exhibit A. Linda Lamone’s refuted letter of October 14, 2022, declaring
incorrectly any credence or reliability refuted in its essence by Exhibit B, a listing
of Erroneous records, apparently attempts and alleged to be fraud and/or atempts at
unlawful ballot harvesting.
2. The whistleblower analysis of data errors filed with this Court on November 8th
, 2022. Exhibit # 2.
3. Exhibit # 5 in the initial filing in this case. Business records and an admission
of a party opponent, Howard County Maryland, list of persons who received
apparently tax free payments paid for by Chicago corporation, CTCL consisting of
about 730 different person couriers and other data harvesters or couriers, mostly in
even dollar values matching to the penny the contributions for political purposes of
CTCL to a donation of tax-free funds.
is declared free of taint or influence of the RICO enterprise found to exist at a
hearing on a preliminary injunction scheduled for that purpose.
4.The kinds and types of fraud admitted by President Biden and bragged about as it
was, and is, a very clever (and unlawful and unconstitutional) RICO vote fraud,
which occurred in the 2020 election process and is apparently being repeated
today.
-6-
JA230
5. Exhibit # 2.1 of the record of this case. Eyewitness testimony via declaration of
Lois A. Gibson, probative proffered evidence “Mule Activity” in stuffing of
unwatched and unmonitored drop-boxes in Frederick County Maryland.
B. The Court is requested to schedule a hearing on a preliminary injunction to be attended
by representatives of the Maryland State Board of elections to include, if not previously
contained in the record pursuant to these plaintiffs request to allow subpoenas duces
tecum and for F.R.Civ. P Rule 30(b)(6) depositions of the Maryland State Board of
Elections, its administrator Linda Lamone, Esq. and knowledgeable information
technology (IT) representatives.
C. Also, permission is requested to similarly depose pursuant to Rule30(b)(6)
knowledgeable executives and politicians of Howard County, Maryland.
D. Also, similarly, the most knowledgeable of the events described in this case,
representatives of CTCL most knowledgeable of the events in this case, the employees or
contractors of the Maryland State Board of elections who are most knowledgeable of the
content of all of the voter information and related information technology or database
files pertaining to Maryland voters, including retention schedules for information
received from other Maryland agencies or out of state information files acquired
regarding former or present or expected future Maryland voters.
E. (1) The Maryland State Board of elections within five days of the issuance of the TRO
by the United States District Court for the District of Maryland or other federal court shall
-7-
JA231
provide a detailed explanation for each of the instances identified in plaintiff's exhibit a to
this motion for temporary restraining order and preliminary injunction as to any
explanation or cause identified by the Maryland State Board explaining the apparent error
identified by that listing in exhibit a, the cause of the error, the identification of the person
committing the error, if other than a routine data error, and in which such results from a
routine data error i.e. data entry or the like, the frequency of such errors and what has
been done if anything to excise such errors in the current election process.
F. In the event the differences result from a criminal activity of any kind, the person
responsible for such activity should be identified if such information is available to any
person or from any file for example known to exist anywhere by any employee of the
state of Maryland Board of elections.
G. The Maryland State Board of Elections, and specifically Linda Lamone, shall we then
five days of this injunction order examine in detail the letter of Linda Lamone dated
October 14, 2022, and after an examination of plaintiff's Exhibit 3 attached and
accompanying plaintiff's motion for a temporary restraining order and plenary injunction,
explain in detail the reason, if such is known or determinable by the Maryland State
Board of election or any of its contractors or representatives, as to how the administrator
of the Maryland State Board of elections Linda Lamone could in good faith maintain that
its files and records were correct and therefore bar inquiry by citizen groups as to
questions regarding the truth and veracity of such files, and secondly what authority exists
-8-
JA232
in the laws of the state of Maryland and or the rules and regulations of any agency
including the State Board of elections preventing such audit or inquiry of questionable
information or data.
H. Further analysis of the voter rolls of the Maryland State Board of Elections (the
Board). The Board claims that it maintains and accurate system of voter rolls and a
mythology for recording in summarizing actual vote activity that is free from taint an
outside influence. And it claims effectively that the voting results are accurate, and
accurate reflections of the summaries of all genuine voters.
I. Plaintiffs Counsel has already requested a 26(f) status conference with opposing
counsel for the Board regarding discovery. At this time, prior to or immediately
following the hearing requested on a preliminary injunction the Board will be expected to
be ordered to furnish all information, statistical or otherwise, claiming to prove the
correctness of and accuracy of the functioning of its voter counting and tabulations
tracing back results on a verified audited basis. Plaintiffs submit that this task cannot be
done simply because of tainted records and absolutely no accountability control, flawed
or otherwise.
Since the Board of Elections maintains it has no ability to match electronic vote
counts to individual ballots please explain what methodology, if any such exists, enables
this resul to be verified on any reliable level at all.
The Maryland State Board of Elections should be ordered to show cause why all
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JA233
electronic voting machines furnished by Dominion, Diebold, ES&S should not be stricken
as corrupted by on line connections to uncontrollable sources and or dominated by foreign
controlled corporations. Linda Lamone, Esq. should be ordered to show cause why she is
not dominated in all decisions by her conflict of interest with the suppliers of such voting
machines for Maryland and throughout the entire nation.
J. And that, pursuant to the first round of discovery, permission is hereby requested
in the event that the state Board of elections does not conform fully to this show cause
order that the Maryland State Board of elections shall be found in contempt of this Court
and that a further Federal rule of civil procedure civil rule 30 B6 deposition of the board
of elections of the state of Maryland and its administrator Linda Lamone Esq. should be
ordered to appear for said deposition, at the cost of the State Board of Elections, and to
produce, pursuant to a subpoena issued for this purpose all documents electronic files and
the like relevant or material to this line of questioning or which might lead to the
production of evidence regarding this subject matter broadly construed..
K. This Honorable Court is requested to issue a declaratory judgment Finding that
the expert witness who has determined to remain anonymous is entitled to the affirmative
provisions of the whistle blower act and the identification of that witness shall remain
under seal for the duration of this case and that the whistle blower be entitled to all of the
beneficial provisions of that act found by the Court to be applicable hereafter.
-10-
JA234
Request for a Finding of the Existence of a RICO Enterprise in Maryland

And Elsewhere of Massive but Indeterminate Scope
L. Plaintiffs request that plaintiff's Exhibit number five attached to the original complaint
filed in this case be accepted as probative evidence in this case as being Howard County's
response to a lawful inquiry by citizens, and that the apparent information provided and
that exhibit is to the effect that about 760 checks or payments were made to about 730
different persons. And that further, in the event the preliminary evaluation is found to be
correct by the Court in testimony, or admitted to be vaild, that the great bulk of those
persons were paid piecework wages or the equivalent, and that further those payments
correlate on a one-for-one basis with the donations purportedly for tax exempt purposes
by the Chicago organization CTCL, apparently in violation of existing election and
Internal Revenue Service rules requiring bona fide tax exempt activity. CTCL and and
Howard County should be required to show cause why the activities performed by those
about 730 different persons, believed to have acted as mules for the conveying of false
documents throughout Maryland should not be found to be in violation of federal internal
revenue and election laws as well as the activities of an unlawful RICO Enterprise in
violation of the voters rights provisions of Federal Law including the Constitution of the
Untied States of America.
III, THE CONSTITUTIONAL CURE FOR THE FLAWED SYSTEM:
A. If, as expected, this injunction and exposure of the fatally flawed election systems
-11-
JA235
functioning not just in Maryland but throughout the country, prove to be as fraught with
error and intentional fraud as all indications now existing demonstrate, there is no
possibility of utilizing the machine results generated by the existing system for any
definitive election actions. Either total recounts, summarized and verified the old time
traditional way involving paper ballots are required (which appears to be impossible
because of the separation of envelopes from the ballots themselves and the fraudulent
manipulation of ballots) or, a total recount involving paper ballots is required with
enhanced validation using old-time forensic methods.
Alternatively, a total redo of the election process using nothing but paper ballots
would allow a one time "fix" of the results while the system itself is rebuilt using up to
the date system controls and totally self authenticating systems which is certainly possible
within the state-of-the-art.
However given the apparent failure of the state election boards to maintain such
things as accurate death and moving out of voters records such corrections will be a
process not possible until the next election cycle. Therefore the corrections necessary for
this cycle start with a scrapping of the entire existing system and rebuilding it given
sufficient controls in accordance with law before any reliance on election results would
be justified.
In any event the election results for the current cycle would be delayed until each
jurisdiction i.e. each state is able to certify with the reliability the results of its own
-12-
JA236
elections. However any eventuality is undoubtedly acceptable to reliance upon foreign
dominated and corrupted voting systems management personnel and voting machines
subject to online foreign and domestic communist dominated manipulation.
Walter T. Charlton
Walter T. Charlton, DC Bar # 186940,
Md Fed Bar # 07638.
11213 Angus Way, Woodsboro, Md
21798
Counsel for the Plaintiffs and the
Putative Classes
-13-
JA237
I hereby certify that I filed, on the 8th of November, 2022, in the ECF System of the
Court, two copies of Plaintiffs’ Motion for a TRO, and Preliminary Injunction and the Finding of
an Ongoing RICO Enterprise, and a Transfer of the Multi-District along with all issues, both
procedural and substantive, with the expectation that each of the defendants herein will be
electronically served with a copy of this Motion through the ECF system of the United States
District Court of Maryland in the normal course of the filing process.
Walter T. Charlton, Maryland Federal Bar # 07638.
-1-
JA238
In the
LOIS ANN GIBSON, et al. * * * * * * * * * *

Plaintiffs, *
Maryland 20-20 Watch, et al *
v. * CIVIL NO. GLR-22-1642
STATE OF MARYLAND, AND *
MARYLAND STATE BOARD OF ELECTIONS , *
et al *
Defendants. *
* * * * * * * * * * * * * * * * * * * * * * *
SUMMARY OF THE INJUNCTION ORDERS REQUESTED
1. A Temporary Restraining Order should be issued, freezing in place any

decisions by voting Boards or State Officials pending resolution of Constitutional and/or
RICO Violations.
2. It is requested that a forthwith notification of the MDL Panel be made with the
recommendation of approval of the Honorable United States District Judge assigned this
case.
3. And for such other actions as either of the Honorable District Judges believe
are in the Best Interests of preservation of the Nation and our honorable way of life,under
God.
Walter T. Charlton
Md Fed Bar # 07638.
11213 Angus Way, Woodsboro, Md
21798
Putative Classes
-2-
JA239
Case 1:22-cv-01642-SAG Document

MARYLAND
37-1 Filed 11/09/22 Page 1 of 7
STATE BOARD OF ELECTIONS

P.O. BOX 6486, ANNAPOLIS, MD 21401-0486 PHONE {410} 269-2840
William G. Voelp, Chairman Linda H. Lamone
Severn E. S. Miller Administrator
Michael G. Summers
Justin Williams Nikki Charlson
T. Sky Woodward Deputy Administrator
October 14, 2022
Via Electronic Mail Only
Robyn Sachs
Maryland Voting Integrity Group
Several local boards of elections received emails requesting a manual audit of ballots
from selected precincts, and based on news reports, we understand that your organization is
organizing this effort. I am responding on behalf of the local boards, and for the reasons
provided below, the local boards are not able to accommodate the requests.
First, the accuracy of the voting units is tested and confirmed several times during the
election process. Before each election, local election officials test each voting unit that will be
used in the election. The purpose of this test is to verify that each scanner properly counts votes
marked on ballots and each ballot marking device correctly records the voter's selections. To
conduct this test on the scanners, we feed pre-marked ballots into each scanner and verify that
the results printed from the scanner match the results we expect to receive from the "votes" on
the pre-marked ballots. Once local election officials verify that the pre-election test results
match the expected results, they clear the test results, verify that there are no results on the
scanner, and close and seal the unit. This unit is now ready for voting during early voting or on
election day. You can review all of the forms completed during the pre-election testing at the
local boards' public demonstrations.
Before the unit is used for early voting, election day or at a canvass, election officials
compare the numbered and tamper-evident seals against paperwork showing the seal number
affixed at the end of the pre-election testing. If the numbers match, it is confirmation that the
voting unit has not been tampered with since the unit was tested and accurately counted the
ballots fed into it. Otherwise, tampering with any type of voting equipment, including ballot
scanners, is a felony in Maryland punishable by up to three years' imprisonment and/ or a
$10,000 fine.
After each election and before certification, we send digital images of each ballot to an
independent entity. This third party re-tabulates all of the ballot images and provides us with
the results of its independent tabulation. When we receive the results of the independent
tabulation, we send the third party the results from the voting system. The third party then
compares their results against the voting system's results and identifies - at the precinct level -
any differences between the two sets of results. These reports are posted on our website as they
are received. We receive the results of the audit of early voting, election day, and some of the
mail-in ballot canvass before the local boards certify the local election results, and we receive
the results of the audit of all ballot images before the Board of State Canvassers certifies state
election results. This audit is called the post-election automated ballot tabulation audit.
FAX (410) 974-2019 Toll Free Phone Number (800) 222-8683 151 West Street Suite 200
MD Relay Service (800) 735-2258 https://elections.marvland.oov Ann.r1nnlic M:::tn.11::inrl '"J"f ..1.n1
JA240

Letter to Ms. Sachs
Page 2
October 14, 2022
Even though we perform an audit of 100% of the ballot images before certification, the local
boards will also perform a second audit - a manual count of ballots from selected
precincts. Information about the manual audit process is available here.
Since this voting system was first used in Maryland in 2016, these audits have confirmed
the accuracy of the voting system and that the certified results reflect the intent of each voter in
each election. If the voting system counted inaccurately as you suggest, these audits would have
identified the error. I encourage you to review the results of prior audits posted on the SBE's
website.
Second, your request for a recount is not permitted under State law. Recounts cannot be
requested until after the election results are certified, and you are asking for a recount before the
election results are certified and before all of the votes are even counted. Only defeated
candidates can request a recount, and you are not a candidate on the ballot. A recount can only
be requested if the margin of victory between the candidate with the most voters and defeated
candidate is less than 5%, and you are asking for a recount before the margins of victory are
even known. If the margin of victory is more than 0.25%, the candidate requesting the recount
must file a bond covering the cost of the recount. Again, we will not know the margins of victory
the day after the election and therefore cannot determine the cost of the recount.
While I appreciate your willingness to provide the personnel to conduct the requested
"recount," access to official election documents - including ballots - is limited to sworn and
trained election officials, not volunteers. The local boards can facilitate providing you with
visual access to the ballots after the election is certified and with an appropriate fee to cover the
costs of locating ballots for the requested precincts and staffing your review of the ballots.
Lastly, there is no evidence to indicate that the voting system we use does not count
accurately or that election results do not reflect the intention of the voters. We confirm the
accuracy of the voting equipment before election day, verify the chain of custody of the
equipment, and audit the results.
There are many opportunities to participate and observe the election process. As I
mentioned above, you can attend the local boards' public demonstrations. You can also observe
the local boards' mail-in ballot and provisional ballot canvasses. Information about the public
demonstration and canvasses is posted on the local boards' websites. I encourage you to take
advantage of these opportunities and learn more about the election process.
Sincerely,
Linda H. Lamone
State Administrator
JA241
EXHIBIT B
November 3, 2022
Analysis by Expert Witness, Cross Referencing

Maryland Voter Rolls to Official Addresses for 16 other States and Comments on Inaccuracies
Counsel's conclusion: The comments of demonstrate an amazing degree of

inaccuracies currently present in the voter data base. See following Details.
I, , am submitting information that captures a set of concerns and anomalies

found with the State of Maryland Voter Rolls. The documented concerns are limited only on
registered voters that have voted.
The data used for the analysis consists of:

• Maryland Voter Info and Voter History purchased from the Maryland Board of Elections
in August 2022 after the 2022 Primary election.
• The United States Post Office National Change of Address (USPO NCOA) data dated on
or about September 15, 2022
• Voter Info and Voter History files from sixteen states (Colorado, Florida, Georgia,
Kansas, Michigan, Minnesota, North Carolina, Nebraska, New Hampshire, New York,
Oklahoma, Pennsylvania, South Dakota, Texas, and Vermont)
The eleven (11) areas of concern with a sample set of voter information include the following:
(Additional rows and supporting column data is available upon request)
1. 4 Voted in the Maryland 2022 Primary election (Maryland Vote) and in the 2022 Primary
(New State Vote) of their new state (New State)
Maryland ID Maryland Vote New State Vote Last Name New State
501183115 7/19/22 8/2/22 MANLEY Ml
502298009 7/19/22 9/1/22 GIBBONS TX
502286532 7/19/22 9/1/22 MCBENNETT TX
501756168 7/19/22 8/9/22 QUAM MN
2. 6 Voted in the Maryland 2020 General election (Maryland Vote) and in the 2020 General
election (New State Vote) of their new state (New State)
502214854 11/3/20 11/3/20 VAIL FL
500999695 11/3/20 11/3/20 SCHMIDT FL
- - - - -- - - - - - - - -- -- - - - -- - - - -- - -- - - - -- ------ -- -
JA242
Continued
4389755 11/3/20 11/3/20 SENN FL
6063863 11/3/20 11/3/20 BEAGHAN FL
2863957 11/3/20 11/3/20 GORMAN FL
4357559 11/3/20 11/3/20 GEBUS SD
3. 24 Voted in the Maryland 2022 Primary election {Maryland Vote} and moved before
(Move Date) the Maryland 2022 Primary election date
Maryland ID Move Date Maryland Vote Last Name

5149340 6/1/22 7/19/22 HOFFMAN
500424516 6/1/22 7/19/22 JONES
2197941 4/1/22 7/19/22 LINDROTH
501183115 6/1/22 7/19/22 MANLEY
502360153 9/1/21 7/19/22 MOORE
4730798 6/1/22 7/19/22 HOLLAND
3004020 6/1/22 7/19/22 JACOBSON
500892132 6/1/22 7/19/22 BAZEMORE
4. 437 Voted in the Maryland 2020 General election (Maryland Date} and moved before
{Move Date} the Maryland 2020 General election date
Maryland ID Move Date Maryland Vote Last Name

502066464 8/1/20 11/3/20 MELLETT
501371780 8/1/20 11/3/20 STANDIG
3360732 2/1/19 11/3/20 SCHULDE
1375060 6/1/20 11/3/20 SPROULE
500207518 6/1/19 11/3/20 ZEITVOGEL
501714912 6/1/20 11/3/20 BROWN
501179092 7/1/20 11/3/20 SEMUSKIE
500878525 3/1/20 11/3/20 MOORE
3605301 2/1/20 11/3/20 TAYLOR
501912657 5/1/20 11/3/20 LEDFORD
JA243
5. 50 Voted in Maryland 2022 Primary election (Maryland Date) after their move date
(Move Date) which was before the Maryland 2022 Primary election date
Maryland ID Move Date Maryland Vote Last Name New State

501904919 6/1/20 7/19/22 LIVADITIS PA
502360153 9/1/21 7/19/22 MOORE NC
2197941 4/1/22 7/19/22 LINDROTH FL
501432898 4/1/22 7/19/22 MCDOOM-ECHEBIRI NC
5149340 6/1/22 7/19/22 HOFFMAN FL
500424516 6/1/22 7/19/22 JONES FL
501183115 6/1/22 7/19/22 MANLEY Ml
4730798 6/1/22 7/19/22 HOLLAND NC
3004020 6/1/22 7/19/22 JACOBSON NC
500892132 6/1/22 7/19/22 BAZEMORE PA
6. 1420 Voted in Maryland 2020 General election (Maryland Vote) after their move date
(Move Date) which was before the Maryland 2020 General election date
Maryland ID Move Date Maryland Vote Last Name New State

501586666 10/1/18 11/3/20 ATLEY GA
501105876 10/1/18 11/3/20 KESS NC
500252850 10/1/18 11/3/20 DEAN PA
750158343 10/1/18 11/3/20 PELTA-PAULS PA
501747780 11/1/18 11/3/20 BORZA FL
2366814 11/1/18 11/3/20 LICHTMAN FL
501619248 11/1/18 11/3/20 CROCKETT NY
501582455 12/1/18 11/3/20 MENSAH GA
500592995 12/1/18 11/3/20 WEAVER PA
2803813 12/1/18 11/3/20 SOTO-TORRES FL
7. 635 Voted both in Maryland (Maryland Date) and their new state (New Date) after their
move date (Move Date) to the new state (New State)
Maryland ID Move Date New Date Maryland Date Last Name New State
1500755 1/1/20 11/3/20 5/17/22 HELMICK PA
4352078 2/1/20 11/3/20 5/17/22 EVERHART PA
4377866 2/1/20 11/3/20 5/17/22 EVERHART PA
JA244
Continued
Maryland ID Move Date New Date Maryland Date Last Name New State
4667395 3/1/20 6/2/20 11/3/20 GUERIN FL
1016924 3/1/20 6/2/20 11/3/20 FOSTER FL
500175834 3/1/20 6/2/20 11/2/21 BARRETT PA
750154369 3/1/20 6/2/20 11/3/20 GRIMES PA
2400889 3/1/20 11/3/20 5/17/22 SHEELY PA
502073525 3/1/20 6/2/20 5/18/21 HOPWOOD PA
501047399 3/1/20 6/2/20 11/2/21 CAMPBELL PA
8. 1703 Voted in their new state {New Vote) prior to the move date {Move Date) to the
new state (New State)
Maryland ID Move Date New Vote Last Name New State

3044876 10/1/22 3/8/22 LESSANS FL
3401899 10/1/22 11/3/20 NELSON FL
502238091 10/1/22 11/3/20 FULLER PA
502176207 10/1/22 12/4/18 MCLAUGHLIN GA
502134294 10/1/22 11/8/16 IJITIMEHIN GA
502422432 10/1/22 11/8/16 MORGAN PA
501091698 10/1/22 11/6/12 COLE GA
3168066 9/1/22 6/13/22 DAVIS TX
502071426 9/1/22 5/17/22 DELAHAY PA
3568109 9/1/22 12/28/21 EVERETT TX
750373957 9/1/22 11/11/21 KAYASTHA TX
4681083 9/1/22 11/2/21 MANUZAK co
9. 2021 Voted in Maryland (Maryland Date) after their move date {Move Date) to the new
state (New State)
Maryland ID Move Date Maryland Date Last Name New State

501650133 5/1/19 11/3/20 BABYAK TX
502003615 5/1/19 11/3/20 IGBAWUA Ml
501647374 5/1/19 11/3/20 BABYAK TX
750073664 5/1/19 11/3/20 ESCHENBURG FL
500207518 6/1/19 11/3/20 ZEITVOGEL co
4587950 6/1/19 11/3/20 BEAUPRE FL
502233668 6/1/19 11/3/20 AMBROSE PA
502012147 6/1/19 11/3/20 GARRETT MO
JA245
Continued
Maryland ID Move Date Maryland Date Last Name New State
501474547 6/1/19 11/3/20 BARTELS NY
3731742 6/1/19 11/3/20 HOFFMAN PA
10. 253 Voted in Maryland (Md Vote Date) before they registered to vote in Maryland (Md
Reg Date)
Maryland ID Md Reg Date Md Vote Date Last Name New State

2150750 1/31/19 11/4/14 LYNCH FL
750463542 2/15/19 4/26/16 KEEGAN Ml
6459354 3/18/19 11/4/14 WALLIS NY
4604042 4/3/19 11/4/14 PAYNE NC
1174129 4/4/19 11/4/14 PATRICK FL
501459269 5/31/19 11/8/16 THOMAS NC
750426905 6/26/19 11/4/14 GRAVES FL
750330099 7/29/19 11/6/12 MORTON SD
500690269 8/16/19 11/8/16 JILLSON co
501348351 8/22/19 11/8/16 FAWLEY GA
11. 459 Voted in their new state (New Vote Date) before they registered to vote in their
new state (New Reg Date)
Maryland ID New Reg Date Move Date New Vote Date Last Name New State
502161506 8/8/15 5/1/21 11/6/12 JACKSON GA
501994867 9/28/15 1/1/20 11/6/12 HEMPHILL MO
502456653 5/24/16 8/1/22 8/3/10 KERSTEN MO
501778430 10/11/16 1/1/21 11/4/08 WALLACE MO
502090907 5/2/17 7/1/21 11/8/16 BAEZA GA
6814002 10/25/17 7/1/22 11/4/08 KILLMAN SD
501805333 2/12/18 2/1/20 11/8/16 DYNE co
502012147 6/1/18 6/1/19 11/4/08 GARRETI MO
502211572 10/10/18 1/1/21 11/8/16 LEWIS GA
502271201 11/27/18 10/1/21 11/6/12 WATSON GA
502269087 5/2/19 9/1/21 6/24/14 MAY co
The above data in my opinion sheds doubt on the accuracy and legitimacy of the past and
future elections in Maryland . The numbers will get worse when the data from the remaining 33
states are included.
JA246
IN THE
UNITED STATES DISTRICT COURT FOR THE DISTRICT OF MARYLAND
LOIS ANN GIBSON, ET AL., *

Plaintiffs,
*
v.
*
No. 1:22-cv-01642-SAG
FREDERICK COUNTY MARYLAND, *
ET AL.,
*
Defendants.
* * * * * * * * * * * *
OPPOSITION TO PLAINTIFF’S THIRD REQUEST FOR A TEMPORARY

RESTRAINING ORDER
Four hours after the polls closed on the general election day in Maryland, Lois
Gibson, plaintiff, requested of this Court injunctive relief enjoining “any state agency from
declaring a winner to any election” conducted on November 8, 2022. ECF 37 at ¶ II.A.
The basis for the request stemmed from Ms. Gibson’s belief that the voting system in
Maryland remained unreliable because it failed to tether a voter’s identity to the ballot they
had cast. ECF 37 at I.B–F. Ms. Gibson therefore seeks to freeze all canvassing efforts,
nationwide, “until such time as the election process verification, ‘assumed to be in the
demonstrated presence of a RICO fraud,’ in any applicable State, is concluded.” ECF 37
at II.A.
This Court must reject the request for injunctive relief. Ms. Gibson’s unsworn
assertions are without basis and fail to show, in any way, how irreparable harm with inure
JA247
to her (or any named plaintiff) before she succeeds on the merits of her complaint. She has
also made this injunctive request, her third in this case, at a time that implicates both the
doctrine of laches and the Purcell doctrine. Put plainly, Ms. Gibson has shoehorned a
collateral attack on the 2022 election into her complaint regarding the 2020 presidential
election. The pending request for a temporary restraining order and/or preliminary
injunction should not be countenanced by this Court.
I. MS. GIBSON FAILS TO SATISFY ANY OF THE REQUIREMENTS TO OBTAIN

EITHER MODE OF INJUNCTIVE RELIEF SHE HAS REQUESTED.
Ms. Gibson requests of this Court a temporary restraining order to immediately
cease any formal certification of winners from the 2022 gubernatorial election held on
November 8, 2022. Ms. Gibson has failed, however, to provide “specific facts in an
affidavit or a verified complaint” that “clearly show” how immediate and irreparable loss
will occur before any adverse party can be heard in opposition. Fed. R. Civ. Pro
65(b)(1)(A). No affidavit was attached to her request and no verifiable facts were included
in her motion. And Ms. Gibson has failed altogether to show how certification of election
winners will injure her or any of the plaintiffs named in the complaint in any way.
Accordingly, Ms. Gibson cannot obtain a temporary restraining order.
She further requests a preliminary injunction enjoining the same. A preliminary
injunction, though, is an “extraordinary remedy never awarded as of right.” St. Michael’s
Media, Inc. v. Mayor and City Council of Baltimore, 556 F.Supp.3d 327, 350 (D. Md.
2021) (quoting Winter v. Natural Res. Def. Council, Inc., 555 U.S. 7, 24 (2008)). This
Court only grants preliminary injunctions “sparingly and in limited circumstances.” Micro
2
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Strategy Inc. v. Motorola, 245 F.3d 335,339 (4th Cir. 2001). A plaintiff must therefore
make a “clear showing” of entitlement to such relief. Winter, 555 U.S. at 22.
A plaintiff bears the burden of satisfying four distinct requirements to obtain a
preliminary injunction. First, the plaintiff must “establish [she] is likely to succeed on the
merits” of the overall complaint. St. Michael’s Media, 566 F.Supp.3d at 351 (quoting
Winters, 555 U.S. at 20). Next, the plaintiff must prove “[she] is likely to suffer irreparable
harm in the absence of preliminary relief.” Id. Third, the plaintiff must show that the
balance of the equities “tips in [her] favor”; and fourth, the plaintiff must clearly show that
that an injunction is in the public interest. Id (quoting Benisek v. Lamone, 138 S. Ct. 1942,
1943-44 (2018) (per curiam)).
Ms. Gibson has failed to satisfy any of the four required elements. First, she cannot
succeed on the merits of her complaint. Without restating in full the motions to dismiss
filed by the State Board of Elections, State Prosecutor, and co-defendant counties, see ECF
14, 18, 21, 23, 25, 26, 29, 31 and 34, Ms. Gibson has failed to plead a cause of action for
which relief in this case can be granted. She alleges a RICO conspiracy without a
cognizable factual basis. She pleads a civil RICO cause of action without mentioning,
much less sufficiently pleading, any of the component legal elements of a RICO claim.
And she requests injunctive relief for her RICO claim when such relief is not permitted, by
law, for that cause of action. See Hengle v. Treppa, 16 F.4th 324, 353 (2021). Ms. Gibson’s
complaint, as a matter of law, faces dismissal, not success on the merits.
Second, Ms. Gibson’s request for injunctive relief fails to address how she is harmed
by the certification of 2022 election winners. She is not a candidate. It is not clear whether
3
JA249
she even voted in the 2022 election. And Maryland law permits her, or any registered
voter, to file suit challenging the outcome of an election if an outcome-determinative
violation of election law is uncovered before or after an election is run. See Md. Code Ann.
(LexisNexis 2017), Election Law Article, § 12-202(a). It would seem that Ms. Gibson
takes issue with the candidates declared winners by the media during the evening hours
after the polls closed on November 8, 2022. See ECF 37 at I.A.1 Being upset with the
outcome of an election, however, is not a cognizable injury that can be addressed by this
Court, much less a preliminary injunction.
Third, the balance of equities does not favor granting Ms. Gibson’s request for
injunctive relief. Ms. Gibson filed her original complaint on July 5, 2022 and filed her
amended complaint on August 20, 2022. She waited until midnight on November 9, 2022,
after polls closed in Maryland four hours earlier, to file the present request for a preliminary
injunction. Nothing in Ms. Gibson’s current injunctive request, other than the perceived
outcome of the election, took place or accrued between August 20 and November 8. The
urgency of Ms. Gibson’s purported need for injunctive relief was entirely self-created and
could have been avoided had she plead it in her original complaint. That Ms. Gibson waited
four months after initiating this case and four hours after polls had closed in Maryland
warrants denial of her request under both the doctrine of laches, see Voters Organized for
the Integrity of Elections v. Baltimore City Elections Board, 214 F.Supp.3d 448, 454-55
1
Plaintiff’s Counsel, Walter T. Charlton, is currently listed as the Treasurer for the “Dan
Cox for Governor” candidate committee on the campaign’s public website. See Homepage,
Cox for Governor at https://www.coxforfreedom.com/ (last accessed Nov. 10, 2022).
4
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(D. Md. 2016), and the Purcell doctrine governing injunctive relief in election law cases,
see Benisek, 138 S. Ct. at 1944-45 (citing Purcell v. Gonzalez, 549 U.S. 1, 2-5) (2006) (per
curiam)).
Finally, the public interest favors denying Ms. Gibson’s request for a preliminary
injunction. On December 5, 2022, certain county-level offices are mandated to begin their
term of office. See e.g., Montgomery County Code, Part I, art. I, § 105 & art. II, § 202
(mandating the term of office for Members of the Montgomery County Council and County
Executive begin at noon on the first Monday in December). Congress is mandated to
convene on January 3, 2023. See U.S. Const., amend. XX, § 2. And Maryland’s new
Governor will begin his term on January 16, 2023. See Const. of Md. Art II, § 3. If Ms.
Gibson’s request is granted, new officeholders would not be allowed to assume the office
to which they had been elected. Maryland would be forced to leave vacant, among others,
the offices of governor, attorney general, comptroller, and representative to the United
States House of Representatives (for all eight newly drawn congressional districts). There
is no public interest served in vacating the near entirety of Maryland’s representative
government.
This Court should therefore deny Ms. Gibson’s request for injunctive relief, in the
form of either a temporary restraining order or preliminary injunction.
BRIAN E. FROSH
Attorney General of Maryland
/s/ Daniel M. Kobrin

___________________________
5
JA251
DANIEL M. KOBRIN
Federal Bar No. 30392
Office of the Attorney General
200 Saint Paul Place, 20th Floor
Baltimore, Maryland 21202
dkobrin@oag.state.md.us
(410) 576-6472
(410) 576-6955 (facsimile)
November 10, 2022 Attorneys for Appellee
6
JA252

LOIS ANN GIBSON, ET AL., )
Plaintiffs, )
v. )
) no. 1:22-cv-01642-SAG
FREDERICK COUNTY MARYLAND, )
ET AL., )
Defendants )
* * * * * * * * * * * *
PLAINTIFF’S REPLY MEMORANDUM TO DEFENDANTS’ STATE OF
MARYLAND, THE MARYLAND STATE BIARD IF ELECTIONS, AND
HOWARD COUNTY,
---------------------
(AND INJUNCTIVE RELIEF FROM ALLEGED RICO AND OTHER FRAUD)
AGAINST 7 ADDITIONAL CITIES AND COUNTIES WHERE SERVICE HAS
BEEN PERFECTED, AND ABOUT 11 MORE COUNTIES WHERE SERVICE BY
FIRST CLASS MAIL AND MULTIPLE TIMES BY ELECTRONIC DELIVERY, BUT
SERVICE OF PROCESS NOTIFICATION MAY STILL INCOMPLETE:
-----------------
REPLY TO DEFENDANTS’ OPPOSITION TO PLAINTIFFS’ 3RD MOTION
TEMPORARY RESTRAINING ORDER, PRELIMINARY INJUNCTION AND
ACCELERATION OF TRIAL ON THE MERITS, AND MISCELLANIOUS
FOR RICO, CONISITUTIONAL AND EQUITABLE AND
MULTLE DISTRICT LITIGATION(MDL) RELIEF
I. Summary of Argument
Plaintiff Lois Ann Gibson and other plaintiffs have submitted a complaint in Early July
2022 that attempted to address anomalies in the 2020 election which include affidavits alleging
criminally organized voter fraud, identity theft, and paid ballot harvesting. These issues have not
been addressed to date. Although RICO is an important part of this filing, it is not the only
JA253
component. The lawsuit also requests remedies under federal election law, State law and the
U.S. Constitution. The 2022 primary showed additional anomalies. The October 2022 general
election, having recently finished, with votes still being counted shows a similar pattern. The
election should be prevented from being certified by means of TRO, Preliminary Injunction and
the Finding of an Ongoing RICO Enterprise, a declaratory judgment of the presence of fraud.
A transfer to the MDL court is requested at the earliest possible moment once the
injunctive relief is initiated preventing further damage in the election process both in Maryland
and in any affected State.
COUNT of CASES for MDL PURPOSES
Made plaintiffs have made an attempt at quantifying the number of federal cases ongoing
at the present time and the number of state cases ongoing at the present time it appears that voter
fraud or voter malfunction in one form or another is alleged and well over 100 cases and is
estimated based upon our initial count as approximately 200 cases where this similar patterns and
similar frauds affecting about nine different types of malfunctions and inaccuracies and out right
cheating is alive and well in Maryland and all other states therefore this case appears to be a
good candidate for multi-district litigation and transfer at the present time further details are
being gathered as to the various methodologies used to achieve the false and dishonest results
and are expanding to an extent that that these plaintiffs have not been able to keep up with it in
the last few days.
The number of State cases with similar concerns and issues appear to be well over 200
cases, all of which are candidates for consolidation into the approximately over 200 Federal
Cases which are now in process at this time in one state or another of litigation. Therefore, the
JA254
approval by the Court for transfer to Multi District Litigation is respectfully requested. A
separate motion will be filed in accordance with the rules hopefully within the next several days.
II. Summary of Relevant Facts.

During and after the 2020 presidential election, plaintiff Lois Ann Gibson, Maryland 20-
20 watch and a committee of injured citizens/voters witnessed a series of alarming events that
combined show a RICO conspiracy between CTCL and 21 Maryland voting jurisdictions to use
CTCL funding to these local election boards to ostensibly for election administration needs.
Although both previous motions were denied, and time has now involved the next cycle
of elections basically the corrupt systemic issues complained of continue. In fact, they have
gotten worse. Substantial evidence now exists in every jurisdiction in Maryland and in adjoining
states and in fact across the country to the effect that the systems in the fact are all very similar in
systemic function and in result and appear to be a coordinated series of events whereby it is not
possible for any fair election to take place utilizing the existing systems.
At the present time the process of stripping the identification of voters from the balance
and the changing of the vote counts and the failures to keep chain of custody over ballots and to
maintain security over drop boxes for ballots and all of the various pre-voting day methodologies
for collecting ballots continue without any provable correctness or security in ballot control over
vote control whatever.
Examples of Evidence of Corrupted Systems and Fraud
Exhibits one through five attached hereto are mere examples for demonstration purposes
hopefully for use in a hearing on a preliminary injunction. Exhibit 5 is notable and that it was
part of the election cycle of 2020 which demonstrated approximately 730 people who were used
JA255
to distribute allegedly used to distribute ballots that had been fabricated by the allegedly false
process of creation of a slush fund of ballots.
This process was paid for by another defendant, CTCL, of with a direct match in dollar
value of the purportedly charitable donation to persons who allegedly acted as couriers for the
fabricated and allegedly fraudulent ballots which transferred votes, from one candidate to
another. This process has continued and is continuing in the ongoing tabulations occurring right
now.
Plaintiffs seek a hearing on a preliminary injunction with evidence collected to
demonstrate the truth of the allegations and the truth of their allegation that the election system in
Maryland and very likely throughout the United States is flawed to the point where no fair
election process is possible. The details of this allegation will be elicited using expert witness
Drazza, an electronic engineer who has made studies of these examples throughout the last three
election cycles. Due to the press of time no further elucidation is possible in this document.
If the voting system in Maryland is put to the test of proving its accuracy not only, can it
not be done example sorry transmitted here with proving to the contrary. Example of grants to
Frederick and Carroll County Election Boards at ECF 1, exhibit 4. However, the amounts for
each jurisdiction (ECF 1, exhibit 1) show that jurisdictions that are predominately democratic,
receive per capita, much more per capita than those that are not. Additionally, ECF 1, exhibit 4,
provided by the Howard County Election Board, in lieu of an expected contract between the
Board and CTCL, similar to the Frederick and Carroll County documents, appears to show
payments made to individuals in hundreds to a few thousand dollars, that happened to total up to
the same amount listed for Howard County in ECF 1, exhibit 1. Presumably these payments
JA256
were to recompense ballot collection and ballot box stuffing as witnessed in affidavits at ECF 1,
exhibits 2.1 and 2.2. Finally, current evidence shows an affidavit that alleges voter fraud via
wire fraud and mail fraud at ECF 1, exhibit 3. There is also an affidavit at ECF-1, exhibit 1 at
document 1.1 which alleges anomalies within the electronic voting system in Frederick County.
The evidence already accumulated thus far indicates a strong RICO case involving voting fraud.
Plaintiffs believe even preliminary further discovery will greatly expand the amount of evidence
to show the full level of election interference in the 2020 presidential election.
Defendants State of Maryland and Harford County also seem to attribute all actions and
motivations to one plaintiff: Lois Ann Gibson, when in fact there are several individuals and a
class of voters similarly situated in both the 2020 and 2022 elections. Additionally, over 100
Federal cases have been filed across the county with similar causes of action stemming from the
2020 election, with further expected from 2022. Defendants’ argument against a TRO state that
there are four distinct requirements to obtain a preliminary injunction: A. That Plaintiff has
standing and is likely to succeed on the merits. B. Plaintiff must suffer irreparable harm. C.
Plaintiff must show balance of equities tip in her favor and D. Plaintiff must show the injunction
is in the public interest.
III. Response to TRO Denial Arguments.

A. That Plaintiff is likely to succeed on the merits: Denial Due to Failure to Satisfy
the Requirements to Obtain Injunctive Relief
Defendants, State of Maryland and Harford County argue that this motion for a TRO,
Preliminary Injunction and acceleration of trial on the merits should trial case should be denied
due to failure of one plaintiff: Lois Gibson to “clearly show” standing and immediate and
irreparable loss will occur before any adverse party in opposition can be heard. Here Defendants
are using the same standing arguments that have been used in previous dismissal motions, c1;22-
5
JA257
cv-01642-GLR Document 14, but in considering standing, the court must view Plaintiff’s
arguments as if allegations were considered to be true Warth v. Seldin, 422 U.S. 490, 501 (1975)
citing Jenkins v. McKeithen, 395 U.S. 411 (1969).
The defendants also argue that both the doctrine of laches and the Purcell doctrine apply
to prevent Plaintiffs injunctive request from being granted. Defendants argue on the one hand the
Plaintiffs did not submit a timely motion in the first place, triggering laches, but on the other
hand, a restraining order or injunction should not be granted because courts should not interfere
with the election process. If this is the case, then the question is: when is the proper time to
question a possibly fraudulent election?
If a plaintiff acts before the election, then a cause of action is too early because no
damage can be shown to have been suffered, if after the election, then the plaintiff is too late, and
laches applies. Clearly time is of the essence and immediate relief will have fewer disruptive
effects than trying to unravel already sworn administrations. However, either way, the harm of
possible elections fraud far and the subsequent loss of trust and social cohesion due to dilution of
votes due to various RICO schemes involving voter fraud.
While Purcell is good law and rightly avoids court interference in state administered
elections, this case is different because it addresses criminal interference in elections, not newly
decided or legislated law. Indeed, Purcell takes note of the threat of voter fraud to our polity: “A
State indisputably has a compelling interest in preserving the integrity of its election process.”
Eu v. San Francisco County Democratic Central Comm., 489 U. S. 214, 231 (1989). Confidence
in the integrity of our electoral processes is essential to the functioning of our participatory
democracy. Voter fraud drives honest citizens out of the democratic process and breeds distrust
JA258
of our government. Voters who fear their legitimate votes will be outweighed by fraudulent ones
will feel disenfranchised. “[T]he right of suffrage can be denied by a debasement or dilution of
the weight of a citizen’s vote just as effectively as by wholly prohibiting the free exercise of the
franchise.” Reynolds v. Sims, 377 U. S. 533, 555 (1964). Purcell v. Gonzalez 589 U.S. 1, 4
(2006). Citing Purcell should include citing concerns over voter fraud.
B. Plaintiff must suffer irreparable harm: Denial of Injunctive Relief due to failure
to address how the Plaintiff would be harmed by certification of 2022 election
winners.
Defendants State of Maryland and Harford County argue that one plaintiff being upset
with the outcome of the 2022 Maryland general election is the injury for which she claims a TRO
should be granted. This is a direct mischaracterization of the causes behind the current TRO
request. This request is the result of the original causes of action described in the original
complaint filed on May 7, 2022, after sufficient evidence was acquired as a result of the 2020
presidential election, and as no corrective action had been taken by the 2022 general election. In
fact, as noted in the original filing at ECF 1 alleges voter fraud during the 2020 election, and
none of the irregularities describe in the original filing have been addressed, to include affidavits
alleging identity theft: 1:22-cv-01642-GLR Document 1-3, potential ballot harvesting: Document
1-2 and potential paid ballot harvesting Document 1-5. Since then, Plaintiffs allege in the current
TRO and Injunction request instances in the 2022 primary, of individuals voting in two states,
which while not comprehensive, add up to thousands of votes: Document 37-1. Plaintiffs,
including Lois Ann Gibson, are affected by dilution of their votes, in this case by fraud which
harmed them in both the 2020 and 2022 elections. See Gray v. Sanders, 372 U.S. 368 (1963),
Bush v. Gore 531 U.S. 98 (2000). Also note that O’Rourke v. Dominion Voting Sys. Inc. No. 20-
7
JA259
CV-03747-NRN, 201 WL 1662742 (d. Colo. Apr 28, 2021) aff’d No. 21-1161 2022 WL
1699425 (10th Cir. May 27, 2022), which addresses similar voter fraud, vote dilution issues was
docketed by the U.S. Supreme Court on September 26, 2022.
C. Plaintiff must show balance of equities tip in her favor: Denial Because the
Balance of Equities Does Not Favor One Plaintiff’s Request for Injunctive Relief.
Defendants State of Maryland and Harford County have argued one plaintiff’s request for
injunctive relief, triggered four hours after polls closed for the 2022 election does not outweigh
effects of court interference per the Purcell Doctrine, and perhaps laches is also in effect:
presumably Plaintiffs should have filed after the 20 August Primary and before the November 8
election day. Of course, this characterization, which seems to imply one plaintiff’s concerns,
triggered by watching television on election night should not outweigh the effects of
implementing a TRO. As has been described about, there are several plaintiffs, including and
entire class of disenfranchised voters, and Purcell is not correctly applied in Defendants’
argument.
D. Plaintiff must show the injunction is in the public interest:
Defendants State of Maryland and Harford County argue that certain county level offices
are mandated to begin their terms of office as early as December 5, 2022, with top State and
Federal offices commencing in early January 2023. Plaintiff argues that the harm of having
potentially fraudulently elected officials at any level of government far outweighs any possible
inconvenience resulting from temporarily certifying the results of a questionable election. More
importantly, if the court grants Plaintiffs’ other motions, including ordering the recounting of all
paper ballots by hand, granting the acceleration of trial and discovery, to include investigation of
JA260
potentially illegal, paid ballot harvesting operations in Howard County noted at Document 1-5 of
ECF-1 original filing. If no evidence of wrongdoing is found, potentially, original start dates of
local, State and Federal elected offices could commence. In fact, the sooner discovery
commences, the better.
IV. Conclusion.
For all of the reasons above, the Plaintiffs respectively submit that the Court should over
rule Defendants’ Objection and grant all claims after an evidentiary hearing eliciting in detail the
relevant facts and grant the appropriate injunctive relief and transfer to the Multi District
Litigation Panel in due course of this motion. Acceleration on the trial on the Merits is also
appropriate in light of the unprecedented National upset and ongoing irrevocable harm to every
Citizen’s Rights. A Preliminary Injunction and Acceleration of Trial on the Merits should be
granted.
Walter T. Charlton
Md Fed Bar # 07638.
11213 Angus Way, Woodsboro, Md 21798
Putative Classes
I hereby certify that I filed, on the 15th of November, 2022, in the ECF System of the
Court, a copy of Plaintiffs’ Reply to the State of Maryland and Howard Counties’ opposition to
Plaintiffs’ 3rd Motion for a Temporary Restraining Order, and Preliminary Injunctive and
Equitable Relief, Etc., with the expectation that each of the defendants herein will be
electronically served with a copy of this Motion through the ECF system of the United States
District Court of Maryland in the normal course of the filing process.
Walter T. Charlton, Maryland Federal Bar # 07638
JA261

*
*
Plaintiffs, *
* Civil Case No.: SAG-22-1642
v. *
*
FREDERICK COUNTY, MARYLAND, *
et al., *
*
Defendants. *
*
* * * * * * * * * *
MEMORANDUM OPINION
Presently pending before this Court is Plaintiffs’ Motion for a Temporary Restraining
Order, Preliminary Injunction, and Acceleration of Trial on the Merits (“Motion”)1. ECF 37. The
Motion seeks to prevent any state agency from declaring a winner of any November 8, 2022
election (or any election thereafter) until the election process is verified free of fraud. ECF 37 at
5. Defendant State of Maryland filed its opposition. ECF 38. Defendant Harford County also
opposed the motion, simply incorporating Maryland’s opposition into its own. ECF 39. Plaintiffs
have filed their Reply. ECF 41. This Court has reviewed the filings and has determined that no
hearing is necessary. See Loc. R. 105.6 (D. Md. 2021) (“Unless otherwise ordered by the Court,
. . . all motions shall be decided on the memoranda without a hearing.”). For the following reasons,
Plaintiffs’ Motion, ECF 37, is denied.
1
The Motion also seeks to create or have this case transferred for multidistrict litigation; however,
this Court does not have authority to transfer a case for coordinated or consolidated proceedings.
See 28 U.S.C. § 1407.
JA262
I. BACKGROUND
In July, 2022, Plaintiffs Lois Ann Gibson, Maryland 20-20 Watch, Charlton Scientific
Educational and Engineering Foundation Inc., and others 2 (collectively “Plaintiffs”) filed a
Complaint against a variety of defendants, primarily Maryland counties and the non-profit Center
for Tech and Civic Life (“CTCL”). ECF 1 at 1–3. CTCL is a nonprofit that provided grants to
local governments or political subdivisions “exclusively for the public purpose of planning and
operationalizing safe and secure election administration.” ECF 1-4 at 1. Pursuant to the terms of
the grant, the counties or subdivisions could use the funds to recruit and train poll workers, pay for
polling place rentals and cleaning on Election Day, or pay for vote-by-mail/absentee voting
equipment and supplies. Id. at 2. The Complaint alleges voter fraud and violations of the Racketeer
Influenced and Corrupt Organizations (“RICO”) Act in Maryland and other states across the
nation, through the use of CTCL grants and other means. Id. at 5.
In conjunction with their Complaint, Plaintiffs filed an initial temporary restraining order
(“TRO”) to require Defendants to preserve election-related materials for an additional fourteen
days to permit Plaintiffs to engage in expedited document and testimonial discovery. ECF 2. This
Court considered and denied Plaintiffs’ TRO because Plaintiffs had failed to allege any immediate
harm. ECF 4 at 1. Plaintiffs moved for reconsideration, citing new evidence of irreparable harm.
ECF 6. On reconsideration, this Court again denied the TRO because Plaintiffs’ concerns about
document destruction were not “based on anything other than speculation.” ECF 7 at 4. Plaintiffs
subsequently amended their Complaint, ECF 9, and many Defendants have moved to dismiss the
complaint for failure to state a claim, see ECF 14, 18, 21, 23, 25, 26, 29, 31, and 34.
2
Other plaintiffs include “A Committee of Injured Citizens/Voters for Themselves and All Others
Similarly Situated,” “Any, Presently Unknown State Agency which was Duped by the Multiple
Frauds Alleged Herein,” and “All Others Similarly Situated Injured Persons.” ECF 1 at 1.
2
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Just after the November 8, 2022 election, Plaintiffs filed the current motion, which again
requests a TRO, a preliminary injunction, and an acceleration of the trial on the merits. ECF 37.
Plaintiffs argue that the voting system in Maryland is “fatally flawed” and “must be scrapped.”
ECF 37 at 3. They argue that mail-in ballots cannot be verified because there is a disconnect
between the voter and the ballot. Id. at 5. They point to past grant money paid to counties in
support of election operations as well as alleged inconsistencies in the votes cast in Maryland, and
argue that these inconsistencies, “if intentional,” present a pattern of RICO violations across the
country. Id. at 4. Plaintiffs request this Court to enjoin “any state agency from declaring a winner
to any election” conducted on November 8, 2022. ECF 37 at 8.
As explained below, Plaintiffs have not presented evidence to justify the issuance of a TRO
or preliminary injunction. Additionally, any trial will be scheduled after the resolution of the
pending motions to dismiss, so this Court declines to “accelerate” the timing. Plaintiffs’ Motion
will be denied.
II. HEARING
Preliminarily, the Court declines to hold a hearing on Plaintiff’s Motion. “A preliminary
injunction preserves the status quo ‘pending a final trial on the merits,’ while a TRO ‘is intended
to preserve the status quo only until a preliminary injunction hearing can be held.’”
GlaxoSmithKline, LLC v. Brooks, No. 8:22-CV-00364-PWG, 2022 WL 2916170, at *1 (D. Md.
July 25, 2022) (quoting Hoechst Diafoil Co. v. Nan Ya Plastics Corp., 174 F.3d 411, 422 (4th Cir.
1999)).
A hearing for a preliminary injunction “is not required when no disputes of fact exist and
the denial of the motion is based upon the parties’ written papers.” Fundamental Admin. Servs.,
LLC v. Anderson, No. CIV. JKB-13-1708, 2015 WL 2340831, at *1 (D. Md. May 13, 2015); see,
3
JA264
e.g., Hunter v. Redmer, No. CIV. JKB-15-2047, 2015 WL 5173072, at *1 (D. Md. Sept. 3, 2015)
(ruling without a hearing when receiving further evidence would not be helpful); see also Aoude
v. Mobil Oil Corp., 862 F.2d 890, 893–94 (1st Cir.1988) (“an evidentiary hearing is not an
indispensable requirement when a court allows or refuses a preliminary injunction”). This Court
has previously cited a well-respected treaty, which explains:
Even if a party desires to present testimony [as to a motion for

preliminary injunction], several federal courts have held that when
there is no factual controversy the trial court has discretion to issue
an order on written evidence alone, without a hearing. Similarly,
preliminary injunctions are denied without a hearing, despite a
request for one by the movant, when the written evidence shows the
lack of a right to relief so clearly that receiving further evidence
would be manifestly pointless. This practice is supported by Rule
78(b), which provides that “the court may provide for submitting
and determining motions on briefs, without oral hearings,” and by
the fact that Rule 65 does not explicitly require an oral hearing on a
preliminary-injunction motion.
Fundamental Admin. Servs., LLC v. Anderson, No. CIV. JKB-13-1708, 2015 WL 2340831, at *1
(D. Md. May 13, 2015) (citing 11A CHARLES ALAN WRIGHT, ARTHUR R. MILLER, & MARY KAY
KANE, FEDERAL PRACTICE AND PROCEDURE § 2949, at 246–48 (2013)).
In the instant case, the parties’ written submissions do not raise a question of fact that must
be resolved before the Court may rule on Plaintiffs’ motion. Thus, no hearing is required. See
Loc. R. 105.6 (D. Md. 2021).
III. LEGAL STANDARDS
“Temporary restraining orders and preliminary injunctions serve similar functions and are
subject to substantially the same legal standards.” GlaxoSmithKline, LLC v. Brooks, No. 8:22-
CV-00364-PWG, 2022 WL 2916170, at *1 (D. Md. July 25, 2022). “A preliminary injunction is
distinguished from a TRO only by the difference in the required notice to the nonmoving party,
4
JA265
and by the duration of the relief it provides. . . . Temporary restraining orders are of limited
duration, whereas preliminary injunctions are indefinite.” Id. (internal citations omitted).
A TRO or a preliminary injunction is warranted when the movant demonstrates four
factors: (1) that the movant is likely to succeed on the merits, (2) that the movant will likely suffer
irreparable harm in the absence of preliminary relief, (3) that the balance of equities favors
preliminary relief, and (4) that injunctive relief is in the public interest. League of Women Voters
of N.C. v. North Carolina, 769 F.3d 224, 236 (4th Cir. 2014) (quoting Winter v. Natural Res. Def.
Council, Inc., 555 U.S. 7, 20 (2008)); Wilson v. Williams, 2019 WL 4942102, at *1 (D.S.C. Oct.
8, 2019). The movant must establish all four elements in order to prevail. Pashby v. Delia, 709
F.3d 307, 320–21 (4th Cir. 2013).
A TRO, much like a preliminary injunction, affords ‘“an extraordinary and drastic remedy’
prior to trial.” Ultimate Outdoor Movies, LLC v. FunFlicks, LLC, 2019 WL 2642838, at *6 (D.
Md. June 27, 2019) (quoting Munaf v. Green, 553 U.S. 674, 689–90 (2008)); see also
MicroStrategy, Inc. v. Motorola, Inc., 245 F.3d 335, 339 (4th Cir. 2001) (stating preliminary
injunctive relief is an “extraordinary remed[y] involving the exercise of very far-reaching power
[that is] to be granted only sparingly and in limited circumstances.”). Because preliminary
injunctions are intended to preserve the status quo during the pendency of litigation, injunctions
that “alter rather than preserve the status quo” are particularly disfavored. Mountain Valley
Pipeline, LLC v. 6.56 Acres of Land, 915 F.3d 197, 216 n.8 (4th Cir. 2019). Courts should grant
such “mandatory” preliminary injunctions only when “the applicant’s right to relief [is]
indisputably clear.” Id.
5
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IV. ANALYSIS
A. Likelihood of Success on the Merits
In support of their Motion and legal claims, Plaintiffs present the following exhibits and
evidence:
(1) A letter from Linda H. Lamone, State Administrator of the Maryland Board of
Elections, explaining how the Board tests and confirms the accuracy of the
State’s voting units prior to the election, ECF 37-1, Exh. A;
(2) A spreadsheet of names of Howard County residents who allegedly received
payments from CTCL, ECF 1-5;
(3) A summary of an analysis comparing the dates that voters submitted ballots, as
acquired by the Maryland Board of Elections, with the dates those voters
submitted change-of-address forms, as acquired by the U.S. Post Office, ECF
37-1, Exh. B;
(4) The declaration of Plaintiff Lois Ann Gibson stating that she witnessed an
individual place “at least several dozen” ballots in a ballot box in Frederick,
Maryland on or around November 2, 2020.3
Each of these documents fails to provide evidence of election fraud or a RICO conspiracy.
First, the letter from Ms. Lamone, the State Administrator of the Maryland Board of
Elections, plainly contradicts Plaintiffs’ assertions. The letter enumerates the multiple actions
taken by the Maryland Board of Elections to ensure the validity of Maryland’s elections. For
example, the letter describes how Maryland election officials test each voting unit before its use
in the election, send digital images of every ballot to an independent entity for confirmation of the
3
Plaintiffs also list, “The whistleblower analysis of data errors filed with the Court on November
8th 2022. Exhibit # 2.” ECF 37 at 6. To this Court’s knowledge, there was no “Exhibit 2” filed
by Plaintiffs on November 8th. There are two exhibits attached to Plaintiffs’ current Motion, but
the two exhibits are labeled A and B. This Court assumes Plaintiffs are referring to Exhibit B,
which this Court includes in the list above. Plaintiffs also list: “The kinds and types of fraud
admitted by President Biden,” ECF 37 at 9; however, Plaintiffs do not provide any specific
evidence for this Court to review. Plaintiffs also attached a new exhibit, without further
explanation, to their Reply. ECF 41-3. This exhibit, a copy of a presentation asserting
mathematical errors in the Maryland 2020 election, contains two hyperlinks to sources that are
non-functional and generally appears to rely on less-than-reliable and hearsay sources of
information. In sum, it does not provide reliable evidence of organized fraud in the 2022 election.
6
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results, conduct an audit of some of the mail-in ballots before elections are certified, and publish
the results and election processes online for review by the public. ECF 37-1.
Second, Plaintiffs present a spreadsheet (reportedly from Harford County’s records, ECF
1 at 67) of hundreds of names of Howard County residents receiving payments during the 2020
election. See ECF 1-5. Plaintiffs assert that this is a list of “data harvesters or couriers.” ECF 37
at 9. Plaintiffs point to the fact that the total amount of these payments equals the grant amount
received by Howard County from CTCL. Id.; see also ECF 1-1. Plaintiffs also note that many of
the payments were made in round-dollar amounts, which they assert is “clear evidence that the
Grant was of the fee [sic] was for piece-work services for example the rumored 5 or 10 dollars
each for ballot delivery.” ECF 1 at 18; ECF 9 at 16–17. However, rumors and conclusory
speculation are insufficient to support a finding of likelihood of success on the merits. There is no
evidence—direct or circumstantial—to suggest nefarious use of these funds.
The acceptance of CTCL grant money is not a violation of federal or state law. In their
Second Amended Complaint, Plaintiffs document that twenty-one Maryland counties accepted
grant funds from CTCL in the 2020 election. ECF 9 ¶ 4; see also ECF 1-1. Plaintiffs assert that
the grants disguised payments to individuals to harvest unlawful votes. ECF 9 ¶ 10. However,
nothing in the Grant Agreements’ language suggests the acceptance or use of these funds violated
any law. Indeed, Plaintiffs concede that the transfer of money occurred through “apparently
normal official budgeting receipt channels,” ECF 9 ¶ 4, and describe the end use of the money “for
a particular (purportedly) innocuous and perfectly lawful, usage,” id. ¶ 6. Thus, the grants are
facially lawful, and there is no actual evidence of their illicit use. In 2020, other courts denied
TRO motions propounding a similar theory, concluding that no law prevented CTCL from granting
money to the counties for the non-partisan purpose of supporting safe elections. Cf. Iowa Voter
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All. v. Black Hawk Cnty., No. C20-2078-LTS, 2020 WL 6151559, at *4 (N.D. Iowa Oct. 20, 2020);
Election Integrity Fund v. City of Lansing, No. 1:20-CV-950, 2020 WL 6605985, at *1 (W.D.
Mich. Oct. 2, 2020). This Court concludes the same.
Next, Plaintiffs’ Exhibit B presents a summary analysis comparing individuals’ voting
dates to their change-of-address dates. ECF 37-1. The summary only provides a few examples of
alleged voter names and dates, but reports larger amounts of inconsistencies are “available upon
request.” ECF 37-1 at 3. The analysis reports varying inconsistencies, such as twenty-four
Maryland voters who changed their mailing address to another state prior to voting in the Maryland
2022 primary election. The report also compares voting and change-of-address dates from the
2020 election. Even assuming this data is accurate, the fact that a voter submitted a change of
mailing address does not demonstrate that the voter is ineligible to vote in Maryland. An individual
may forward mail to a new address for a variety of reasons aside from a change of permanent
residence, and may still be entitled to vote lawfully in Maryland while receiving mail in another
location. Thus, Plaintiff’s analysis of the U.S. Post Office’s National Change of Address registry
does not show fraud or unlawful voting to the degree required to prove a likelihood of success on
the merits.
The remaining example of voter fraud presented by Plaintiffs in Exhibit B is their allegation
of four voters who voted in two states’ 2022 primaries. ECF 37-1 at 3. Plaintiffs argue that these
double votes demonstrate data inconsistencies overlooked or willfully ignored by the Maryland
Board of Elections. ECF 37 at 4. Of note, however, there are data inconsistencies in Plaintiffs’
own summary analysis. Plaintiffs identify two voters who allegedly voted in Maryland and then
voted in the Texas 2022 primaries on September 1, 2022. ECF 37-1 at 3. However, Texas’s
primaries were held in March and May of this year, not September. This leaves only two voters
8
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who Plaintiffs allege voted in two states’ primaries. But even assuming these allegations are true,
two instances of double voting falls far short to prove Plaintiffs’ RICO claim because no evidence
suggests these two voters were paid by county officials to double vote. In other words, the
evidence of some small number of voters voting in more than one jurisdiction is entirely divorced
from the RICO conspiracy alleged by Plaintiffs. There is no alleged connection to the CTCL
grants, any action by the state of Maryland, or any of the county defendants.
Finally, Ms. Gibson’s declaration is likewise unavailing. She reports seeing an individual
place multiple ballots in a drop box during the 2020 election. Of note, this individual identified
themselves as someone from the U.S. Post Office. Even absent that work-based justification, the
mere act of dropping off multiple ballots does not invalidate those ballots or document unlawful
activity. An individual can collect and drop off ballots for family or local community members
without committing voter fraud. See Md. Code, Election Law § 9-307 (permitting a voter’s agent
to deliver an absentee ballot). This Court will not infer illegal activity from speculation. Cf. King
v. Whitmer, 556 F. Supp. 3d 680, 718 (E.D. Mich. 2021) (refusing to infer “illegal double voting”
from an individual’s reported observation of people voting in person who had previously applied
for an absentee ballot because a “resident can request an absentee ballot and thereafter decide to
vote in person”). Moreover, this event occurred in 2020 and did not impact the 2022 midterm
election, which this Motion seeks to invalidate.
In sum, Plaintiffs have failed to present evidence of intentional, organized voter fraud to
support their RICO cause of action. Much of Plaintiffs’ Motion is dedicated to describing what
information could be obtained if permitted to depose and further analyze data acquired through
discovery. ECF 37 at10 – 14. However, “Plaintiffs are not entitled to rely on the discovery process
to mine for evidence that never existed in the first instance.” King v. Whitmer, 556 F. Supp. 3d
9
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680, 720 (E.D. Mich. 2021). Based on the present record, Plaintiffs cannot show that they are
likely to succeed on the merits of their claims.
B. Irreparable Harm
Although their failure to show likelihood of success on the merits is dispositive of
Plaintiffs’ Motion, see Pashby v. Delia, 709 F.3d 307, 320–21 (4th Cir. 2013) (requiring a movant
to demonstrate all four factors), this Court will also weigh the remaining factors.
As with their previous injunctive efforts, Plaintiffs have not shown that they would be
irreparably harmed absent a TRO or preliminary injunction. Plaintiffs seek to halt certification of
the 2022 election results in Maryland. However, Plaintiffs have not explained how certification
of those election results would harm them. None of the Plaintiffs claim to be candidates in the
election or even assert that they voted in the 2022 election.
Many of the allegations made by Plaintiffs relate to the 2020 election, not the 2022 election.
See ECF 41 at 7 (“the [Complaint] alleges voter fraud during the 2020 election”). Ms. Gibson’s
declaration reports an incident she witnessed in 2020. ECF 1-2. Reports of grants made by CTCL
to Maryland counties occurred in 2020. ECF 1-1; ECF 1-4; ECF 1-5. And much of the analysis
comparing voting records with change-of-address dates relates to the 2020 (or earlier) elections.
Preventing certification of the 2022 election fails to remedy any of these allegations, even if the
evidence had sufficed to suggest a meritorious claim.
Maryland law permits Ms. Gibson, or any registered voter, to file suit challenging the
outcome of an election if an outcome-determinative violation of election law is uncovered before
or after an election is run. See Md. Code, Election Law Article, § 12-202(a). Thus, adequate
alternative remedies exist for election law violations. Plaintiffs argue that they “are affected by
dilution of their votes, in this case by fraud which harmed them in both the 2020 and 2022
10
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elections.” ECF 41 at 7. But as explained above, Plaintiffs have failed to allege fraud that was
outcome determinative on the election in any way. Thus, Plaintiffs have failed to allege irreparable
harm.
C. Balance of Equities and Public Interest
“The remaining factors – the balance of equities and the public interest – merge when the
government is a party.” Bauer v. Elrich, 463 F. Supp. 3d 606, 614 (D. Md. 2020) (citing Nken v.
Holder, 556 U.S. 418, 435 (2009)). The remedy that Plaintiffs seek—to “scrap” the election
process and prevent any state agency from declaring a winner of any November 8th election—is
grossly disproportionate from the allegations of harm in this case. Enjoining certification of the
election results would likely leave vacant county-level positions across the State as early as next
month. See, e.g., Montgomery County Code, Part I, art. I, § 105 & art. II, § 202 (mandating the
term of office for Members of the Montgomery County Council and County Executive begin at
noon on the first Monday in December). Aside from two allegations of double voting in the
Maryland 2022 Primary, Plaintiffs put forward only a handful of instances from past elections
where individuals inferred, but did not actually witness, voter fraud. Their allegations require
inferences and assumptions drawn from perfectly lawful activity. Plaintiffs have also put forward
evidence of why the Maryland election was valid and secure, as demonstrated by the letter from
the Maryland Board of Elections. On the whole, given the underwhelming evidence to suggest
any irregularities, discarding or delaying the November 8th election results would contravene the
public’s interest.
V. CONCLUSION
For the reasons stated above, Plaintiffs’ motion for a TRO, preliminary injunction, and
acceleration of the trial on the merits, ECF 37, is DENIED. A separate Order follows.
11
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Dated: November 16, 2022
/s/
Stephanie A. Gallagher
12
JA273

*
*
Plaintiffs, *
v. *
*
et al., *
*
Defendants. *
*
* * * * * * * * * *
ORDER
For the reasons stated in the accompanying memorandum opinion, it is this 16th day of
November, 2022, ORDERED that Plaintiffs’ motion for a temporary restraining order, preliminary
injunction, and accelerated trial on the merits, ECF 37, is DENIED.
/s/
JA274

LOIS ANN GIBSON, ET AL., *
Plaintiffs, *
v. *
* no. 1:22-cv-01642-SAG
FREDERICK COUNTY MARYLAND, *
ET AL., *
*
Defendants *
* * * * * * * * * * * *
PLAINTIFF’S MEMORANDUM IN OPPOSITION TO DEFENDANTS STATE

OF MARYLAND, ALL COUNTIES FILING MOTIONS TO DISMISS, AND
OTHER PARTIES FILING MOTIONS TO DISMISS ON SAME GROUNDS:
I. Preliminary Statement
On the 4th of July, 2022 plaintiffs filed this lawsuit challenging the election
practices in the state of Maryland which had been building since about the third term of
the century. Maryland is a predominantly one-party state having been that way for several
hundred years.
Maryland's election practices are and have been entirely dominated by the
Democratic Party which utilized the Maryland State Board of Elections and its staff to
dominate election practices throughout the 23 counties of the state including Baltimore
County and the city of Baltimore.
The chief executive officer of the state Board of elections, Linda Lamone, has
historically dominated the process serving as the national chairman of the national
advisory board of state election boards for a number of years before returning to continue
running the state Board of elections with its substantial staff and essentially fully
JA275
computerized operations.
Notably, as a practical matter the Maryland State Board of elections assumed
power over all of its branches, one in each County and Baltimore city. Although
purportedly independent all decisions regarding management procedures and regulations
were de facto dominated by Linda Lamone (See Exhibit B).
During the upset and social turmoil of the second decade of the 21st century
several active individuals began to question operations of the state Election Board in
terms of fairness and propriety of its actions. A group arose to perform investigations and
adopted the name 20-20 Watch.
Prior to the midterm elections for 2022 a number of individuals and formal
organizations have been joined by professional groups, systems engineers, political
figures and others to analyze and challenge what is perceived to be unlawful actions by
the Maryland State Board of Elections and unknown others who seek, it is alleged, to
deprive all Maryland citizens of their fair and equal opportunity to vote for persons of
their choice in a fair and consistent manner.
The specifics of information obtained alleged in this lawsuit is to the effect that the
electronic databases maintained by the State of Maryland, and not coincidentally,
similarly essentially every state of the union are dominated by nefarious actors to
participate in the accumulating of incorrect voter information to take advantage for
purposes of deflating the vote of those persons. This effort culminated in the printing of
incorrect, or partially incorrect voting ballots. These tools of their trade come equipped
with preassigned identities and addresses of both fictitious, dead, and correct voters, on
2
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information and belief, utilized in virtually every state in the union to accomplish the
diversion of votes as needed to accomplishing false election results.
These diverted and fictitious votes and thereby incorrect votes contribute to and
usually are successful in accomplish a contrived, that is a fixed, election. Thereby, the
forces of evil, bent upon or the fully knowing destruction of our nation. The persons who
do this namely, whether the innocent pawns, or fully knowledgeable for example, the
radical Communist Traitors are alleged to be supported by the likes of George Soros and
tightly linked to the Dominion voting machines.
Plaintiffs allege, based upon out of state reports combined with in-State contracts
with Maryland State Election Board, beginning in 2020 and continuing as we speak,
through the mid-terms, that a significant percentage of election ballots, and/or envelopes
were manufactured intentionally containing defects. This procedure is in wide usage to
furnish envelopes and/or ballots for use with ballot stuffing schemes. The purpose of bad
addresses, or defective specifications is to create rejects from the system, in large
numbers that can then each be diverted to a re-directed vote.
Plaintiffs propose to test large numbers off ballots with high speed paper handling
equipment to verify the report assertion that at least one of the printers of Maryland
Ballots and/or Envelopes intentionally misprinted election materials along with tests of
actual ballots and/or envelopes.
Analysis of Evidence Alleged to be Defective

In Material Parts:
An evidentiary hearing will be requested upon the electronic information produced
JA277
and stored during the most recent election cycle, the mid-term election of 2022. With the
permission of the Court, the evidentiary hearing shall present the full scope of the afore-
mentioned fields of expert knowledge and evidence an give the authorities in Maryland a
full view of what has been going on, presumably behind their backs. For it would
certainly be unthinkable to discover that Maryland’s entire government would be
complicit in a RICO Enterprise in falsification of voter identification data of this
magnitude.
It is expected that the evidentiary hearing requested shall reveal the full scope of
the falsities in state board of election(s) deceptions involving fake printed ballots become
clear. There shall be no question at that time regarding the existence of a racketeering
and likely treasonous actions of the Maryland State Board of election key personnel.
Similar affects upon the operations of various state boards of elections in other
parts of the country, notably Florida and New York are having similar experiences as
well. Bu from informal reports still being researched many and various locations have
had their experiences with alleged, but not voter integrity and as of yet unresolved
difficulties in election integrity and counting.
II. Summary of Argument:
Plaintiff Lois Ann Gibson and other plaintiffs have submitted a complaint that
should not be dismissed for lack of standing under Rule 12(b) (1) or failure to state a
claim upon which relief can be granted under rule 12(b)(6); or as a matter of law, or
because it fails to allege all of the multitude of the precatory elements of a classic
Common law fraud case.

4
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However in addition, this Maryland case alleges that during the election cycles
since about 2012 Maryland, through its Maryland State Election Board has created an
unworkable and fraud laced RICO Enterprise to intentionally control the results of
elections contrary to the intent of the voters. Maryland State Board of Elections voters
have been substantially disenfranchised, The extent of the diminution of vote, and the
substitution of false or fabricated votes cancelling good and valid votes is alleged to be
substantial.
Because profits by such persons as printers of false and misleading information
coupled with large profits for doing so by wrongdoers are alleged to implicate creation of
a RICO Enterprise for profit from operation of the racketeering Enterprise. For the
flexibility of available charges under the 2009 landmark Boyle, case, see Boyle v. United
States, 556 U.S. , 129 S. Ct. 2237 (2009). The extent of the rule changes by this case
required the Department of Justice to totally revamp the specificity requirements
applicable to RICO. A liberalization of the specificity requirements applicable to Boyle
resulted. These standards are applicable here.
The RICO charges summarized according to 18 U.S.C. §1962(b) - Acquire an interest in
and Enterprise Through Racketeering Activity.
1. Existence of an enterprise;
2. The enterprise engaged in, or its activities affected, interstate or foreign commerce;
3. The defendant derived income, directly or indirectly, from a patternactivity or through
collection of an unlawful debt in which such person has participated as a principal; and
4. The defendant used or invested, directly or indirectly, any part of that income, or the
5
JA279
proceeds of that income, in the acquisition of an interest in, or the establishment or
operation of, the enterprise.
Similarly, there is no requirement of Plaintiffs to allege facts beyond the
“Specificity” requirement for common law fraud or for that matter, voter system fraud
which is applicable here and now, not just in Maryland but in at least 43 states in which
the same patterns of fraudulent acts have been uncovered by expert witnesses available to
testify based upon just the partial evidence uncovered to date.
Although the “specificity requirement” of common law fraud is addressed below,
and in addition plaintiffs claim the applicability of RICO.
The unique elements required to invoke the “RICO Enterprise” allegations
resulting in findings applications by the Court of the statutory elements shall also be
addressed following, and cited, even based upon the total lack of discovery allowed to
date, the available evidence clearly meets the threshold for denial of dismissal. The
threshold is met because all of plaintiffs proffered documentary evidence must be taken
as true, and their allegations must be taken as true also, unless those allegations are
clearly “outlandish”. But the expanded allegations herein are and evidentiary examples
and patterns continue to increase in complexity and availability of probative evidence
along with witnesses, both laymen and experts, explanations.
More instances of common law fraud, and the existence of multiple RICO
Enterprise conspiracies between businessmen who gain funds, and businesses via power
and manipulations of dishonest elections. These actions meet the threshold criterial
contained in the landmark case of Boyle vs. United States, 556 U.S. I 129 S. Ct. 2237
6
JA280
(2009). These troublesome matters continue to be discovered in this State as well as
throughout the Nation in the commission of very similar, and sometimes virtually
identical fraud acts and procedures. Over 139 federal cases also continue to explain in
greater detail the complexities fraudulent activities in virtually every State.
The Presence of Fraud, both Common Law, Constitutional and

The Presence of a RICO Enterprise with Imbedded RICO Activities is Legion:
Indeed it is not possible to claim absurdity in the presence of fraud which clearly
does exist in every state. For this reason, accompanying this Opposition, plaintiffs file
this request for initiation of discovery along with a renewal of the Motion for a
Preliminary Injunction and a Declaratory Judgment of the Presence of Fraud during the
presently being tabulated mid-term elections requiring forthwith injunctive relief to avoid
permanent and irreparable harm as of yet indeterminate scope and effect.
A second declaratory judgment should find that the election system in Maryland
should be found defective, inaccurate, and this fact standing alone prevents the dismissal
of all present claims pursuant to the pending motions to dismiss. No present
determination of a reasonable solution to the mid-term elections is possible with such a
magnitude of incorrect counts and false records remaining unresolved.
In fact, the admissions of party opponents on the basis of business records and
admissions of genuine financial records furnished by just one County, Howard, prevent
any dismissals of claims until such time as a reasonable factual determination of
anomalies and outright erroneous results are completed and corrected. Those documents
contain lists of about 730 election workers. The exact sum paid to these workers was
7
JA281
financed by a well-known Chicago democratic funding organization, CTCL. CTCL, by
written contract, controlled the purported duties performed by the Howard County
election workers. And all other grants to subdivisions of the State of Maryland for which
each subdivision accepted funds subject to restricted use governed by the grant contract
for a total of about $ 6.3 million for the year for Maryland subdivision.
What duties were actually performed in exchange for the about $ 688,226 dollars
paid to Howard County? Plaintiffs expect to inquire in detail. The truth is expected to
include clearly unlawful “ballot harvesting” or other violations of “chain of custody” in
the ballot and envelope delivery process. Whether the grants continue on into the next
mid-term elections is unknown. But examples of these violations have already been
observed and such are available as trial evidence. More shall be specified as received
from fake ballots and envelopes as obtained from the subpoena process which are
ongoing at the present time1.
The magnitude of erroneous and/or false drop-box deposits and false mail-in
envelopes appear to be sufficient to find a consistent and material pattern of RICO and
fraudulent votes, not subject to any verification process whatever prior to discovery. This
fault partially results from no chain of custody whatever being enforced.
But more on this later regarding the essence of the “harvested fake and fraudulent
ballots in Maryland recently discovered in the many hundreds, and expected to be much
1
One of Plaintiffs witnesses today received a notification from his Maryland agent that the Maryland
State Prosecutor was attempting to locate him. Undersigned Counsel was surprised by this Contact
without a courtesy notification of undersigned counsel or response to service in the State Prosecutor’s
Office in the underlying lawsuit. That witness was instructed to fully respond to the Prosecutor.
8
JA282
larger in volume as the investigation and evidence continues to expand for the 2022 mid-
term elections.
The original documents claiming both RICO and Vote fraud and related alleged
unlawful actions were from the 2020 election, furnished by a private investigative
organization, 20-20 Watch, but the allegations are that these practices continued on into
these mid-term elections. And the new evidence including the alleged and measured
patterns of intentional inaccuracies continue, accelerated, not unabated.
Accordingly, the Motions to Dismiss should be denied with discovery instituted
forthwith with the issuance of a scheduling order. As a continuing matter, the three
injunctive relief requests previously denied should be reconsidered forthwith upon
plaintiffs reaching the threshold needed to support the allegation of “immediate and
irreparable harm meeting the presiding Court’s sufficiency criteria.
Our volunteer staff has researched the quantity of cases now proceeding through
the United State is federal courts related to alleged vote malfunctions and fraud. The ever
expanding number is listed in Exhibit A, hereto. The number is 334 (Ex A, pg 39) and
about another State cases, 239 likely removable to federal court from state cases.
Therefore the minimum number of similar factual settings necessary to allege a bare
minimum to support similarity allegations at this stage of the litigation appear to be
readily available. Here the allegations of similarity and specificity would appear to be
common law fraud, constitutional civil or criminal claims under RICO, or any other civil,
and likely criminal wrongs both of which are subject to civil penalties.
Further, anticipated criminal penalties or, as also very likely both civil and RICO
9
JA283
Enterprise acts are linked to interstate fraudulent activities in continuing unlawful vote
fabrication or ballot falsifications. All of these allegations involve crossing state lines to
deliver the false printed product crossing state and County lines. Examples of out of
state printing of false ballots are known to have occurred, and expect to be discovered
early in discovery using the Subpoenas Process coupled with 30 (b)(6) depositions.
Such previously virtually unheard of troublesome unlawful matters are expected to
predominate over strictly local claims in, as of now, a massive number of cases, all of
which combined create a massive upset in the peace and tranquility of this Nation, and a
huge amount of expense to honest law abiding citizens.
For the reasons alleged, the denial of a fair voting process, by trickery and the
other elements of unfair dealing contained in the RICO Statute, the State and Federal
voting requirements, the Constitution of the United States and Maryland, the joint
motions to dismiss should be denied. Should any doubt at all exist as to matters of
standing or fact (which must be viewed and weighed upon the standard of being taken as
true, an evidentiary hearing, forthwith, should be convened before a criminal and civil
grand jury to determine just who is telling the truth and who is not as to the fraudulent
facts herein alleged).
Lastly, if there be any serious question about the overall situation of credibility, the
now infamous, but deadly serious “live remark” by our present President Joseph R. Biden
to the effect that:
“we have put together the greatest and most sophisticated voting fraud
scheme ever devised” .
10
JA284
Plaintiffs believe that this statement is not only true, and no way made in jest, but
should be taken as serious for all purposes in this case as the admission of a party
opponent.
Nevertheless, the tangled web of facts continues to evolve, at a speed almost
impossible to fathom. For this reason, a summary of known and alleged facts based upon
current observations are outlined with specificity following, with regard to common law
fraud voting system matters, and RICO system conspiracy matters embedded in actions
involving cheating and inaccurate tabulations (both “erroneous” and/or intentional
wrongdoing in the voting processes) for both the 2020 cycle through the 2022 mid-term
tabulations being accumulated with specificity, now.
Because of the rapidly changing and evolving facts affecting not only the current
election but obviously all elections in the future, and the also obvious relationship of
election changes caused by the unlawful acts alleged herein which shall be proven beyond
any reasonable doubt in the event this court determines to limit the scope of this case to
previous events, nevertheless another amended complaint should be allowed.
The methodologies described herein for the most recent election has yet again
changed the methodology of the fraudulent actions which, yet again is brand-new and
clever as only highly clever fraudster can design. The Court and ultimately the multi-
district litigation panel should allow the civil and criminal wrongdoing to be addressed by
modifications in the complaint version must continue to evolve along with the alleged
methodology of the various frauds as indeed they continue to evolve in order to
effectively continue to trick this court and the citizenry of the United States of America in
11
JA285
the election process.
Embedded in all of the specific claims is the claim of denial of the civil right to a
fair and untainted voting process. This is a constitutional right both under the
Constitution of the United States and the Constitution of the State of Maryland, and as to
Maryland by specific provision of the Maryland Constitution which created the Maryland
Office of the State Prosecutor to maintain all conditions necessary for a fair honest and
untainted vote. Regardless of cause, likely because of the observed lack of funding of
that office2, the State of Maryland has abdicated that process, and thus is a defendant in
this case for failing its statutory duty.
Should anyone doubt this allegation, let them merely name the last time any
investigation ever occurred by the Maryland State Prosecutor’s Office of voting matters.
Plaintiffs are unaware of any such investigation or action regarding alleged vote fraud, or
vote enforcement. Plaintiffs Motion in this Court, as entered as soon as practical,
pursuant to the provisions of 28 U.S.C. §1407 accompanies this Motion. Plaintiffs
request action as soon as practical on this related action accompanying this Motion as
filed by plaintiffs herein.
The only really binding requirement(s) for RICO standing (Post Boyle) as applied
by our federal government, including private parties as well as our federal government’s
Department of Justice and FBI, is the existence of a Criminal Enterprise, and the
2
It appears that the Office of the Maryland State Prosecutor, is budgeted at a level of about $ 1.4
million per year. That funding level amounts to just slightly over 11 employees, hardly a recognizable
force in the area of vote system control. That is, if indeed, dishonesty or incomp9ence exists, which it
unquestionably does as demonstrated by existing documents of record. Further, where is the FBI or the
DOJ when we really need them? This case seeks to find out by evoking the constitutional power of the
Federal Judicial System, as our third branch of government.
12
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existence of one or more of the RICO required factual statutory sets of facts. Many are
present here, including prominently tax evasion and laundering of tax free money for the
nefarious purpose of cheating in elections controlling not just the federal government but
the military as well. A sorry spectacle.
For example, the money laundering of the 21 Counties who received the alleged
“grants” totaling about $ 6.3 million, with about $ 688,226 to just one county, with about
730 separate individuals being paid apparently tax-free money by the apparent same
political operating arm of the democrat party that ladled out over 600 million nation-wide
creation of false and forged ballots, along with the money laundering for the purpose of
placing false information (fake and/or fabricated signatures and false addresses to support
fake votes) into official government records.
The money laundering during the vote cycles here, cycled into the voter’s hands
for any one sided election torqueing and/or weighting the thrust of votes to the picks for
each such wrongfully influenced vote contest also constitutes a common law fraud. If
proven to have occurred. The very recent Ukranian Ponzi scheme collapse should be
recognized as nothing but one of the side effects demonstrated to occur when the
dishonest politicians set out to deceive the public.
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II
THE SPECIFICITY STANDARDS TO BE APPLIED FOR PLAINTIFFS’
MOST BASIC CLASS CLAIMS BY THE MARYLAND DISTRICT COURT
------------------------
AND THE MULTI-DISTRICT PANEL UPON
FILING OF THE MOTION FOR MDL TREATMENT
OF THE HUNDREDS OF CASES TO WHICH THESE FACTS APPLY:
Despite the obvious nature of the thousands of instances of plain erroneous action
of the Maryland Voter’s System as it now purports to function accurately, and allegations
continuing to escalate and being discovered more each day, plaintiffs shall following,
attempt to allege with the now known specificity (1) the plainly erroneous matters
disclosed in recent analyses of voting results, and (2) those matters that are alleged to be
nefarious and dishonest to the extent apparent and provable at this time, with little or no
discovery within the standard for civil wrongs in Maryland a preponderance of the
evidence, that is (51% as found by a jury convened for that purpose).
III.
Specificity of Claims, Simple System Error
And Sloppiness Distinguished from Intentional Fraud and Treason:
The Maryland election system purporting to function correctly does not do so.
Several inherent flaws make it not trustworthy for citizens3. Those instances mostly
concern the presence of ineligible and/or outright fake voters in the voter rolls and voting.
3
Numerous instances have been cited and are otherwise un-referenced in the record of this case See
Exhibit A.
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The 14th 15th, 19th and 26th Amendments of the Constitution of the United States of
America provide explicitly that citizens can not have their votes abridged or denied for
reasons of race, gender or age. Voting by ineligible non-citizen voters may constitute
reduction, abridgement, or cancellation of an eligible vote by a citizen.
But, there is no place in the Constitution that explicitly provides that general
elections are exclusive only to citizens. Consequently, ineligible voters who may
nevertheless vote are not de-facto bound by any of the limits to fair play in current law.
Nor does the Maryland voters system (and many others, 43 states are cited herein (Exhibit
10), and proffered expert testimony4 with hundreds of federal cases are now in process on
one aspect or another of the vote fraud(s) problem.
The vote accountability problem, although obviously destructive of our society in
the judgment of any knowledgeable security persons (for example, bank security
officials) is not generally publically acknowledged as a vital or crucial threat by most
governmental managers and politicians (even though it is so). And this blindness, or
disingenuous is for good reason, those persons, universally, have a personal stake in the
outcome. Therefore, it is axiomatic that those persons cannot be trusted to decide the
outcome of situation decisions like this one.
No one likes to be caught cheating, particularly if your life and fortune depends
upon not getting caught. Accordingly, this viewpoint is universally controversial in
regard to unlawful voting. But this does not make the cheaters right or honest or worthy
4
Proffered testimony of Dr. Douglas Frank, Exhibit 10, previous filing this case, and
about 324 federal cases (Exhibit A, listing Attached).
15
JA289
of belief. The fox cannot be trusted to guard the henhouse. Neither can nefarious
individuals, regardless of how much their personal or corporate net worth. But that is
where this country has placed its trust at this time. In government, auditing is a dead (or
at least slumbering art).
Indeed, an argument can be made, and this case attempts to do so, that cheating is
encouraged by governmental forces now in power, regardless of political persuasion.
Whether this is governed by foreign forces or not is an open question. Recent events in
the Ukraine Ponzi collapse indicate the probability of those events being a part of the
existing accountability problem impinging upon the entire voting system in the United
States of America.
One example of that would be the insertion of false materials that change the
effective legal status of non-eligible voters, like dead people, people who vote twice in
two states, and people who move out of the state before they vote, and people who lie
about their right to vote or outright forge ballots. For example, alleged printers of ballots,
or election workers who fill out false ballots and then drop them into unguarded and
unsafe drop-boxes (see the documentary based upon actual evidence, 2000 Mules).
These “Fake Filler” ballots are used as a tool to win elections using untraceable
and un-audit-able, fabricated ballots, into official government records flowing throughout
the entire vote recordation system. Examples of this are specified in Attachments to
recent filings with the Court. Accordingly, these materials cannot be deemed speculative.
They either exist of they do not. And none of such factual matters have even been alleged
to be non-existent or false. They somehow just are supposed to be ignored by the Courts
16
JA290
as, perhaps privileged from question because they are election materials.
Accordingly, although RICO is an important part of this filing, it is not the only
component. The central elements of a RICO Case, a conspiracy and creation of a “RICO
Enterprise”. Those elements are some of the central elements in this allegedly multi-
district case, both throughout the State of Maryland as well as across state lines into other
States.
This lawsuit requests remedies under common law fraud, federal and State election
law fraud as well as systemic malfunctions. Some of these are contained in attachments
recently filed in support of injunctive relief. The experts who compiled these reports are
available for testimony if the Court would allow a hearing on these material and relevant
matters. (See attached evidentiary Exhibit C-1, for just a few examples).
All of these malfunctions deny voting rights. If intent to deceive is present, or may
be inferred, both which appear likely other implications including intentional conspiracies
arise. But regardless of intent, the overall effect is to de-facto deny or materially reduce
the effects upon each individual and overall all individuals and his/her joint voting rights
of each group or class so which the voter belongs.
Thereby, each citizen’s property and liberty rights of the a basic unalienable right
guaranteed by the Constitution of the United States and also his/her State of Citizenship,
here, in Maryland, are also violated. Those violations, once they occur are permanent and
unrecoverable once done. As such equitable relief is the only effective remedy and must
be corrected as soon as possible at the source. This is of the essence of this case.
Therefore there is standing for all plaintiffs under our founding documents. Attempts to
17
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pigeon-hole the types of claims are not based upon sound law or the existing obvious
facts of this case.
IV. The State of Maryland Office of the Prosecutor Has

Failed to Maintain and Perform Its Statutory Duty
of Election Oversight
Perhaps uniquely and specifically in the State of Maryland, the Office of the
Maryland State Prosecutor (OMSP) was created by a Constitution Amendment. That
office has as one of its specified duties to ensure a fraud free election environment. The
multiple frauds listed herein have been identified with specificity would seem to satisfy
that requirement of alleging sufficient facts to prevent dismissal under the Rules cited by
defendants, certainly at this stage of this important litigation.
Through that Constitutional Amendment that created it, the Office of the Maryland
State Prosecutor is charged with the responsibility for eliminating fraud from the election
process. This lawsuit alleges and seeks to prove beyond any reasonable doubt (not just a
preponderance of the evidence) that such election fraud has occurred consistently within
the past 10 years. Furthermore, the violations are universal, not just in this state, indeed
throughout the Nation.
Accordingly, the evidence shall be elicited to date, if the Court shall allow such
evidence to be developed through the discovery process into probative evidence, shall
demonstrate the existence of a RICO Enterprise. That RICO Enterprise is alleged to
effectively control at least 43 State Boards of Elections operations5. Dr Douglas Frank,
5
Discovery by Dr. Douglas Frank, referenced in the Second Amended Complaint, (First Amended
Complaint, Exhibit 10) discloses similar evidence in 43 states of vote count manipulation(s) of voter’s
file and vote count flipping from actual recipient and interference by media with official vote tabulation
18
JA292
and an Electronic Engineer, as expert witnesses shall present expert testimony as to the
existence and specificity of one or more RICO Enterprises, in information and belief
linked together to game the elections rolls and systems throughout Maryland and the
Nation. And this is done by commerce across state lines amounting to one or more giant
RICO Enterprises which collect and use and fabricate millions of false votes to maintain
false control of all of this Nation.
Because of the striking nature of these alleged facts, this document is filed under
seal and shall not be disclosed without protection of the Court, and despite and from,
normal government sources. (Like the department of Justice and the FBI).
V. Other Matters
Exhibit C-1, recently filed in support of injunctive relief, is resubmitted hereto as
both expert opinion and evidentiary data supporting the similarity of claims in the several
states, as well as the existence of a RICO Enterprise.
Exhibit 5 to Filing of July 5, 2022. The Court will also please note the about 730
individuals who performed purportedly innocuous Election Related Tasks in one County,
paid for by a Chicago based charity who has donated hundreds of millions of dollars for
similar operations across the country.
Documentation herein is alleged to link those donations, to unlawful distributions
of ballots. Impeachment, of material falsities in that one document alone is expected to
expose the workings of the criminal enterprise in Maryland for those about 739 persons.
Documentation of the actual tasks performed has been obtained and official records are
totals.
19
JA293
expected to be either missing entirely, or conflicting. The existence of a computerized
data base creation and means, as well as thousands of fake ballots in virtually every
national election, both presidential and mid-term.
To be sure, sufficient impeachment evidence has been identified to prove beyond
a shadow of a doubt, to a Grand Jury or a Panel of unbiased Judiciary the existence of
massive and multiple forms of intentional fraud, and likely felonious acts by the principal
perpetrators. Plaintiffs plan to issue subpoenas for documents as soon as practical, and
request a normal scheduling order as soon as the Court indicates approval is appropriate.
Plaintiffs Request Leave to Issue Subpoenas for a 30 (b)(6) Deposition.
Only a minimal discovery effort is required to produce definitive and substantial
evidence of fraud in Maryland which links to the same nation-wide pattern of about nine
different methodologies of systemic vote manipulation fraud. But to date the Maryland
District Court has conducting a hearing, or issuing a Scheduling Order. A Rule 26 (f)
conference has been requested from opposing counsel Daniel Korbin, Esq. This response
requests an expediting of the beginning of discovery now that the Rule 26 (f) request for
discovery has been made by undersigned counsel.
For this reason, these oppositions to the ongoing Motions to Dismiss are
accompanied by a motion to invoke the full force and power of the Constitution inherent
in federal code, § 28 U .S,C §1407. A number of audit type tests, including seizures of
ballots, envelopes and electronic materials are a fertile fields for investigation of ballot
manipulations, whether in chain of custody or mere tabulation and summations of cast
vote totals or other matters.

20
JA294
VI
The Standard for Resisting Dismissal Has Been Overwhelmingly Exceeded:
The principle of law requiring the District Court to take all allegations of facts as
true is invoked for all Exhibits herein as genuine and all allegations as true require this
Honorable Court to overrule all claims of dismissal. In addition, the Honorable Court is
requested to forward the Motion for acceptance by the Multi-District Litigation Panel,
along with the edited, renewed and amplified allegations of Maryland and Nation-Wide
very similar voting systemic fraud disclosed with specificity following as detailed in
Attachments.
Plaintiffs prayers for injunctive relief are renewed by additional election materials.
Specifics of material evidence imbedded therein are listed with the request for
reconsideration in a Ru le 59 (e) motion to alter or amend the application for equitable
relief, as likely necessary for survival of this nation. Further details of the actual evidence
specified to the extent available from currently available sources derived from newly
discovered evidence,
VII. Summary of Relevant Facts.

During and after the 2020 presidential election, plaintiff Lois Ann Gibson,
Maryland 20-20 watch and a committee of injured citizens/voters witnessed a series of
alarming events that combined show a RICO conspiracy between CTCL and 21 Maryland
voting jurisdictions to use CTCL funding to these local election boards to ostensibly for
election administration needs. Examples of grants to Frederick and Carroll County
Election Boards at ECF 1, Exhibit 4. However the amounts for each jurisdiction (ECF 1,
21
JA295
Exhibit 1) demonstrate that jurisdictions that are predominately politically controlled by
Democrats, receive much more per capita than those that are not. This weighting tends to
both politically reward democrats and drive the tax benefits toward those in political
favor.
Additionally, ECF 1, Exhibit 4, provided by the Howard County Election Board, in
lieu of an expected contract between the Board and CTCL, similar to the Frederick and
Carroll County documents, appears to show payments made to individuals in hundreds to
a few thousand dollars, that by no coincidence total the same amount listed for Howard
County in ECF 1, Exhibit 1.
But, at the first opportunity all speculation shall cease, simply because the no tax
payroll funds received shall be analyzed by person and duties to catagorize exactly what
services were fact performed and whether or not any illegal actions or payments, or bribes
actually took place or not. Presumably these payments were to recompense ballot
collection and ballot box distributions. Whether these distributions were of the legal
variety or illegal variety, and with guilty knowledge or not is the question. See Affidavits
at ECF 1, Exhibits 2.1 and 2.2. Finally, current evidence shows an affidavits that alleges
voter fraud via wire fraud and mail fraud at ECF 1, exhibit 3. There is also an affidavit at
ECF-1, Exhibit 1 at document 1.1 which alleges anomalies within the electronic voting
system in Frederick county.
Even without impeachment materials and matters under seal, the evidence already
accumulated thus far indicates a strong RICO case involving voting fraud and production
22
JA296
of unlawful election materials for money. Plaintiff assert that even preliminary further
discovery will greatly expand the amount of evidence to show the full level of election
interference in the 2020 presidential election and in the present mid-term elections as
well.
VIII. Response to Arguments.

A. Dismissal Pursuant to Rule 12(b)(1)
Defendants, State of Maryland, Montgomery, Wicomico, Anne Arundel, Garrett
Washington and Harford Counties argue that this case should be dismissed due to lack of
subject matter jurisdiction. The defendants argue that the plaintiffs have not plead the
requisite factual allegations to give them standing, even if all allegations are considered to
be true by the trial court citing Warth v. Seldon, 422 U.S. 490, 501 (1979) citing Jenkins
v. McKeithen, 395 U.S. 411 (1969). However on point Supreme Court precedent shows
that dilution of an individual’s vote does indeed convey standing to that voter. The
Supreme Court has consistently held in many cases that vote dilution is unconstitutional
See for example Bush v. Gore 531 U.S. 98 (2000): “An early case in our one-person one
vote jurisprudence arose when a State accorded arbitrary and disparate treatment to voters
in its different counties. Gray v. Sanders, 372 U.S. 368 (1963). The Court found a
constitutional violation. We relied on these principles in the context of the Presidential
selection process in Moore v. Ogilvie, 394 U.S. 814 (1969), when we invalidated a
county-based procedure that diluted the influence of citizens in larger counties in the
nomination process. We observed that “[t]he idea that one group can be granted greater
voting strength than another is hostile to the one man, one voted basis of our
23
JA297
representative government.” Id., at 819.” Bush v, Gore at 107. Indeed, in Gray v. Sanders
cited in Bush v. Gore, a single voter who was disenfranchised by a State primary election
apportionment scheme had standing to take a case all the way to the U.S. Supreme Court
and win. In this entire series of cases, violation of the Fourteenth Amendment, Equal
Protection Clause is at issue. See for example Gray v. Sanders at 372.
Additionally, the U.S. Supreme Court has found in other election equal protection
cases involving representative apportionment: Baker v. Carr,, 369 U.S. 186, 206 (1962).
“Thus, voters who allege facts showing disadvantage to themselves as individuals have
standing to sue to remedy that disadvantage.” Baker at 206. Baker is also cited in two
other cases involving gerrymandering: see Gill v. Whitford, 138 S. Ct. 1916 (2018) at
1929 and Reynolds v. Sims, 337 U.S. 533, 561 (1964).
Harford County also cites appeals court law: O’Rourke v. Dominion Voting Sys.
Inc, No. 20-CV-03747-NRN, 201 WL 1662742 (D. Colo. Apr 28, 2021), aff”d, No. 21-
1161, 2022 WL 1699425 (10th Cir. May 27, 2022). Plaintiff notes that this case has been
appealed and was docketed by the United States Supreme Court on September 29, 2022.
In the current case we have numerous plaintiffs, including witnesses to alleged
ballot stuffing, allegedly paid for by CTCL in one case and separate voter fraud involving
ID theft from a voter who moved out of state and presumably mail fraud. Clearly, such
allegations, as a matter of law are construed to be true for the proposes of standing under
rule 12 (b) (6). Each allegation would alone be sufficient to provide subject matter
jurisdiction under rule 12(b)(1).

24
JA298
B. Dismissal Pursuant to Rule 12(b)(6)

Defendant State of Maryland as well as Maryland County defendants argue that
this case does not meet the standard of a plausible claim, because it does not “contain
‘sufficient plausible matter’ to present a ‘plausible’ claim. Ashcroft v. Iqbal, 556 U.S.
662, 678 (2009)” Def. State of Maryland Mot.to Dis. at 4. this must be dismissed pursuant
to rule Fed. R. Civ. P.12(B)(6).
On the contrary, this complaint contains affidavits alleging identity theft, large
scale ballot harvesting and currently unexplained large scale payments to individuals
from non-profit grants which provide sufficient evidence to build a plausible case of
racketeering. The affidavit at ECF-1, Exhibit 3 alleges identity theft for the purposes of
illegally voting. The affidavit at exhibit ECF-1 Exhibit 5 shows a $688,226.00 in
payments made to individuals allegedly by the Howard County Board of Elections. This
is the exact amount of money paid by the Center for Tech and Civic life (CTCL) in the
form of a cash grant to the Howard County Election Board. ECF Exhibit 1. Thus a direct
connection between CTCL and payments to individuals by Howard County has been
established. Clearly, this linkage of current evidence is sufficient to meet the Iqbal
standard. Additionally, ECF-1, Exhibit 1 shows 21 counties (of which 0ne was Howard
County) plus Baltimore City received cash grants in 2020, and ECF-1 Exhibit 2 show
potential ballot harvesting and drop box delivery in Frederick County and Exhibit 3
shows potential identity theft in Carroll County. While these reinforcing links are
conclusory at this stage, they do not make the overall allegation implausible. In deed
these supporting conclusory statements based on circumstantial evidence do not meet the
25
JA299
standard for dismissal under Rule 12(B)(6) at this preliminary state. See: In re Text-
Messaging Anti-Trust Litigation, Case No. 10 8037 at 6 (7th Cir, Dec 29, 2010). There is
sufficient evidence to pursue discovery. All of these allegations must be considered true
and in the manner most favorable to the Plaintiff for the purpose of determining whether
to dismiss. Chambers v. King Buick GMC, LLC, 43 F. Supp.3d 575, 586 (D. Md. 2014.
These exhibits already show sufficient evidence of criminal activity, the question
remaining is whether RICO activity is plausibly asserted. The large quantity of otherwise
unexplained funding shown in EFC-1, exhibit 5 by itself show sufficient grounds for
further investigation.
C. Dismissal Because Plaintiffs Cannot Obtain Relief Requested as a Matter

of Law
Defendants have argued that the United States Court of Appeals, Fourth Circuit in
Hengle v. Treppa ruled that civil RICO does not allow plaintiffs to receive injunctive
relief. Civil RICO is a component of this case designed to identify the contours of a
criminal conspiracy to violate election laws and thus the Constitution of the United States.
However, this lawsuit is requesting injunctive relief to preserve evidence per FRCP 26 (a)
ultimately to address violations of the Constitution and election law. Because TROs were
denied prior to the statutory end date of September 3 for retaining 2020 election records,
the end date has now past. In order to preserve what records have not yet been destroyed,
an injunction must be ordered now to preserve evidence. Additional injunctive relief to
address already committed election law violations and prevent additional Constitutional
and election law violations, is not found under RICO but under respective Constitutional
26
JA300
and election law provisions. The Fourteenth Amendment of the Constitution states:
“…(N)or shall any State deprive any person of life, liberty, or property, without due
process of law, nor to deny any person within its jurisdiction the equal protection of the
laws.” This clause has been interpreted to include protection of every citizen’s legal vote
from dilution by unlawful votes. “(T)he right of suffrage can be denied by a debasement
or dilution of the weight of a citizen’s vote just as effectively as by wholly prohibiting the
free exercise of the franchise.” Reynolds v. Sims, 377 U.S. 533, 555 (1964). This
constitutional right is protected by U.S. Code: “Providing false information concerning a
voter’s name, address or period of residence in order to register to vote, or to vote in a
federal election.” 52 U.S.C. §§ 1307, 20511. See affidavit at ECF 1, exhibit 3, of former
State resident whose residency was changed back to Maryland by a currently unknown
person, and whose name was then used to obtain an absentee ballot, vote in the 2020
election, then changed back. Also see 52 U.S.C § 10307, 18U.S.C. § 597: “Paying voters
to register or to vote in elections where a federal candidate’s name is on the ballot”. See
ECF 1, exhibit 5 and ECF1, exhibits 2.1 and 2.2 for elements of potential ballot
harvesting scheme. The RICO aspect allows for a civil action against conspirators who
enabled the election violations to occur. Civil RICO in this case will allow for triple
expenses and attorneys’ fees.
D. Dismissal Because the Complaint fails to allege the Elements of a RICO

Violation.
Defendant State of Maryland argues that plaintiff fails to meet the elements
necessary to make a RICO case per 18 U.S.C. §§ 1962 & 1964; Defendant argues that
27
JA301
civil RICO “…is not simply a label, as Ms. Gibson uses it but a civil claim requiring
proof of complex elements.” Def. State of Maryland Mot. to Dis. at 6, Citing Sedima
SPRL v. Imrex Co., 473 U.S. 479, 496 (1985). Plaintiff’s case contains all elements
necessary to sustain a RICO case: 1) conduct 2) of an enterprise 3) through a pattern 4) of
racketeering activity 5) that caused injury to business or property interests.
The plaintiffs have met the Sedima standards:

1) conduct: election fraud by registering a current Florida resident in Maryland. ECF-1
(Exhibit 3), paying ballot harvesters using CTCL funding thru a local election board ECF-
1 (Exhibit 4) and funding 21 local election boards using CTCL funding, with
disproportionate funding on a per capita basis to predominately democratic counties.
2) of an enterprise: In accordance with the Cedric Kushner Promotions, Ltd v. King, 533
U.S. 158 (2001), the enterprise alleged is the funding provided by the Center for Tech and
Civic life, to 21 county election boards which operated on two levels: first, to provide a
disproportionate level of funding to twenty county election boards, and Baltimore City,
with more funding per capita where there is a greater proportion of democrat voters, and
secondly in one county already alleged by exhibit 5 of ECF-1, and probably others when
additional evidence is provided, that appear to show the payment of “ballot mules’ to
facilitate the delivery of ballots to drop boxes, with both the drop boxes and mules being
funded by CTCL.
3) through a pattern: A pattern can be shown by either at least two predicate acts, 18
U.S.C. 1961(5) showing a continuity of racketeering activity H.J. Inc. v. Northwestern
28
JA302
Bell Telephone Co. 492 U.S. 229, 239 (1989). This continuity can be shown either by a
closed period of repeated conduct or by past conduct which by its nature projects into the
future. H.J. Inc., 241. This case show both, by repeated transfer of funding from CTCL
to local election boards, and by current election cycle funding (2022) by CTCL.
4) of racketeering activity: 18 U.S.C. § 1961 (1) lists the specific acts that constitute
racketeering activity. The acts of fraud and wire fraud with regard to the use of CTCL
funding (exhibit 5 of ECF-1) to violate constitutional rights and to fund ballot harvesting
and drop box stuffing are the predicate criminal acts of Civil RICO.
5) that caused injury to business or property interests:
Defendants then cite Sedima in stating that unlike other civil causes of action,
RICO must avoid “threatening ordinary commercial transactions”. However, plaintiffs
insist that national elections should not become “ordinary commercial transactions.”
Although cited as a limitation by the Defendants Document 18-1, page 9, Case 1:22-cv-
01642-GLR, that Sedima limits Civil RICO. However, in Sedima, the Supreme Court
actually expanded the ability of plaintiffs to prevail under Civil RICO, by overturning a
Second Circuit ruling that § 1962 of RICO required that an injury must be a “racketeering
injury” not merely a result of racketeering, and that for a civil RICO complaint to be
successful, it must allege that defendants had been convicted of mail or wire fraud or
racketeering. Sedima at 484-485.
Damages caused by the racketeering of Defendants have resulted in plaintiffs’ in
29
JA303
economic losses due to inflation, loss of economic opportunities, loss of value in equity
markets and other markets, loss of value in retirement funds as well as the incalculable
injury from having votes stolen or diluted.
E. Dismissal Because Preliminary Injunctions, Permanent or Temporary

Restraining Orders are not Civil RICO Enterprise remedies.
Defendants Washington and Calvert Counties assert that the remedy of TROs or
Preliminary injunctions are not available due because the Civil RICO statute did not
specifically list injunctive relief as an available remedy to private parties, citing Hengle v.
Treppa, 19 F. 4th 324 (4th Circuit 2021) cert dismissed sub nom, Asner v. Hengle, 212 L.
Ed. 2d 795.
However, the facts of Hengle are different. In Hengle, the plaintiffs were victims
of usurious loans, and one remedy requested was injunctive relief to prevent defendants
from current and future usurious loan activity. Hengle v. Asner Civil No. 3:19 cv 250
(E.D. Va. Feb 20, 2020). While in this current case, Plaintiffs are requesting injunctive
relief, including a TRO in order to preserve evidence.
IX. RELIEF REQUESTED
A. Plaintiffs Request an Evidentiary Hearing on this Motion, and B. Additions to the Classes
of Plaintiffs and C. Additional Defendants (Served Prior to Such Hearing), D. With Leave to
File a Motion for an Amended Complaint to Amend the Complaint for Newly Discovered Facts,
E. With a Renewed Request for Such Equitable Relief and or a Jury, Judicial Panel or this Court
May Fashion.
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X. Conclusion.
For all of the reasons above, the Plaintiffs respectively submit that the Court
should deny Defendants’ Motions to Dismiss pursuant to Federal Rules of Civil
Procedure 12(b)(1), 12(b)(6), for failure to state a claim upon which relief can be granted,
and failure to allege elements of a RICO action. The Court should find the allegations of
the existence of a RICO enterprise at least preliminary well made because all allegations
must me taken as true and the evidentiary attachments have not even been challenged as
incorrect or insufficient. The Court should continue with approval of setting a scheduling
order and approval of subpoenas for documents and electronic documents and associated
preliminary informal discovery; consideration of approval of a request for transfer to the
Multi Division Litigation Panel, and such other actions are will expedite resolution of the
RICO and Constitutional grievances now before this Honorable Court.
Walter T. Charlton
Walter T. Charlton, D.C. Bar # 186940
Maryland Federal Bar # 07636
Walter T. Charlton & Associates
Telephone 410 571-8764
Email charltonwt@comcast.net
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I certify that, on this 22nd day of November, 2022 the foregoing was filed in the
CM/ECF system of the Court, and rejected for technical filing reasons by the Court. and refiled
as corrected as to title, and a proposed Order, and thereafter expected to be served on the 23 day
of November, 2022, upon all registered CMF users in this case with the expectation that it
would be served in due course upon all defendants in this case.
Walter T. Charlton
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Southern Division
LOIS ANN GIBSON, et al. *
Plaintiffs *
v. * Civil Action No.: 1:22-cv-01642-SAG

et al.
*
Defendants *
* * * * * * * * * * * * * *
DEFEDANTS, CALVERT COUNTY, MARYLAND, WASHINGTON COUNTY,
MARYLAND, CARROLL COUNTY, MARYLAND AND KENT COUNTY,
MARYLAND’S REPLY TO PLAINTIFFS’ OPPOSITION TO
DEFENDANTS’ MOTIONS TO DISMISS
BOARD OF COUNTY COMMISSIONERS OF CALVERT, WASHINGTON,
CARROLL and KENT COUNTIES (collectively referred to hereinafter as the
“Counties”), four of the Defendants, by and through their attorneys, KARPINSKI,
CORNBROOKS & KARP, P.A. and KEVIN KARPINSKI, pursuant to Federal Rule
of Civil Procedure 12(b)(6) hereby file this Reply to Plaintiffs’ Opposition to the
Counties’ Motions to Dismiss (the “Opposition”).
INTRODUCTION
This case involves claims brought pursuant to the federal Racketeer
Influenced and Corrupt Organizations (“RICO”) Act, 18 U.S.C. §§ 1961 to 1968.
The Amended Complaint primarily alleges violations of the RICO Act with respect
Page 1 of 14
JA307
to the 2020 election.1 The Counties, as well as other Defendants, filed Motions
to Dismiss the Amended Complaint on various bases, including but not limited
to, the following: (1) that Plaintiffs lack standing; (2) that Plaintiffs have failed to
state a claim upon which relief could be granted; (3) that the county Defendants
do not maintain any oversight into the State elections; and (4) that governmental
entities cannot be liable in civil RICO actions. On or about November 23, 2022,
Plaintiffs filed an opposition to all of those motions.
ARGUMENT
I. PLAINTIFFS LACK STANDING.

To establish standing under Article III, Section 2 of the United States
Constitution, plaintiffs generally must demonstrate and “injury in fact” that is
“concrete and particularized and [ ] actual or imminent, not conjectural or
hypothetical.” Lux v. Judd, 651 F.3d 396, 400 (4th Cir. 2011) (quoting Doe v.
Obama, 631 F.3d 157, 160 (4th Cir. 2011)). Any such “injury in fact” must be
“fairly traceable to the challenged action of the defendant[s]” and “likely, as
opposed to merely speculative, that the injury will be redressed by a favorable
decision.” Friends of the Earth, Inc. v. Laidlaw Envtl. Servs. (TOC), Inc., 528 U.S.
167, 180–81, 210 S.Ct. 693 (2000).
In the Amended Complaint, Plaintiffs fail to allege any actual or imminent
injury in fact. Instead, Plaintiffs badly allege that “the honest functioning of
Maryland’s entire constitutional process is [ ] threatened” and that some
1 The Amended Complaint is not a model of clarity. Even the claims brought by
Plaintiffs are not entirely clear, as Plaintiffs fail to comply with Rule 10(b) which
requires a party to state claims in numbered paragraphs.
Page 2 of 14
JA308
unidentified actions of all Defendants “threaten the stability of the Republic,
threaten to destroy all hope of any fair election process for all time.” Am. Compl.
at ¶¶ 57, 60. In the Opposition, Plaintiffs fail to demonstrate standing and
instead, reiterate more of the same overly broad claims of alleged injuries:
[E]ach citizen’s property and liberty rights of the a [sic] basic

unalienable right guaranteed by the Constitution of the United
States and also his/her State Citizenship, here, in Maryland, are
also violated. Those violations, once they occur are permanent and
unrecoverable once done. As such equitable relief is the only
effective remedy and must be corrected as soon as possible at the
source.
ECF 64, p. 17. Again, Plaintiffs fail to allege any concrete or particularized injury
and, instead, appear to allege some form of broadly based injury on behalf of all
individuals voting in any election in Maryland. This broad assertion of injury
fails to satisfy the injury in fact requirement.
Plaintiffs argue that they have standing based on the Supreme Court’s
decision in Gray v. Sanders, 372 U.S. 368, 83 S.Ct. 801 (1963). However, the
facts of Gray are immediately distinguishable from the instant case and its
holding in no way suggests that the Plaintiffs have standing to bring their
nebulous claims.
In Gray, the Supreme Court considered a case alleging that a Georgia
statute was unconstitutional under the Equal Protection Clause and the Due
Process Clause of the Fourteenth and Seventeenth Amendments. Id. at 370–71,
83 S.Ct. at 803. Under the Georgia law at issue, each county in Georgia was
given a specified number of representatives in the lower House of the Georgia
General Assembly. Id. At the time of the Statewide primaries which the plaintiff
Page 3 of 14
JA309
challenged, the Georgia statute was administered in the following manner:
(1) Candidates for nominations who received the highest number of

popular votes in a county were considered to have carried the county
and to be entitled to two votes for each representative to which the
county is entitled in the lower House of the General Assembly; (2)
the majority of the county unit vote nominated a United States
Senator and Governor; the plurality of the county unit vote
nominated the others.
Id. at 371, 83 S.Ct. at 803–04. The plaintiff in that case was a resident of Fulton
County, Georgia, which comprised 14.11% of Georgia’s population. Id. at 371,
83 S.Ct. at 804. However, under the election procedure set forth under the
Georgia Statute, see supra, all of the votes of Fulton County constituted only
1.46% of the total votes for the election, i.e., only one tenth of Fulton County’s
percentage of the State population. Id. The Supreme Court ultimately held that
the statutory provision at issue was unconstitutional and violated the Equal
Protection and Due Process Clauses. Id. at 381, 83 S.Ct. at 809. Specifically, the
Court held that Georgia’s method of tabulating votes for counties, which gave
every qualified voter in statewide elections one vote, but which, in counting votes,
employed a system that weighed rural votes more heavily than urban votes and
weighted some small rural counties heavier than other large rural counties was
unconstitutional. See id. at 379–81, 83 S.Ct. at 808–09.
In short, Gray involved a clear-cut case of vote dilution. That claim was
based on facts demonstrating concrete and particularized facts establishing
actual injury to the plaintiff therein. Thus, the plaintiff in Gray had standing to
challenge the Georgia statute on that basis. The same cannot be said for the
Plaintiffs in this case. Instead, the Plaintiffs in this case set forth broad and
Page 4 of 14
JA310
vague assertions regarding some form of alleged fraud involving elections within
Maryland and the only injury asserted by Plaintiffs are those on behalf of all
Maryland voters. In other words, the plaintiff in Gray alleged a cognizable,
specific and concrete injury which he allegedly suffered. Whereas, in this case,
Plaintiffs fail to do so. Thus, Plaintiffs lack standing, and this Court should
dismiss the Counties from this case pursuant to Rule 12(b)(1).
Assuming arguendo that Plaintiffs have standing to maintain the present
suit—which they do not—Plaintiffs, at best, allege only speculative and
conclusory factual allegations against the Counties which are insufficient to
withstand the Counties’ Motions to Dismiss under Rule 12(b)(6).
II. PLAINTIFFS FAIL TO ADEQUATELY PLEAD THEIR CLAIMS.
As indicated in the Counties’ Motions to Dismiss, the Amended Complaint
fails to set forth adequate facts regarding any allegedly fraudulent activity
undertaken by the Counties. In fact, the Amended Complaint is devoid of any
specific factual averments concerning any express action taken by the Counties
that would be sufficient to support Plaintiffs’ claims under Rule 12(b)(6).
Generally, a complaint need only satisfy the standard of Rule 8(a), which
requires a “short and plain statement of the claim showing that the pleader is
entitled to relief.” Fed. R. Civ. P. 8(a)(2). “Rule 8(a)(2) still requires a ‘showing,’
rather than a blanket assertion, of entitlement to relief.” Bell Atl. Corp. v.
Twombly, 550 U.S. 544, 555 n.3, 129 S. Ct. 1937, 1977 (2007). That showing
must consist of more than “a formulaic recitation of the elements of a cause of
action” or “naked assertion[s] devoid of further factual enhancement.” Ashcroft
Page 5 of 14
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v. Iqbal, 556 U.S. 662, 677, 129 S. Ct. 1937, 1949 (2009) (citations omitted). In
evaluating a complaint, the Court need not accept unsupported legal allegations.
Revene v. Charles Cty. Comm’rs, 882 F.2d 870, 873 (4th Cir. 1989). Nor must it
agree with the legal conclusions couched as factual allegations, Iqbal, 556 U.S.
at 678–79, 129 S. Ct. at 1949–50, or conclusory factual allegations devoid of any
reference to actual events. United Black Firefighters v. Hirst, 604 F.2d 844, 847
(4th Cir. 1979); see also Francis v. Giacomelli, 588 F.3d 186, 193 (4th Cir. 2009).
“[W]here the well-pleaded facts do not permit the court to infer more than the
mere possibility of misconduct, the complaint has alleged, but it has not ‘show[n]
. . . that the pleader is entitled to relief.” Iqbal, 556 U.S. at 679, 129 S. Ct. at
1950 (quoting Fed. R. Civ. P. 8(a)(2)). Further, “[f]actual allegations must be
enough to raise a right to relief above the speculative level,” id. (internal citation
omitted), to one that is “plausible on its face,” id. at 570, rather than merely
“conceivable[.]” Twombly, 550 U.S. at 570, 127 S. Ct. at 1974.
Additionally, with respect to cases involving alleged fraud, the Federal
Rules impose a heighted pleading standing. Twombly, 550 U.S. at 576 n.3, 127
S. Ct. at 1977 n.3; see Fed. R. Civ. P. 9(b) (“In alleging fraud or mistake, a party
must state with particularity the circumstances constituting fraud or mistake.
Malice, intent, knowledge and other conditions of a person’s mind may be alleged
generally.”) A lack of compliance with Rule 9(b)’s pleading requirements is treated
as a failure to state a claim under Rule 12(b)(6). Harrison v. Westinghouse
Savannah River Co., 176 F.3d 776, 783 n.5 (4th Cir. 1999). Thus, to the extent
Plaintiffs base their claims on some form of alleged fraud, they are required to
Page 6 of 14
JA312
comply with the heightened pleading standard set forth under Rule 9(b) and
Plaintiffs have fail to do so.
The Amended Complaint fails to set forth any cognizable facts with respect
to any of the Counties and—at most—establishes through exhibits that the
Counties received grant funding from the Center for Tech and Civic Life (“CTCL”)
and nothing more. The Amended Complaint does not identify any allegedly
illegal, improper or other actionable facts with respect to the Counties. In fact,
the Amended Complaint is devoid of any express reference to Kent, Calvert or
Washington County and contains no factual averments regarding the actions
taken by those Counties. See generally Am. Cmpl. With respect to Carroll
County, the Amended Complaint only indicates that Carroll County received
grant funding from CTCL and nothing more.2
Simply put, although the Amended Complaint represents that the
Counties received grant funds from CTCL, the Amended Complaint is entirely
devoid of any factual averments or plausible allegations to support Plaintiffs’
generalized contentions that said grant funding was improperly utilized in any
2 As indicated in Carroll County’s Motion to Dismiss, Exhibit 3 of the Amended

Complaint contains an affidavit which alleges that Mr. Kurtis S. Colb received
notice that his voter registration was changed from Clay County, Florida to
Carroll County, Maryland. This change of voter registration was allegedly
performed through fraud and/or forgery. Exhibit 3, however, only alleges
wrongful conduct on behalf of the Maryland Board of Elections, the Maryland
Motor Vehicle Administration and (possibly) the United States Postal Service.
Exhibit 3 fails to set forth any factual representations concerning Carroll
County’s involvement in that alleged wrongdoing. Therefore, in addition to
Plaintiffs’ failure to make any factual averments within the Complaint concerning
Carroll County’s involvement in the acts about which Plaintiffs presently
complain, that affidavit is also insufficient to overcome Carroll County’s Motion
to Dismiss.
Page 7 of 14
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way. Without more, Plaintiffs fail to set forth sufficient factual allegations with
respect to the Counties for the Amended Complaint to survive dismissal under
Rule 12(b)(6) and the standards established in Twombly and Iqbal. Instead,
Plaintiffs set forth entirely speculative and conclusory allegations regarding the
involvement of the Counties and fail to anchor their claims upon any express or
otherwise identifiable actions of any of the Counties.
To the extent Plaintiffs allege any additional factual averments regarding
the Counties’ involvement in the events complained of in their Opposition,
Plaintiffs are not entitled to do so. See Sirmans v. Univ. of Maryland Med. Ctr.,
No. CV CCB-21-618, 2022 WL 596803, at *1 n.5 (D. Md. Feb. 28, 2022)
(“Plaintiffs cannot amend a complaint through opposition briefing.”) (citing S.
Walk at Broadlands Homeowner’s Ass’n, Inc. v. OpenBand at Broadlands, LLC,
713 F.3d 175, 184–85 (4th Cir. 2013)); Olekanma v. Wolfe, Olekanma v. Wolfe,
No. CV DKC 15-0984, 2016 WL 430178, at *1 n.3 (D. Md. Feb. 4, 2016)
(observing that “In his responses to Defendants' motions to dismiss, Plaintiff
offers additional factual context dating back to 2005. . . . The motions to dismiss,
however, test the sufficiency of the amended complaint, and Plaintiff may not
amend his pleading through opposition briefing”). Therefore, any additional
factual averments first introduced in Plaintiffs’ Opposition regarding the
Counties’ alleged involvement should not be considered by this Court.
Accordingly, this Court must dismiss Plaintiffs’ claims with respect to the
Counties.
Page 8 of 14
JA314
III. THE COUNTIES MAINTAIN NO RESPONSIBILTIY FOR THE

OVERSIGHT OF MARYLAND ELECTIONS
The Counties are not proper parties to this suit, because they maintain no
responsibility for the oversight of elections within Maryland. As indicated in the
Motions to Dismiss filed by Washington and Calvert Counties, the relevant
portions of the Election Law Article of the Maryland Code establish that the State
Board of Elections is statutorily tasked with supervising the general operations
of elections within the State of Maryland, including supervising the operations
of Local Boards of Elections. See ECF 18-1 p. 11–14. The only duties individual
counties have with respect to elections are ministerial ones, i.e., appropriating
funding for the operations of Local Boards of Election. Md. Code, Election Law §
2-203.
In the Opposition, Plaintiffs now appear to recognize that the State Board
of Elections is the appropriate entity which exercises oversight of Maryland
elections. See ECF 64 p. 1–3 (referencing actions allegedly taken by the State
Board of Elections); ECF 64 p. 5. Therefore, based on Plaintiffs’ representations
contained within the Oppositions, Plaintiffs appear to now be aware that the
State Board of Elections is tasked with the responsibility for overseeing elections
within Maryland and not individual counties. Accordingly, the Counites are not
proper parties to the instant suit and must be dismissed because they do not
maintain any responsibility for the oversight of elections within the State.
IV. PLAINTIFFS’ RICO CLAIMS MUST BE DISMISSED.
As indicated in the Counties’ Motions to Dismiss, to establish liability in a
civil RICO action, a plaintiff must allege and demonstrate “(1) conduct (2) of an
Page 9 of 14
JA315
enterprise (3) through a pattern (4) of racketeering activity.” Sedima SPRL v.
Imrex Co., 473 U.S. 479, 496 (1985). A plaintiff must also demonstrate that he
or she suffered “compensable injury” from the actions complained of. Id. at 497.
Plaintiffs fail to satisfy any of these requirements. To establish an enterprise, a
plaintiff must demonstrate three elements: “(1) an ongoing organization; (2)
associates functioning as a continuing unit; and (3) the enterprise is an entity
‘separate and apart from the pattern of activity in which it engages.’” Mitchell
Tracey v. First American Title Ins. Co., 935 F. Supp. 2d 826, 842 (D. Md. 2013)
(quoting Proctor v. Metro. Money Store Corp., 645 F. Supp. 2d 464, 477–78 (D.
Md. 2009)).
One type of enterprise defined under § 1961(4) is an associated-in-fact
enterprise. U.S. v. Tillett, 763 F.3d 628, 631 n.2 (4th Cir. 1985). An associated-
in-fact enterprise,
consists of ‘a group of persons associated together for a common

purpose of engaging in a course of conduct’ and thus requires the
existence of ‘an ongoing organization, formal or informal’ and
various members functioning “as a continuing unit.’ Boyle v. United
States, 556 U.S. 938, 944-45, 129 S.Ct. 2237, 173 L.Ed.2d 1265
(2009). It must have certain structural features consisting of: (1)
‘a purpose,’ (2) ‘relationships among those associated with the
enterprise,’ and (3) ‘longevity sufficient to permit these
associates to pursue the enterprise's purpose.’ Id. at 946, 129
S.Ct. 2237.
Starr v. VSL Pharmaceuticals, Inc., 509 F. Supp. 3d 417, 436 (D. Md. 2020)
(emphasis added). To the extent Plaintiffs attempt to allege the existence of an
associated-in-fact enterprise in the Amended Complaint, Plaintiffs fail to make
any factual averments regarding the “structural features” of such an enterprise
Page 10 of 14
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in the Amended Complaint. Instead, the Amended Complaint contains only
threadbare assertions regarding some form of unidentified enterprise, which is
insufficient to plead a civil RICO action.
Plaintiffs contend that the Supreme Court’s decision in Boyle v. U.S.,
resulted in a “liberalization” of the pleading requirements associated with civil
RICO actions. 556 U.S. 938, 129 S. Ct. 2237 (2009); ECF 64, p 5–6. From this,
Plaintiffs further contend that, based on this “liberalization,” Plaintiffs have—
somehow—pleaded a cognizable RICO claim. However, this is not the case.
In Boyle, the Supreme Court considered criminal RICO charges against
several identified individuals who engaged in a pattern of criminal activity,
mainly bank thefts.3 556 U.S. at 940, 129 S. Ct. at 2241. The issue before the
Supreme Court was “whether an association-in-fact enterprise must have ‘an
ascertainable structure beyond that inherent in the pattern of racketing activity
in which it engages.” Id. at 945, 129 S. Ct. at 2244. The Supreme Court
concluded that an association-in-fact enterprise requires some form of structure,
but need not contain an express chain of command, hierarchy or fixed roles. Id.
at 948, 129 S. Ct. at 2245–46. Therefore, to the extent Plaintiffs allege the
existence of an association-in-fact enterprise in this case, they are not required
to establish a hierarchal structure within any such enterprise. However,
Plaintiffs are required to plead the existence of the enterprise, its purpose, the
relationship of entities that constitute such an enterprise and the sufficient
3Moreover, unlike the instant matter, Boyle did not involve a civil RICO claim.
See id.
Page 11 of 14
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longevity of an enterprise to carry out its purposes. Id. at 946, 129 S. Ct. at 2244.
Plaintiffs fail to do so in the Amended Complaint. As such, even in consideration
of Boyle, Plaintiffs have failed to plead a cognizable RICO claim against the
Counties.
Further, as observed by numerous Defendants in this action, a
government entity cannot be held liable in a civil RICO action, “because a
government entity is incapable of forming the requisite intent.” Levy v. City of
New Carrollton, No. CV DKC 2006-2598, 2009 WL 10685579, at *14 (D. Md. Mar.
17, 2009) (citing Brubaker v. City of Richmond, 943 F.2d 1363, 1370 (4th Cir.
1991)). Accordingly, this Court must dismiss the RICO claims against the
Counties.
CONCLUSION
For all the foregoing reasons, the Counties respectfully request that the
Amended Complaint be dismissed with prejudice.
KARPINSKI, CORNBROOKS & KARP, P.A.
BY: /s/Kevin Karpinski

KEVIN KARPINSKI, #11849
AIS #9312150114
120 East Baltimore Street
Suite 1850
Baltimore, Maryland 21202-1617
410-727-5000
Kevin@bkcklaw.com
Counsel for Calvert, Washington,
Kent and Carroll Counties
Page 12 of 14
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I hereby certify that on this 6th day of December 2022, the foregoing was
electronically filed, with notice to:
Walter T. Charlton, Esquire

213 Morgan Street
Washington, DC 20001
Counsel for Plaintiffs
Gary W. Kuc, Esquire

Cynthia Peltzman, Esquire
3450 Court House Drive
Ellicott City, Maryland 21043
Counsel for Defendant Howard County
Gorman E. Getty, III, Esquire

23 Washington Street
Post Office Box 1485
Cumberland, Maryland 21501-1485
Counsel for Defendant Garrett County
David M. Wyand, Esquire

Rosenberg Martin Greenberg, LLP
25 South Charles Street, Suite 2115
Counsel for Defendant Harford County
Gregory J. Swain, Esquire

2660 Riva Road, 4th Floor
Annapolis, Maryland 21401
Counsel for Defendant Anne Arundel County
Wendy L. Shiff, Esquire

Counsel for Defendant Office of the State Prosecutor
Page 13 of 14
JA319
Andrew N. Illuminati, Esquire

Webb, Cornbrooks, Wilber, Douse
Mathers & Illuminati LLP
115 Broad Street
P.O. Box 910
Salisbury, Maryland 21801
Counsel for Defendant Wicomico County
Patricia L. Kane, Esquire

Edward B. Lattner, Esquire
101 Monroe Street, Third Floor
Rockville, Maryland 20850-2540
Counsel for Defendant Montgomery County
Daniel Michael Kobrin, Esquire

Civil Litigation Division
200 Saint Paul Place
20th Floor
Counsel for Defendant State of Maryland
Andrew C. Meehan, Esquire

Patrick W. Thomas, Esquire
MacLeod Law Group, LLC
110 North Cross Street
Chestertown, Maryland 21620
Counsel for Defendants Caroline County, Dorchester County and Talbot
County.
/s/ Kevin Karpinski

Counsel for Calvert, Washington, Kent and
Carroll Counties
Page 14 of 14
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In the
* * * * * * * * * * * * * * * * * * *
Plaintiffs, *
v. * CIVIL NO. 22-CV-1642 SAG
MARYLAND STATE PROSECUTOR’S OFFICE *
et al *
Defendants. *
* * * * * * * * * * * * * * * * * * * * * **
RULE 59(e) MOTION TO ALTER AND AMEND
THE ORDER DISMISSING THIS CASE;
OR ALTERNATIVELY; TO REOPEN,
RECEIVE NEW TESTIMONY, AMEND FINDINGS, CONCLUSIONS,
MANDATES, OR JUDGMENTS AS A MATTER OF LAW (JMOL).
I. Introduction:
This is a F. R Civ. P Rule 59(e) Motion to Alter or Amend the Judgment, and/or
the Reversal of the Order of Dismissal for Failure to State a Claim and entry of a
Declaratory Judgement of existence of Fraud, and/or Treason and/or Civil and/or
Criminal Damages resulting from the Creation of a RICO Enterprise to strip voting rights
and control of government entities from the duly vested voters property, liberty, and civil
rights by money laundering, use of purportedly benign machine equipment which in fact
was on-line capable and in fact used to divert voting rights in Maryland and elsewhere in
the United States of America, and further alleged to use federal facilities in a manner to
both fuel funds to forces dedicated to the overthrow of the liberty, ownership rights , and
management of the citizens of the United States by violation of the election law
limitations and controls by non-lawfully elected forces dedicated to destruction of the
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United States of America’s duly and lawfully elected government subdivisions of all
descriptions.
In this complex fraudulent process a diverse group of citizens have come together
to join the original plaintiffs and discovered that the mechanisms of the frauds encompass
thousands of violations of at least two diverse types which impact the essence of
America, giving standing to sue to all Americans as victims of diverse acts, all
encompassed within the unlawful conspiracy actions of the unlawful conspiracy resulting
in a RICO Enterprise. Details of the actions which are unlawful are described with
particularity following. This description, even without discovery, is therefore believed to
support a judgment of both equitable, statutory, civil rights claims Under 42 U.S.C. Sec
1983, constitutional, loss of freedom, liberty and civil rights claims of virtually unlimited
scope of every American possessing constitutional and statutory procedural, due process,
and property rights vitiated by failure, of governmental units to follow solemn proscribed
conduct of election procedures on a scale hardly imaginable.
During the period of time since the amended complaint was filed and served
additional new material and relevant evidence has been obtained, affecting both the
substance and standing of the very numerous plaintiffs and classes of plaintiffs. Also
many new events of alleged systemic voting system violations have occurred. These new
events have occurred through been a whole new election cycle, the mid-term elections of
November 8th 2022.
Both State and Federal Elections are utterly corrupted. The rights of Citizens to a
secure governance and enforcement of the voting rights laws to all citizens, not just those
in power working for our government as employees.
Standing to sue under the Constitution due process clauses, both the 5th and 14th
Amendments as well as Section 1983 of the civil rights states as expressed in the Bivins v.
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JA322
Unnamed Tobacco and Alcohol officers agents, 403 U.S 388 (1971), the entire series of
cases are now legion, that is Nationwide as demonstrated by details and the affidavits that
support this Rule 59(e) Motion to Alter and Amend the Judgment, and enter a declaratory
judgment and grant injunctive equitable relief in the form of an accelerated hearing or
trial as detailed following to avoid contributing irreparable harm and lost rights.
Now, the demonstrated violations Constitutional and civil rights of citizens both
named plaintiff organizations and ordinary citizens, whose voting rights were falsely
ripped from them, altered by machines controlled by dark money, laundered by
intentional false statements and thousands of transactions of cheating votes recorded and
falsely tabulated in on-line machines. Those machines were used to alter and tabulate
thousands upon thousands of false and altered ballots. The overall methodology is
described utilizing financing by “dark money” paid to printers and process who are
expected and do manipulate both by programmed controls and political payout of the dark
money harvested by means described as alleged following. Ths mechanism has now been
discovered. These acts violate Section 1983 civil rights and alleged RICO civil and
criminal rights, and the voting integrity laws of every state.
Attached to this 59 (e) motion as required by Rule (c) and (e) are Affidavits in the
form of Sworn Declarations. New and material evidence has been discovered of new
facts of two types. 1. Screen Shots computerized active wi-fi on the latest voting day
accompanied by three information technology engineer whistle blowers and 2. What
appears to be thousands of collections from many thousands of persons amounting to
thousands of dollars (each) from unemployed persons. That is massive collections from
persons (Thousands of Times in a two year period). These facts were obtained from the
official Federal Election Commission data covering the entire state of Maryland.
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JA323
(PART 2 Exhibit 2)
The newly discovered data indicates repetitive machine manipulation with
volumes of such magnitude that undreamed of until now has just been discovered. These
facts were disclosed by loyal Americans, Experts describing from many talents and
professions have in the interim since this case was filed by the diligent citizen members of
the classes of plaintiffs. Some of them are professionals functioning as citizen whistle-
blowers. They perform expert investigative functions in this emergency in the absence of
a corrupted, and/or even perhaps complicit Department of Justice and FBI.
That new evidence includes on-line functioning and physical evidence of machine
manipulation of voting machines where such ability was denied to exist by state officials.
But nevertheless occurred. The ability for the voting machines for all ES&S to function
using dedicated network communications, is also corroborated. This claim of innocence
of machine manipulation is also refuted by a former employee of the same supplier
ES&S, Exhibit B, an Independent IT engineer, Preston Smith and further corroborated by
an employee/whistleblower, from Florida, as a formerly with ES&S, the policy
applicable to the entire country treated as a big joke, nationwide. Wide existence is
demonstrated both for the entire country and verified as applicable in Maryland by
declaration by the protected witnesses, of existence of operational systems measured by
three separate members on November 8th, 2022 screen-shots made by a Whistleblower
engineering group in Maryland.
Live screen shots Exhibit A, are supported by a sworn declaration, which refutes
false statements by operators, in Maryland of decades of false testimony, which shall be
demonstrated s to the very Maryland authorities who are charged by the Maryland
Constitution for the duty of security being violated, even as we speak. Enterprise co-
conspirators, some of which are alleged to be agents or employees of defendant Counties
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JA324
and City of Baltimore, and the Maryland State Board of Elections. Facts, including newly
discovered materials and additional expert opinions, have been hidden or simply failed to
be disclosed to the Court of material false information relevant to the allegations of
voting system fraud. And some of those facts are now sufficiently vetted to become
grounds for reopening the case standing alone. Two sets of such material are contained
herein in support of this Motion. In the event this Motion results in reopening the case,
further amendment of pleadings appears likely to enter new facts relevant to the new and
expanded scope of the fraud claims adding further specificity but previously omitted as
additional material and relevant facts from the record.
These individuals and class plaintiffs demand both equitable relief for all injured
parties, as individuals, as members of similar class action groups, and where the law
allows as class or collective actions, with a requested result that all such unlawful
fraudulent activities cease under control of the Federal Courts as a result of a Writ of
Mandamus.
II. Procedural Avenue Requested:
When this newly discovered and hidden evidence is presented to the Court and
reviewed, it shall no doubt be understood, for plaintiffs, acting both for themselves and
similarly situated victims have standing to state both Constitutional claims for themselves
and others. And also to state valid claims of a long-standing existence of a RICO
Enterprise and voluminous and long-standing common law fraud upon both Plaintiffs, the
State of their residence, Maryland as well as property and liberty rights under 28 U.S.C.
Sec 1985 et Seq and the civil and criminal due process requirements of the fifth and
fourteenth Amendments to the Constitution of the United States of America.
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JA325
III. SUMMARY STATEMENT OF NEW FACTS-DECLARATIONS
Note: This Motion Relies Upon Both New Substantive Evidence and Failures and
Abuse of Authority, Including Government Entities De-Facto Participating by
Failure to Control Unlawful Actions within its Own Power; Whether any of this
Rises to Treason is Yet to Be seen as a Matter of Discovery-None Has Yet been
Allowed:
“THE BIG CHEAT”

1. The small group of individuals began this case by filing on July 4, 2022 have now
expanded to a group of citizens professions education levels and skills. This case is not
now about a few diverse observations of chicanery by widely dispersed malcontents.
Instead what has been disclosed is an ongoing conspiracy of immense scope whereby a
very small minority of malcontents seek to transform the state of Maryland and indeed
each of the United States of America into a Communist oligarchy run by the government
itself. As per the requirements of the federal rules of procedure contained in Rule 59(e) &
(c), the following information is not just supported by argument but rather
affidavits/declarations and documents and here in presented as an allegation of absolute
fact that plaintiffs seek to present initially at a hearing on a preliminary injunction with an
acceleration of trial evidence and immediately upon the approval of discovery whether for
the state of Maryland only over the national landscape of all states is for the courts to
decide. The plaintiff’s seek to be class representatives in this class of citizens against a
RICO organization consisting of employees controlling the voting process in each of the
states and thereby also the federal election process (whether or not said process is
correctly administered).
Immediately, filing of this motion to alter or amend the judgment a sister motion
shall be filed in this United States District Court as per the multi district litigation rules
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Part V, of the federal rules of civil procedure now codified in article 28 U.S.C. Section
1407. But to initially introduce the astounding scope of the frauds that have been
committed upon the entire United States, including the structure of the United States
A corrupted system of federal and state laws whereby the federal reporting system
for the financing of votes and voters in the process of voting purportedly maintains fair
and evenly distributed campaign financing funds but in fact has been corrupted to allow
cheating of collections whereby the controls are short-circuited and in fact hugely favored
cheating by outside the country dark money (Soros at Al) and inside the country dark
money whereby certain individuals utilizing controls over the federal election reporting
process in fact collect in hundreds of thousands and millions of quantities payments from
big money donors who are intent upon corrupting the process. In fact they have put
succeeded in this which will be demonstrated in affidavit form following and this a
following recall operation of a RICO enterprise de facto does use this excess of dark
money to cheat in approximately nine different ways using conspiracies between printers
machine manufacturers machine operators in nine different methodologies each one of
which has been observed and measured.
IV. Description of the first major component the cheating with online machines.
First, it must be established incontrovertibly that each voting machine in use in the
great majority of states in the United States and in every County there of do in fact
function online and did so in the past two election cycles:
a. Using a false cover story that the ES&S voting machines were in capable of on line
processing they were in fact used in Maryland in the November 8, 2022 election cycle and
the entire purchasing sales cover story and publicity is to the effect that any such cheating
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is not possible. Testimony by two IT experts familiar with the ES & S machines, refute
this cover story as ridiculous and false in application not just in Maryland but across the
country.
It therefore seems not just likely but positively an accepted fact that the ES&S
machines have been used in the same methodology across the entire country and therefore
well supports the proposition that multi district litigation is appropriate to litigate not just
similar claims but identical RICO claims the same situation also applies as to the
financing of the cheating process. During the election cycle of November 8th, 2020 a
team of information technology professionals employed on government contracts, but
nevertheless Patriots who believe in fair elections volunteered to monitor the election
systems while in use during that election.
This was done in three separate locations by separate professionals. Each of those
professionals took a "screen shot" from their cell phone at the voting location. Each result
was the same. Each cell phone recorded a "live" Wi-Fi connection at the situs of the
voting machines thereby demonstrating that the Wi-Fi machine could be connected to
voting machines if they wished. A written affidavit from one member of the team has
been obtained. However that name is of a whistleblower who states that he undoubtedly
would be fired from his position if it was known that he in fact reported on this violation
of the law. This incident is described as a violation of the law because repeatedly the
Maryland voting authorities emanating from the Maryland State Board of elections had
stated that the voting machines have no online capability, including Wi-Fi, and these three
examples demonstrate that is not only flawless but that they not only have that capability
what were actually using that capability during the past election.
Example number two: a former ES&S employee and professional IT (Exhibit B)
with substantial analytical skills from another state has volunteered information
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confirming that all ES&S voting machine operations in Maryland are the same. They all
function in on-line communication.
Machines originally manufactured by an program by with systems designed by a
company named ES&S. This company was taken over by the federal government in
approximately 2010 and purportedly split into two companies one is ES & S another is
Dominion voting machines on information and belief both of these machines at the
present time are controlled during election day by on-line controls and systems.
Part II
A. Exhibit 2, Attached:
Plaintiffs began their quest to unravel the complexities in the run-up to the interim
election of 2022. MD 20-20 Watch group gathered together in preparation for filing this
case began their investigations much earlier and the group that is responsible for this
lawsuit, they found it necessary to research for a historical perspective. The RICO statute
allows for a 10 year retroactive review. Even preceding the turn of the century that is,
January 1, of the year 2000.
Although counting votes is a very simple mathematical task as president Biden has
openly bragged, with words to the effect that the complexities of vote manipulation are
far from simple and take great skill.
The persons constituting the task force that worked on this lawsuit however also
have great experience and great skill and, nevertheless were unable to comprehend how
such an apparently complex alleged fraud was managed on such a massive scale, live, real
time, in the midst of an Election. This was a confounding problem. However, when a
historical perspective is taken and research discloses the intricacies and understanding of
exactly how the massive fraud has been managed the answers become not just apparent,
but quite simple.
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With the lapse of time required to serve recalcitrant parties, research to develop
proof of these complexities of the alleged fraudulent acts had become possible. This
Motion reports upon both the omissions of violations of voting procedures and law and
newly discovered evidence. Thereby plaintiffs assert that they have demonstrated the
existence of the presence of fraud in election procedures, as well as violations of their
own regulations by the Maryland State Board of Elections and its standard mandated
procedures at each County and City voting locations.
B. Researching, The Complexity of the Vote Fraud(s):
What was confounding to researchers was just how was it possible mechanically,
that is in arithmetic as a matter of engineering, Information Technology (IT), cheat in
multiple elections, through various methods, not just in Maryland but simultaneously
across the country. And not only cheat, but do it with such skill that the winners could be
selected with precision. And do so when the information technology (IT) components, all
of them were sworn and regulated to be internet and programing control (by manager
operators) free from manipulation. The duty sworn through oath of office. In addition,
elected individuals have sworn to uphold their oath of office.
However, some strange occurrences of mathematical impossibilities named for
want of a better term “anomalies” appeared from time to time in the vote counts, and a
few such were noted in Maryland voter record research. Examples were: (1) a consistent
spread in exact percentages across a number of unrelated elections, in the percentage of
spread between competitors, and the second, some rare instances in close contests, where
the eventual number of votes exceeded the number of registered voters. A third, instances
during the election vote counting where vote accumulation actually went down during a
segment of time. Also astounding and mathematically and statistically impossible was
and the same degree of percentage spread, to an exact decimal place, in unrelated
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different elections, even in different States.

Therefore common sense alarms went off, that something radically wrong was
under the surface, and these triggers were the same with the same great precision in
voting contests in varying states, all across the nation.
Approaching the problem from this oblique angle proves fruitful. The only
possible mechanism known to produce these results was online database management
systems with automatic programmed controls. Such systems had begun to be utilized by
government and businesses in America beginning in the early 1980s. Those methods had
become perfected around the turn of the century when these strange result in elections
also began.
In fact, in Maryland, and in 43 states across the nation where data analysis had
been performed by one of plaintiff's expert witnesses, Dr. Douglas Frank, such database
systems had been utilized and were well established in each of those states analyzed.
Fraud was found in all states and also in Maryland.
To pierce the veil of falsity two new items of information were necessary. The
first was the election boards falsely reported, at every turn, under oath, in advertising to
get contracts and budget manipulation that:
(1) The ES&S voting machines had no on line capability and;
(2) were entirely off line during election processing.
Analysis by Expert IT Engineers
To test the truth of this claim of truth and honesty a crew of citizen voters,
professional IT engineers, were requested to make an engineering test of Maryland voting
places for unlawful and illicit on-line functioning “live” of polling places in different
parts of Maryland on interim Election day, November 8th, 2022. That was done and
reported an identical results. The three locations tested each had a “live” Wi-Fi
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Connection at the counting place, connected and running during the “live” voting hours.
A record was made for proof purposes and for presentation as probative evidence
when appropriate. To preclude collection of confidential voter data no confidential or
personal voter data or vote or summation data was recorded nor reported upon.
Nevertheless Attachment A, a whistleblower’s report, with name redacted demonstrates
that the control arm of the State of Maryland, the State Board of Elections has
consistently misstated material facts about two relevant and material systemic election
integrity matters:
These misstatement are:
First, that the ES&S Machines have no on-line capability and;
Second, that the on-line voting machines were not functioning on-line at any time during
election day (presumably that the machines did not even have that capability.
Plaintiffs assert that these facts, and the non-candid reporting and failure to report
these violations of election procedures in each and every voting location in Maryland, on
November 8th, 2022 placed each of those locations as operating in the presence of fraud,
sufficient to void all election results as suspect. But this is not all.
The Second area of concern was: Now that a methodology of keeping track of the
tide of votes and the Count of votes at this Moment, at every Maryland voting place, and
the Maryland State Board voting place and god knows other voting places since the
Maryland Official Voting Administrators lie about their operations, were false and
fraudulent. Since, no surveillance was maintained on drop boxes, as admitted by various
county administrators, it is likely that the remote collections from drop boxes, and mail in
ballots will also be operated in the presence of fraud.
Since plaintiff’s allege on information and belief that: it is now known that on-line
monitoring is not only possible but on-line operations was actually done, the illicit on-line
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monitors know exactly how many more votes are need to cheat and win, in each and
every contest. And once we know, how do we get the votes loaded into the official vote
Count for this contest. As it turned out there are two ways.
(1) Fraudulently change the count totals on any race you want using on-line
program methods delivered to that machine on-line, or simply change the numbers using
on-line transactions methodology built into the machine, and specifically designed by
lacking security measures, to allow such cheating with precision, to a given percent or
magnitude.
(2) Send an order to drop-box couriers to deliver the needed additional false ballots
to one or more of the available drop-boxes or by U.S. Mail. This was facilitated by the
failure to do surveillance on drop-boxes,
(3) And also by suborning printers with large and lucrative contracts, to “harvest”
votes by complex procedures described in the Expert Report Attached and Incorporated
by this reference as Exhibit B.
On information and belief, the same printers, Runbeck Company, was caught
cheating in Florida, were utilized to harvest, fabricate, forge, utter or simply file blank
documents and change the results to reflect a genuine and valid vote when there was
none. (Runbeck provided 4 million ballots to Maryland, by the Secretary of Elections via
evidence of an invoice on the Maryland State Board of Elections website.) The magnitude
of these events, each one a felony, or worse, is for Maryland, in the millions of votes,
sufficient to drive the entire election in any county desired and the State contests as well.
Plaintiffs allege and aver, based upon Part II Exhibit 2, this is what happened. For these
reasons also, the Motion should be granted, and:
An evidentiary hearing after a single round of subpoenas and seizures for
examination of both: all ES&S machines and all electronic voter files and working disks,
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and bulk storage devices, and paper ballots and envelopes should be seized and examined
for presentation as hearing evidence at the accelerated trial pursuant to a renewed Motion
for a Preliminary Injunction by the District or Other Court.
Some of these alleged details are contained in the Attached Expert Report, Exhibit
B, along with the professional’s credentials and a Preliminary Findings Report, based
upon new evidence and the cumulative research to date of plaintiffs, assistants and about
5 sets of professional scientists, vote professionals, and information technology experts to
date. All of which has been conducted in the absence of any of the normal formal
discovery allowed by the Federal Rules of Civil Procedure, which appear to have entirely
broken down in the face of these fraudulent events.
Plaintiffs, in the face of these events offer a preliminary report upon what is
alleged to be, again, without the verification allowed normally by subpoena, a Rule
30(b)(6) deposition which is requested, an evidentiary hearing on apparent false pleadings
and responses by election officers, and ignoring the Constitution of Maryland safeguards
afforded (supposedly but not actually) by the Maryland State Prosecutors’ Office.
Attachment B is incorporated by this reference, and its Statements of Fact
incorporated by this reference subject to verifications, normal in a system of reference
utilizing the normal rules of discovery as contained in the Federal Rules of Civil
Procedure.
Initial inquiries as to the possibility of such a control mechanism existing ran into a
stone wall because although, for example in Maryland, the state Board of elections had
contracted with one of the several manufacturers of voting machines utilized to tabulate
read and compile paper or touchscreen ballots, those voting machines were claimed not to
have online capability, and indeed claimed not to be "online" or subject to operator
control during the "live" voting process.
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IV.
A. “THE BIG CHEAT”--A SUMMARY

The CIVIL AND CRIMINAL RICO FRAUDS UPON THE COURTS
AND THE CITIZENS OF THE UNITED STATES OF AMERICA TO DATE
Summary of the RICO unconstitutional fraud upon American voters:

As an overall mechanism of computerized system design the methodology for
accomplishing the overall objective, that is to dominate all votes by whatever
methodology is necessary is quite simple. Before describing each one of the components
in overall viewpoint is helpful.
The overall fraudulent voting system functions as follows::
A. ON-LINE VOTING CONTROL MARYLAND AND NATIONWIDE:
For any one election, in real time, the most important element required to
prevail is an ongoing knowledge at any moment in time as to how the actual vote count is
running. This element is necessary because only then will the controllers of the system
know the extent to which false votes must be injected into the vote count in order to
prevail. New evidence in several aspects has been discovered as to how this is
accomplished. The answer is very simple. In virtually every state the state Board of
elections maintains on-line data-bases of voters registration. Those files, limited only by
the designer’s imagination, contain all known important voting information about each
voter, Indications from statistical analyses, believed to be functional in each state are
identified and maintained using voters Identification Numbers, or other unique
identification methods.
Each voter thereby can be, and is, separately tracked and his/her electronic record
data base manipulated through any stage of the voting process.
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The next major component is a falsity, that in fact on-line voting machines are not
on-line or interactive electronic units. This falsity is spread and sown, sold as truth, by the
administration of the Maryland State Board of elections and elsewhere where the on-line,
ES&S machines and systems are used. These machines/systems are used throughout the
United States of America, along with similar interactive systems like Dominion.
Again, the falsity is maintained that the voting machines in use:
a. Have no online capability; and;
b. Are never turned on during the election counting process.
In truth enabling control of the entire fraud is this fact:
Investigations throughout the country, and also within the state of Maryland are to
the effect that virtually every ES&S or Dominion voting machine, and every one of its
affiliated subsidiary managing companies not only have an online capability but in fact
MUST AND ARE, in an operational state of being “live and turned on” during the
process of entering ballots and counting the elections.
Nevertheless, this component, the hidden online control mechanism for the fraud,
is the most important aspect of the present election debacle.
The myth was spread by intentional lies to the effect that the Dominion type voting
machines, i.e. “Elections Systems & Software” (ES&S), as marketed by the alleged RICO
Enterprise, in Maryland. Maryland’s voting machines have been consistently and
repeatedly stated by both the State of Maryland Election Board and Officials to have no
online or Wi-Fi capability.
This is simply a false statement, easily refuted, and these plaintiffs have gathered
documentary proof of this fact, “live” from multiple examples in the last Maryland
Election. (See Exhibit A, with testimony affidavit and Screen Shots- By Forensic
Engineering, 1 of 3 whistle blowers that took screen shots).
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It should be noted that in fact the “Claim of the Alleged Lack of an On-line
Capability of the Dominion/ES&S Type Machines” has been repeatedly observed to be
false by system inspections across the country. This falsity when and wheresoever
claimed is easily verifiable or refuted, that is impeached as demonstrably false by a simple
seizure and inspection of all such machines.
Which, as to this case is the initial request for forthwith, and unannounced seizure
to once and for all put this key falsity and associated election fraud to rest 1. At that point
in time, the falsities in propaganda by the manipulated State Election Boards, and subject
to fraudulent voting machine systems shall collapse of its own fraudulent weight.
C. OTHER SYSTEMS FOR ACCUMULATING OR HARVESTING VOTES,

VARY WITH THE IMAGINATION OF THE PERPETRATOR:
Not to diminish the importance of the very important work of identifying the other
about 9 different types of methodologies for harvesting and using couriers to transfer
paper ballots by “Mules” blank ballots being counted or forged ballots being filled out by
1
For example, if the Court grants the alternate relief requested and amends the judgment
the frauds will collapse of their own weight. This would be brought about through the issuance
of Subpoenas, for example, served by U.S. Marshals, and the immediate seizure of each machine
in each voting location, starting with the state of Maryland. Each such machine either does or
does not have on-line capability. Once this proves without a doubt that officials at the Maryland
Board of elections have lied to the courts and have lied to their constituents in each County office
the remedy is simple. Plaintiffs suggest that federal authorities mandated by the Federal Courts,
should seize all such machines throughout the country declare all the results avoid as to any
elections in which those machines were used regardless of how far in the past the retroactive
destruction has occurred. Any other remedy is partial and ineffective. Again, oh by the way
plaintiffs sworn declarations have measured in multiple locations in Maryland the on-line
functioning of the wi-fi at election sites, again contrary to false election officials statements.
They lied. And can easily be demonstrated to have done so across the Country by existing
National Security network subpoenas correlated with Machine seizures in each voting location,
everywhere the machines exist (in over 40 states)..
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election workers, each new type of false action is merely a variation of the theme. Once a
system has been suborned, or corrupted it must be scrapped, and emergency corrections
made to become a functional society again, while a sound and secure system is installed.
This needs to be done here, with an emergency “do over” to fix the election results using
one time tried and true methods, hand counting and signature verification to live people
who are citizens entitled to vote by law, Nothing else will work.
D. CONCLUSION:
From all of this a pattern has arisen which is, finally, perhaps for the first time
subject to definitive proof sufficient to prove intentional fraud by a personal group of
persons traceable by definitive evidence. The activity resulting from the past two
elections consisting of analysis and patterns have resulted in an understanding of what has
actually occurred. This summary, abbreviated down to just the essence describes how the
election frauds work.
V. RELIEF REQUESTED:
This Motion should be granted, and, at least, Judgment should be reserved until
after an evidentiary hearing is allowed, with at least limited discovery and/or a Hearing on
Preliminary Injunctive Relief. To do anything less violates both the Constitution of the
United States of America, Amendment 14, guaranteeing fair elections and the
Constitutional Principle of equal treatment under the law.
Alternatively, partial summary judgment should be granted for liability to follow
Maryland’s own law, including fair elections as a provision of Maryland Constitution,
creating the Office of the Maryland State Prosecutor, with Specific duties to monitor and
prevent the very frauds which are patent in the record right now. In any event a hearing
on this Motion is requested and a demand for a jury trial is renewed.
Accordingly, Plaintiffs request that this Case be reinstated as having demonstrated
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that the relevant grounds for dismissal relied upon by the Court were all falsely stated in
each Defendant’s predicate Motion to Dismiss, or have been refuted by both or either of
new materials identified with sufficient clarity and specificity herein, to prevent dismissal
at this time; or alternatively; to grant the Motion and Judgment, or Partial Summary
Judgment at this time, JMOL.
Walter T. Charlton,
ELECTRONIC SIGNATURE
Walter T. Charlton, D.C. Bar 186040, MD USDC Federal Bar # 07638,
Member of the Bar, Supreme Court of the United States of America, March 28th, 1977.
END OF MOTION TO ALTER OR AMEND OR JMOL
------------------------------
Certificate of Service
I hereby certify that I filed in the Pacer System of the Federal Courts this Motion
pursuant to Federal Rule of Civil Procedure 59(e) to Alter or Amend the Judgment/Order
of Dismissal, together with a Statement of Points and Authorities and proposed Order,
with the expectation that it would be served upon all Parties of Record, on this 13rd day of
January, 2023.
Walter T. Charlton,
Walter T. Charlton, electronic signature, DC Bar # 186940
MD USDC Federal Bar # 07638.
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In the
* * * * * * * * * * * * * * * * * * *
Plaintiffs, *
et al *
Defendants. *
* * * * * * * * * * * * * * * * * * * * * * *
STATEMENT OF POINTS AND AUTHORITIES IN SUPPORT OF
OR ALTERNATIVELY; TO REOPEN,
RECEIVE NEW TESTIMONY, AMEND FINDINGS, CONCLUSIONS,
MANDATES, OR JUDGMENTS AS A MATTER OF LAW (JMOL).
1. WHO GETS to control, The chain of custody over ownership of the right to
vote, i.e. the identity of the voter himself. The voter must verify this, not the record
keeper, NOR CERTAINLY NOT THE KEEPER OF THE COMPANY JULES, OR
SOME POLITICIAN. But that is what is happening.
2. The chain of custody of the counting process, totals cannot be delegated to the
record keepers, the state boards, and certainly not the printers of the ballots for addresses
created by state actors whose jobs depend upon an honest address and identification of the
correct piece of paper or person without verification of any kind by the “owner” the
citizen/voter.
3. That decision, which is universal and WRONG is letting the bankers determine
how much money you have in their bank and make you prove it every time you write a
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check. Having Dominion determine what money (votes) are in Soros’s bank is wrong in
principle. Having Soros/Lamone decide the chain of custody (or having no verification at
all) is approving theft and utterly violating generally accepted accounting principles of
cross-checking and separation of counts of record keeping sum records. Ignoring this
principle is quite simply a license to steal, which has 2now come home to roost, for the
last 22 years, at least.
As the epitome of this disaster, the printers in some jurisdictions (Ref. Arizona, per
trial; Florida, criminal Runbeck; Maryland, Runbeck;) are paid to count the very votes
they fabricated using the false information created by cross-checking voter exit records
and extracting names of no-longer resident voters (Via the Eric System, as just one
example).
4. Each verified registered voter should keep the permanent record of their own
eligibility and each vote made as a permanent instant audit record of that voters record for
each and every election in their lifetime
5. Finally, this case demonstrates the massive extent of the fraudulent voting
process from fake voters to bribery of entire voting districts, to failure of “chain of
custody” to failure of security over on-line machines to manipulating of the on-line
totaling process by state actors who print-up and ship intentionally mis-addressed fake
2
Plaintiffs have already attempted to get discovery for known to exist evidence of the
about 9 different types of vote record and systemic fraud in the District Court and none has been
granted despite repeated allegations of immediate and irreparable harm, nor any hearing
whatever. The new evidence of systemic fraud in the vote process, presented herein therefore is
virtually certain, therefore to be greatly expanded in both scope and complexity during even the
first wave of discovery requested via subpoenas for documents and inspection of equipment, i.e
voting machines, on-line communication and ballot printing equipment.
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and fabricated ballots.
6. And for the Grand Finale, Plaintiffs expert witnesses shall describe to each
voting jurisdiction in each state the extent to which this fraudulent process has functioned
since the election of at least 2020 forward.
II. Status and Timing of This Motion to Alter or Amend the Dismissal of the Claims
of this Case:
This case was originally brought about 6 months ago, when the scope of the alleged
frauds was much less fully known, to both most of these plaintiffs and the rest of the
citizens and voters of this Nation. But the unlawful nefarious practices discovered
recently are of decades older origin.
Contemporaneous, but filed in this case, after this motion, there are filed in the
United States District Court for the District of Maryland two more motions, deemed
necessary by plaintiff's counsel to forestall an utter melt-down, i.e. collapse, with likely
violence likely to rip-apart peaceful American society.
This situation is not unexpected because after all foreign communist sources have
been attempting to bring down our society for decades. For this reason these motions have
all been filed under seal so that this District Court and the associated multi-district panel
may shape the responses without the additional pressures likely to be created should some
of the facts contained herein become general public now knowledge. For this reason also
the scope of matters discussed herein are somewhat wider and more basic than perhaps
would be appropriate under other less stressful circumstances. The first such circumstance
is the standards which should be applicable to judgments involving the most basic
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component parts of the structure of our society. The first such matter to be discussed and a
resolution suggested for further analysis by our most brilliant legal minds who are now in
control of our courts and the deep the judicial system. That first component is the standard
for judgment of fraud upon the court itself and the structure of our society sometimes
known as or viewed as Treason. But also required to be viewed as common law fraud and
the presentation of an counting of the right to vote upon governance of air governmental
structures both the local and national.
III. Plaintiffs’ Statement of Facts Supporting F.R. Civ. P 59(e) Motion to Alter or
Amend the Judgment:
A: Note of Warning, for All Parties and/or all Governmental Officials, State and
Federal Participating in an Official Capacity in this Case:
The Following List of Alleged Facts (B: hereto) are Detailed with Specificity as
Required by the Pleadings Rules Governing Fraud in the State of Maryland. This List is
Made in Good faith based upon all known to exist evidence by undersigned counsel, who
is a long-time member of the Bar of both the District of Columbia, and the United States
Supreme Court. But, in light of the nature of the evidentiary dispute, all disputed facts are
likely subject to a final determination by a trial by jury, which is demanded by Plaintiffs as
to all relevant factual allegations, hence now proffered herein, based upon best evidence
available.
Accordingly, one reason this Motion is filed under seal is that until a reasonable
amount of discovery is completed, the extent to which each Honorable Governmental
Official, including members of law enforcement, like the Federal Bureau of Investigation,
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and Members of the United States Department of Justice, Knew or Should have known of
obvious dishonest actions, like for example, forged or uttered ballots or false statements to
the Courts, were known or should have been known by each of them is a very complex and
detailed question. This question should be asked of each of themselves by each such
member, even of the judiciary, participating in this case as a matter of course.
Extreme penalties upon a party defendant’s criminal activities resulting in
conviction, ranging to felonies and/or even Treason may be, and indeed are expected to be
implicated. This case involves EMERGENCY CONDITIONS. Again, to avoid any
erroneous implications at all, while the necessary discovery is completed, under the
requested Supervision of the Federal Court System each such participating on either side
should take extreme care.
With Newly Discovered Evidence as Modified to Present by Newly Discovered
Evidence of Vote Fraud and a New Discovered Theory of the Essence of the Fraudulent
RICO Scheme---Alleged Based Upon Presently Concealed Evidence Recently Discovered,
and Therefore Known and confirmed to still be in active use and viable as a active as an
unlawful and/or allegedly fraudulent criminal matter as of the date of the last several
elections (and/or when that particular matter was detected or to exist as of the Date of the
Most Recent Election(s).
Because of the complex Sequence of Events, to the Extent any Named Defendant or
Government Attorney or Official Actually Knew or Should have known of the Existence
of the Following Critical Elements of Intentional Fraud, they Also are Actually
Participants in the Fraudulent Schemes, for that Period of Time In Which they, and each of
them, Possessed that Knowledge of the Fraudulent Acts, Yet proceeded to Act in a
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Purportedly but False Governmental Capacity.
B. With the Foregoing Caveat, an Updated Statement of Facts, Systemic Fraud in
Voting Records, Ballots, Procedures and Systems, At Least 2012 to Present Follows:
1 For the first time in the history of mankind the information technology (IT)
and mathematical tools for the measurement of things and the conduct of society may be
judged upon a digital scale of essentially nearly infinite accuracy.
2. As a practical matter this means that Counting of votes of persons, whether
citizens or mere interlopers upon the societal scheme get to voice their opinion is a simple
task.
3. The accuracy of the counting results can be precise to the exact integral count
regardless of how large that count is, and almost as quick as is necessary, and almost with
the precision per voting station (i.e. + or - one vote) as required.
4. Any impression of imprecision in the process is merely propaganda, foisted
upon the public by politicians or opportunists seeking to create seaway or flexibility with
which to cheat on results, totally unnecessary in a well run shop as any large Bank can
give irrefutable evidence. Vote cheating can not occur in a well run shop.
5. Vote error in counts is either a matter of neglect, mechanical or mathematical
failure of equipment or, in the magnitude here as alleged now and proven beyond a
shadow of a doubt, intentional trickery of one type or another for a selfish or truly evil
purpose, for example to bring destruction to our society or our home and world.
6. Nine Kinds of Fraud:
About nine separate types of fraud have been identified as occurring throughout the
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United States brought about by the same RICO Enterprise actors . Examples, reduced to
the specificity required for the traditional proof of common law fraud are available for
presentation to this United States District Court, at trial or preliminary injunction or
however else the District Court wishes to proceed. The only limitation is time and
financial backing required to conduct such inquiries, presentations, and dissemination of
the results to the populace for its understanding along with proof of such overwhelming
volume and clarity that no sane person would deny the existence of the presence of fraud.
Walter T. Charlton,
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In the
* * * * * * * * * * * * * * * * * * *
Plaintiffs, *
v. * CIVIL NO. 22-CV-1642SAG
et al *
Defendants. *
* * * * * * * * * * * * * * * * * * * * * * *
ORDER
Upon consideration of Plaintiffs Motion pursuant to Federal Rule of Civil
Procedure 59(e) and it appearing that falsification of testimony, manipulation of records
and procedures alleged to include money laundering to a very large magnitude has
occurred during the processing of election records for a very long time, at least more than
a decade, and not only within the State of Maryland, but also in many other States, and
further, substantial evidence has been furnished in support of record falsification
pertaining to voting records for the voters and the vote records for the election of
November 8th, 2022, in this District, now therefore, the Motion is Granted, and the case is
reinstated.
Each parties’ counsel, including presently unserved but electronically notified
parties, shall confer and determine the earliest date an emergency hearing on a Preliminary
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JA348
Injunction may be held.
The subject(s) of emergency discovery shall be addressed in the initial
meeting with the Court. That subject shall also be deemed secret and any violation of this
provision by Counsel or clients shall have ramifications against the disclosing party
including Counsel to the fullest extent of the Federal Law. This Motion and all filings in
the Court shall be under seal of this Court, and not appear in any public system pending
further Order of Federal Court.
_________________________________
Judge, United States District Court, Date
-2-
JA349
Exhibit A
Case 1:22-cv-01642-SAG Document 74-1 Filed 01/13/23 Page 1 of P age 1 of 2
------------------------------------------Affidavit------------------------------------
-----Subject: Concerning Maryland Midterm Election at Ballenger Creek Elementary Schoo l------
Whistleblower redactions are
black marks
Frederick, MD 21703
Profession: Engineer, Primary Investigator (Pl), @

(cell, no land line)
I, hereby declare under the penalties of perjury that I am over 18 years of

age, competent to testify, and that the following information is true and correct.
1.Background. Before the midterm election I was told by a colleague of mine at the Lab who
was watching his precinct closely , that I should check to ensure there were no Wi-Fi
connections at the polling site as these might indicate w rongful activities. He also instructed that
I check both outside in the parking lot, and inside for Wi-Fi nodes on my phone. I also visited the
polling site the night before and met Ms. Mary Anne, who introduced herself as the polling site
lead from the Board of Elections. I helped her mark off the distance from the door to the
candidate signs, and moved some of them farther away to make them a legal distance to the
door. The next day I waited until after work and until around 7:30PM to leave for the polling site
as I had learned from the Primaries that when I inserted my ballot into the scanner it would
show my "number" in sequence that day. I wanted to know how many had voted that day at
Ballenger Creek Elementary School.
2. I parked in the parking lot of Ballenger Creek Elementary School, did a Wi-Fi check, and took
a screen shot (Figure # 1, attached). As I approached the polling entry door a kind black woman
-45-50 years old asked me to tum off my phone. I told her I wanted to see if there was active
Wi-Fi in the building. She said, "No, there is no Wi-Fi in the polling place." She was distracted by
another couple who came up, she turned to them and asked them to turn off their phones. At
that moment I just entered the building. As I approached the table of volunteers who checked
your name on the voter rolls, I asked if there are any active Wi-Fi in the building. Both
acknowledged that, "There is no Wi-Fi here." I received my ballot and approached the table with
the white blinds. I saw Ms. Mary Anne from the previous night. I do not know her last name as
her name tag only showed her first name. I asked her if there was active Wi-Fi in the building
and she replied, "No, there is no W i-Fi here." I filled out my ballot and took it to the scanner. I
was number 756, at 7:56 PM. I thought that was quite unique and I texted that fact to my
friends.
3 . Results. I took a screen shot against the rules as I left the polling area and headed toward
the exit door. This showed a number of Wi-Fi nodes as shown in Figure #2 , attached. I cannot
verify nor validate any of the nodes, I can only attest that these were active and picked up by my
personal cell phone.
4. Analysis and Conclusion. Since there were active Wi-Fi nodes inside the polling room, no
one can guarantee this was secure. I work with a number of project and wireless technology
experts and any node can be accessed if it is active. Note in Figure 2 that neither the xfinitywifi
and the FCPSGuest are not secure as ind icated by the lack of a lock icon found on the stewcrew
icon. Second, who is the stewcrew locked access node? It could be any of the staff at the polling
site. It could be a cell phone node. I assume the Bugsbunny node is a cell phone as well, but I do
not know. It too could be used as a remote login node. Under these circumstances stated
above, this polling place was not secure and should be researched.
-----------------------------End of Statement-------------------------------
20 November 2022
JA350
Case 1:22-cv-01642-SAG Document 74-1 Filed 01/13/23 Page 2 of 2 Page 2 of 2

---------------------------------------------------Affidavit ---------------------------------------------
Figure 1, Ballenger Creek Elementary Polling Figure 2, Ballenger Creek Elementary Polling Inside
Parking Lot, 08Nov22; untampered file: by Exit Door, 08Nov22; untampered file:
Screenshot_20221108-194428_Settings Screenshot_20221108-195731_Settings
JA351
Exhibit C and D
Case 1:22-cv-01642-SAG Document 74-3 Filed 01/13/23 Page 1 Summary
of 2
Page 1 of 2
My name is Lisa Batsch-Smith. I am over 18 years of age. I hereby declare under the penalties of perjury
that the factual information contained herein is true and correct and that all opinion testimony is accurate
to the best of my knowledge.
The process of election malfeasance as we have observed:
Fundraising actions:
Fictitious donors with donation matching
Identity theft victims with donation matching
Individuals paid and supplied funds for donation with donation matching
These activities inject larger amounts than allowed by law into donation aggregators (ActBlue, WinRed,
etc.) that disburse both earmarked fund and discretionary funds that go to Non-Governmental
Organizations (NGOs), such as Rock The Vote, etc.
NGO Actions:
Electronic access to voter rolls for addition of voters
Funding for ballot harvesting via gifts for legitimate voters
Mule-ing of ballots into drop box locations
Election Vendor Actions:

Remote networking capability for election monitoring via devices outside of the vote counting
facility
Software with functionality for vote, ballot and database manipulation
Adjudication and duplication functionality that allows for vote manipulation
Ballot printers donating to political organizations that are directly responsible for contracts
Lack of absentee/mail-in ballot chain of custody which allows for multiple ballot printing/ballot
injection
Lack of chain of custody for undeliverable ballots
Poor patching of software to allow for known vulnerabilities to remain on the systems
Unauthorized software installed on machines that provides capability for manipulation
Media Actions:
Election night reporting of vote totals that do not match the results as counted
Demonization of any individual seeking independent verification of election processes or results
Unknown Actor Actions:

Manipulation of voter turnout to intentionally standardize turnouts by age, precinct, etc.
Voter roll manipulation for cloning of voters/duplicate voters
Voter roll manipulation for address/party affiliation/etc. modification
Review of voter rolls over time show modifications that cannot be explained by human behavior with
intentional lack of timestamps for modifications or adequate system logging.
JA352

Page 2 of 2
Post-election Actions:
Risk-limiting Audit structures are designed to prevent detecting certain types of election issues.
Canvassing shows lost votes, mode of voting changes, votes for voters who claim to not have
votes, voters having been denied do to records showing vote by mail by others in their name.
Restriction of citizen auditors from review of documents, equipment and procedures for
verification
Due to all of the above findings from many independent investigations, it is not possible to evaluate the
election process in any state for accuracy, given all of the various modes that are made available for
manipulation.
Lisa Batsch-Smith, P.E.

1/13/2023
JA353
IN THE
UNITED STATES DISTRICT COURT FOR THE DISTRICT OF MARYLAND
LOUIS ANN GIBSON, ET AL., *
Plaintiffs, *
v. * No. 1:22-cv-01642-SAG
*
FREDERICK COUNTY MARYLAND,
ET AL., *
Defendants.
* * * * * * * * * * * *
MARYLAND STATE BOARD OF ELECTIONS OPPOSITION TO RULE 59(E)
MOTION TO ALTER AND AMEND THE ORDER DISMISSING THIS CASE
Defendant Maryland State Board of Elections by counsel, Daniel Kobrin,
Assistant Attorney General, hereby opposes the plaintiffs’ Rule 59(e) motion to alter or
amend the final judgment in this case, ECF 74. This Court should deny the motion,
keeping in place the memorandum opinion, ECF 72, and order, ECF 73, dismissing the
case for lack of subject matter jurisdiction.
STATEMENT OF FACTS
Plaintiffs filed this lawsuit against the State Board of Elections, various Maryland
counties, the Office of the State Prosecutor, and the Center for Tech and Civic Life on
July 5, 2022. ECF 1. The complaint and its amended supplement, ECF 9, alleged a
RICO-style conspiracy amongst the Center for Tech and Civic Life and Maryland
counties for the purpose of fraudulently placing artificial ballots in ballot boxes to
influence the outcome of the 2020 general election. ECF 9 at 5. Plaintiffs sought the
JA354
opportunity to conduct discovery-led investigations into the conspiracy and requested as
relief a preliminary injunction preventing any custodian of election records in Maryland
from destroying materials from the 2020 election. ECF 1 at 30, 34; ECF 9 at 5, ¶81.
Nearly all Maryland counties, the State Board, and the State Prosecutor filed
motions to dismiss. ECF 14, 18, 21, 23, 25, 26, 29, 31, 34, 46, 48, 50, 52, 55, 57, 62, 63,
68, 71. The motions raised multiple substantive and procedural grounds for dismissal.
This Court declined to reach most of those grounds, however, deciding the matter on the
arguments raised surrounding standing and subject matter jurisdiction. ECF 72 at 8-10.
On December 16, 2022, this Court issued a memorandum opinion ruling that
“Plaintiffs lack standing to bring their claims and this Court therefore lacks subject matter
jurisdiction.” ECF 72 at 10. By order dated the same date, this Court granted every
outstanding motion to dismiss, dismissed the case against the remaining Defendants,
denied as moot the plaintiffs’ outstanding motion for service, and directed the Clerk to
the close the case. ECF 73.
Twenty-eight days later, on January 13, 2023, plaintiffs filed a Rule 59(e) motion
to alter or amend the Court’s dismissal. The 29-page filing purports to present a new
theory of election fraud supported by four exhibits. Arguing that improper influence over
the 2022 election was exercised by internet-enabled voting devices, ECF 74 at 15-16, the
motion ultimately asks for a wave of relief predicated on re-opening the matter and
holding an evidentiary hearing, ECF 74 at 18-19. In passing, the motion addresses the
dismissal ruling by stating that: “a diverse group of citizens have come together to join
the original plaintiffs and discovered that the mechanisms of the frauds encompass
2
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thousands of violations of at least two diverse types which impact the essence of
America, giving standing to sue to all Americans as victims of diverse acts.” ECF 74 at
2. The plaintiffs thus request this Court reverse its dismissal order because “[d]uring the
period of time since the amended complaint was filed and served additional new material
and relevant evidence has been obtained, affecting both the substance and standing of the
very numerous plaintiffs and classes of plaintiffs.” ECF 74 at 2.
The “new material and relevant evidence” relied upon by the motion consists of
four exhibits. Exhibit 1 purports to be the November 20, 2022, affidavit of an
anonymous individual. ECF 74-1. The individual reported observing active Wi-Fi
networks in- and around the polling site at Ballenger Creek Elementary School on the
November 8, 2022, general election day.1 ECF 74-1 at 1-2. Exhibit 2 appears to be the
unsigned affidavit of an individual named Preston Smith. ECF 74-2. Mr. Smith reports
observations of election materials he saw while temporarily working in a warehouse in
Florida before and during the 2022 election. ECF 74-2 at 1-2. Exhibit 3 is the affidavit
of an individual named Lisa Batsch-Smith. ECF 74-3. Ms. Batsch-Smith lists
“process[es] of election malfeasance we have observed,” without identifying who “we”
are or which election(s) were observed. ECF 74-3 at 1. Exhibit 4 purports to be an
analysis of campaign finance materials gleaned from the Federal Election Commission’s
1
According to public records maintained by the Maryland State Board of
Elections, the Frederick County Board of Elections sited a polling place inside Ballenger
Creek Elementary School for voting district 2014.1 during the 2022 gubernatorial general
election. Polling Place District List, Md. State Bd. of Elections,
https://www.elections.maryland.gov/elections/2022/GG22_polling%20place%20district
%20list.pdf (Nov. 1, 2022) (last accessed Jan. 26, 2023).
3
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public campaign finance database. ECF 74-4. It concludes that there exists “a
programmatically determined system using an algorithm to seed donations and inject
‘Dark Money’ into the stream of campaign finance donations within the election
process.” ECF 74-4 at 7.
ARGUMENT
I. PLAINTIFFS’ BURDEN TO PREVAIL ON A RULE 59(E) MOTION
Federal Rule of Civil Procedure 59(e) permits a court to reconsider a final
judgment so long as a motion “to alter or amend” that judgment is filed within 28 days of
its entry. The grant of a motion to alter or amend is discretionary, Robison v. Wix
Filtration Corp., LLC, 599 F.3d 403, 411 (4th Cir. 2010), but also an “extraordinary
remedy which should be used sparingly,” Pacific Ins. Co. v. Am. Nat’l Fire Ins. Co., 148
F.3d 396, 403 (4th Cir. 1998). Alteration or amendment of a final judgment under Rule
59(e) permits a district court to “correct its own errors” obviating the need for
“unnecessary appellate proceedings.” Id. at 403.
A Rule 59(e) motion may only be granted under one of three circumstances: “(1)
to accommodate an intervening change in the controlling law; (2) to account for new
evidence not available at trial; or (3) to correct a clear error of law or prevent manifest
injustice.” United States ex rel. Carter v. Halliburton Co., 866 F.3d 199, 210 (4th Cir.
2017). When relying on the second circumstance, newly discovered evidence, the
moving party bears the burden of producing “legitimate justification for not presenting
the evidence during the earlier proceeding.” Pacific Ins. Co, 148 F.3d at 403 (quotation
omitted). A movant cannot prevail by “rais[ing] arguments or present[ing] evidence that
4
JA357
could have been raised prior to the entry of judgment.” Exxon Shipping Co. v. Baker, 554
U.S. 471, 485 n. 5 (2008).
II. PLAINTIFFS’ RULE 59(E) MOTION FAILS TO IDENTIFY NEW EVIDENCE

THAT ADDRESSES THE DISMISSAL FOR LACK OF SUBJECT MATTER
JURISDICTION.
Plaintiffs’ Rule 59(e) motion predicates their request to reopen this lawsuit on
newly discovered evidence. Plaintiffs’ claim falls short in two regards, however. First,
the “new material and relevant evidence,” ECF 74 at 2, is neither new nor relevant.
Three of the four exhibits attached to plaintiffs’ motion contain information that was
available and accessible to the parties while the motions to dismiss were pending before
this Court; and a different three of the four exhibits bear no relevance on the 2020
elections claims or relief requested in the original and amended complaint. Second, the
motion fails to provide legal justification for amending or altering the actual ruling
rendered by this court: lack of subject matter jurisdiction predicated on a lack of standing.
For both reasons, this Court should deny plaintiffs’ Rule 59(e) motion.
Of the four exhibits attached to the Rule 59(e) motion, none provide both new and
relevant information to plaintiffs’ allegations regarding a conspiracy to improperly
influence the 2020 election. Moreover, none of the exhibits speak to a need to preserve
the records of the 2020 election record, which was the relief plaintiffs sought at the outset
of this lawsuit. ECF 1 at 30, 34; ECF 9 at 5, ¶ 81. The exhibits seem to inject a new
theory of electoral fraud, otherwise unconnected to the allegations of the original
complaint.
5
JA358
Exhibit 1 is not new evidence, nor does it speak to the 2020 election. Exhibit 1
was signed and dated November 20, 2022, almost a month before this Court issued its
ruling and order dismissing and closing the case. ECF 74-1 at 1. And the account
recorded in the exhibit speaks only to the conduct of a single polling place on the
November 8, 2022, general election day—the screenshots included in the exhibit are date
stamped “08Nov22.” (ECF 74-1 at 2). Exhibit 1 therefore provides no justification for
amending the dismissal of plaintiffs’ complaint regarding the 2020 election.
Exhibit 2, an unsigned affidavit, is not relevant. It seems to memorialize the
observations of election materials housed in Florida (“Gov. Desantis[sic] had asked them
to save this material,” ECF 74-2 at 2; “I called the FL secretary of states[sic] office to
complain,” ECF 74-2 at 2). The account documented in the exhibit relates nothing about
the conduct of the 2020 presidential election in Maryland. And it contains no indication
that counties in Maryland acted in illegal accord with a Chicago nonprofit corporation.
Exhibit 3, as a list of observed “election malfeasance” (ECF 74-3 at 1), is neither
new evidence nor relevant. The exhibit offers no information about when or where the
malfeasance was observed, nor does it provide a basis for believing that the listed
conduct took place.
And Exhibit 4 is not new. The Federal Election Commission data upon which the
analysis in Exhibit 4 relies, as it related to the 2020 election, was publicly available from
the time plaintiffs filed their complaint on July 5, 2022, until the time this Court
dismissed that complaint on December 16, 2022. Plaintiffs did not provide a “legitimate
justification for not presenting [that] evidence” while the dispositive motions in this case
6
JA359
were pending. Pacific Ins. Co, 148 F.3d at 403 (quotation omitted). Exhibit 4 therefore
cannot provide a basis for granting the Rule 59(e) motion. Exxon Shipping Co., 554 U.S.
at 485 n. 5.
Beyond the failure “to account for new evidence not available” during the
pendency of this case, Halliburton Co., 866 F.3d at 210, plaintiffs’ motion does not
address why this Court dismissed this case. The memorandum opinion reasoned
expressly: “To the extent that they are alleging that governmental entities did not act in
accordance with the law in administering the elections, any injury from those actions
would accrue to every citizen and would not be particularized to Plaintiffs.” ECF 72 at 9.
Accordingly, plaintiffs failed to allege the concrete or particularized injury necessary to
demonstrate standing to maintain a suit. ECF 72 at 9. Without demonstrated standing,
this Court “lack[ed] subject matter jurisdiction.” ECF 72 at 11. Plaintiffs’ motion to
alter or amend therefore needed to demonstrate a viable theory to assert standing.
Plaintiffs motion does not offer any evidence or legal authority to rebut the
Court’s dismissal ruling. Instead, plaintiffs’ motion concedes the point: “a diverse group
of citizens have come together to join the original plaintiffs and discovered that the
mechanisms of the frauds encompass thousands of violations of at least two diverse types
which impact the essence of America, giving standing to sue to all Americans as victims
of diverse acts.” ECF 74 at 2 (emphasis added). There is no concrete or particularized
injury in this suit; there is only injury to the essence of America, which inures to all
Americans equally.
7
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Plaintiffs, therefore, have not carried their burden to alter or amend the dismissal
order in this case. They have forwarded no new and relevant evidence warranting
reconsideration of the Court’s ruling. And there has been no challenge to the legal basis
for the Court’s order.
CONCLUSION
The motion to alter or amend should be denied.
ANTHONY G. BROWN
Attorney General of Maryland

___________________________
DANIEL M. KOBRIN
Federal Bar No. 30392
Assistant Attorney General
dkobrin@oag.state.md.us
(410) 576-6472
(410) 576-6955 (facsimile)
January 26, 2023 Attorneys for Defendant Maryland State

Board of Elections
8
JA361
I certify that, on this 26th day of January, 2023 the foregoing was served by
CM/ECF on all registered CMF, including Plaintiff’s Counsel:

Walter T. Charlton and Associates
213 Morgan Street
Washington, District of Columbia 20001
charltonwt@comcast.net

________________________
Daniel M. Kobrin
9
JA362
In the
* * * * * * * * * * * * * * * * * * *
Plaintiffs, *
et al *
Defendants. *
* * * * * * * * * * * * * * * * * * * * * **
REPLY TO DEFENDANTS’ OPPOSITIONS TO
I. Introduction
This case was dismissed by the Court as to all defendants on essentially two
grounds. First, that the Complaint as filed and Amended once, failed to state a claim.
Second, that each of the alleged Civil RICO plaintiffs did not possess standing to sue.
II Before Proceeding Further the Court is Respectfully Requested to View

the Expert Witness’s Power Point Presentation, Exhibit 10 Hereto.
(Submitted Under Seal as Attachment X to that Report)
Plaintiffs have proceeded with an investigation of election financing data
for the entire State of Maryland and the Nation. Massive, genuine and verified New
Evidence of a comprehensive Nation-Wide money laundering scheme has been
discovered. The RICO defined acts discovered to have been committed violate many
provisions of RICO and other federal statutes as well. Those applicable code sections are
-1-
JA363
presented in detail following. The evidence supporting the conclusions herein is
presented with specificity as extracted from the original evidence also presented in a form
allowing verification by opposing counsel as exactly extracted by a certified engineer,
expert witness.
Because the immediate and irreparable alleged harm continues and now is
demonstrated to be correct as alleged, Plaintiffs respectfully request the opportunity to
present the physical evidence in support of both a Preliminary Injunction at an evidentiary
hearing before the Court or a jury. This evidence, is now available and not before, shall
demonstrate beyond any reasonable doubt the actual existence of the money laundering
and associated banking law violations alleged herein.
However, the bulk PDF data of all Maryland voter transactions is not
presently available for filing in PACER in an acceptable form or format. That evidence is
every donation transaction, and who made it during the election cycles 2019-2020.
Additionally, in a proposed second amended complaint, filed
contemporaneously herewith, plaintiffs file those irrefutable evidentiary details in bulk
form into the record of this case. The originals of that evidence appear in official
government data records available to the general public.
Finally, In addition, plaintiffs are filing contemporaneously with this
Reply, a Motion to Transfer this case, hopefully with this Court’s recommendation to the
Multi-District Litigation Panel for further processing including Equitable, Declaratory
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JA364
and Injunctive relief to prevent further abuses in Maryland (and beyond) as so sorely
needed.
III. The Honorable Court Should Find That Plaintiffs Have Standing to Sue under
Federal Rico Law; Grant the Motion to Alter and Amend the Judgment of
Dismissal, Based upon Massive New and Irrefutable Evidence of Nationwide Rico
Money Laundering, Financial Fraud in Violations of Federal Banking Reports and
Nationwide-Overarching Election Fraud Linked to the RICO Civil and Criminal
Activity.
Plaintiffs in fact sued under, inter alia, the authority of 18 U.S.C. § 1984
(c). That section of the Federal Code states in pertinent part:
“(C) Any person injured in his business or property by reason of a

violation of section 1962 of this chapter may sue therefore in any
appropriate United Stated district court and shall recover threefold the
damages he sustains and the cost of the suit, including a reasonable
attorneys’s fee, except that”... [inapplicable].
Plaintiffs and multiple witnesses, and now new expert witnesses aver based
upon irrefutable evidence obtained from secure government sources that massive multiple
violations of RICO have in fact occurred, primarily involving RICO Enterprise money
laundering and related unlawful activities. Under RICO law the following unlawful
activities occurred in violation of the listed RICO Statutory Section:
Plaintiffs alleged in their original complaint, and in the Amended
Complaint that they were suing under the authority of the RICO Act. Federal Code
contains the following relevant provisions:
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JA365
(Code, Title 18/PART I CHAPTER 96,...
[Selected Applicable Matters].

18 U.S.C Sec 1962, Prohibited activities;
18 U.S.C. Sec 1961, Definitions;
(1) “racketeering activity” means

... bribery, mail fraud...wire fraud...financial institution fraud...obstruction
of criminal investigations...laundering of monetary instruments...illegal
money transmitters...any act that is indictable under the Currency and
Foreign Transactions Reporting Act...
Sec 1961. provides the above definitions and others are “unlawful... [to]...
receive... income...
Sec 1962. “directly or indirectly...from a pattern of racketeering activity”
Summary Discripion of the Newly Discovered Evidence
Since the Original filing of this complaint, on July 4th, 2022 Massive and
highly relevant evidence has been discovered which throws a whole new light on the
events of the past decade (or more) relating to election activity, financing of elections and
money laundering.. This evidence ( all was obtained from public sources, Federal
Government official database files, open to the public) demonstrates the existence of a
massive criminal enterprise functioning right under the noses of authorities in all States
and the District of Columbia. In short, the alleged data control are a criminal farce or
epic proportions.
This new evidence is described in detail, with specificity, in Exhibits and
Data files containing 100% of the financing transactions as reported to the Federal
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JA366
Government pertining to the State of Maryland for the years from 2019 though the two
succeeding election cycles. That evidence and demonstrates injury by, not only all of the
plaintiffs, but each citizen of the United States, functioning in all states and the District of
Columbia. The evidence for Maryland has been reproduced and is available in its original
form in Exhibit 10 to the Expert’s report filed with the plaintiffs proposed Second
Amended Complaint and therefore contained as genuine evidence of Record herein,
Respectfully, this evidence, is not refutable since is entirely based upon and
verifiable to and from and based upon government records (although it may be indeed
incomplete as it was individually filed by the alleged members of the alleged RICO
Enterprise). The Power Point demonstration files attached hereto demonstrate, ( with
accuracy again verifiable and linking to original records), not only the scope of the frauds
in the election process, and link those violations to elections, but also detail how the
frauds occurred, when they occurred, and the magnitude of the false activities performed.
Also the names of the person accomplishing the money laundering, and
related civil and criminal acts. Where is the FBI when we needed them?
For the convenience of the Court although submitted elsewhere, a copy of
these materials are submitted as “under seal” attachments because of the security
implications to each participant in these matters, as well as the criminal implications of all
kinds herein implicated.
The end result is, the RICO wrongs occurred, the injury to each plaintiff is
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JA367
clear, each had some damage or injury, and each voter on both sides of the isle, indeed,
every honest citizen in the Nation is injured by the RICO Enterprise and activities
occurring since at least 2012. All of those who knowingly participated in the falsities and
injury process, one way or another are rightly defendants, but most of the participants are
simply innocent victims. We, as technicians for truth, are simply sickened by these
results and ashamed to be called upon to flesh these matter out to the light of day.
IV. CONCLUSION(S)
(1) For all of the above reasons, the Motion to Alter and Amend should be granted.
(2) The Court should forthwith enter a protective order preserving all documents
pertaining to the election process, at least as far back as the last two election cycles,
starting in 2019 for the State of Maryland.
(3) The Court should recommend with approval the Transfer this case to the MDL
litigation panel, subject to that panel’s acceptance of the Transfer by that panel.
(4) A draft order accomplishing these objectives follows.
Walter T. Charlton,
-6-
JA368
In the
* * * * * * * * * * * * * * * * * **
Plaintiffs, *
et al *
Defendants. *
* * * * * * * * * * * * * * * * * * * * * * *
ORDER
Upon consideration of Plaintiffs Motion pursuant to Federal Rule of Civil
Procedure 59(e) and it appearing that falsification of testimony, manipulation of records
and procedures alleged to include money laundering to a large magnitude has occurred
during the processing of election records for more than a decade, and not only within the
State of Maryland, but also in many other States. Further, substantial evidence has been
furnished in support of record falsification, and copies to Counsel for the Defendants
inviting refutation, or negative response, without adverse comment. (Or Alternatively,
subject to an evidentiary hearing to verify, or allow refutation if such refutation is deemed
possible or likely by the Honorable Judge) pertaining to voting and/or donation records,
financial and banking records) for the voters and the vote records for the elections of
November 3, 2020 and November 8th, 2022, in this District, now therefore, the Motion is
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JA369
Granted, and the case is reinstated.
Each party’s counsel, including presently unserved but electronically
notified party, shall confer and determine the earliest date an emergency hearing on a
Preliminary Injunction may be held.
The subject(s) of emergency discovery shall be addressed in the initial
meeting with the Court. That subject shall also be deemed secret and any violation of this
provision by Counsel or clients shall have ramifications against the disclosing party
including Counsel to the fullest extent of the Federal Law. This Motion and all filings in
the Court shall be under seal of this Court, and not appear in any public system pending
further Order of Federal Court.
___________________________ ______
-2-
JA370
In the
* * * * * * * * * * * * * * * * * * *
Plaintiffs, *
STATE OF MARYLAND, et al *
Defendants. *
* * * * * * * * * * * * * * * * * * * * * **
MOTION TO TRANSFER THIS CASE TO THE
MULTIDISTRICT LITIGATION COURT AND PANEL (MDL)
This motion pursuant to 28 U.S.C., 1407, and Part V of the Federal Rules of
Civil Procedure is a request to transfer this case transfer this case to the Multidistrict
Litigation panel (MDL), of the Federal Judiciary system. In very recently discovered new
and striking evidence, was reported first in this case, in a Reply filed to a Motion to Alter
or Amend the previous dismissal.
That evidence is new and Striking, not only in application to the instant
case, as additional injury to “Business or Property”, but of the existence of a large
(nation-wide) actions by the alleged nationwide RICO Enterprise which crosses party
lines, although predominately participated in by democratic funding organizations. Multi-
State examinations (about 10 to date and more in process) demonstrate that not only that
such evidence exists, but that the evidence is nation-wide in application.
That is, the transfers of money, influencing and affecting local elections in
all states, travels from state to state from money collectors selected by money managers.
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JA371
And such transfers are done with a goal predetermined to avoid/evade all monetary
restrictions which under existing banking, election, Wire and Computer regulating laws
are thereby consigned to the trash heap for the RICO Enterprise participants.
The scope of present examinations is of such magnitude, and detail to allow
inter-state tracing of the funds from source to destination. See pie charts contained in
Exhibit X-1, Page 3-4 hereto. Also the spread sheet, Page 5, containing the names and
amount (cumulative) of all of the thousands of donations for each voter who did in fact
contribute to any campaign, regardless of party affiliation. And all such donations
including the multiple name/address variations, each donation counted as one additional
item and added to the cumulative dollars for that specific donor. The expert’s chart
appearing on page 5 show the results for the top 32 donors of Maryland. The total of just
the top 32 participants in dollars is $ 5,559,429.22. As noted by the Expert, Lisa Smith,
she states,
“The total number of individual donations made in the State of

Maryland from 2019 to 2023 is 9,483,733. The questionable donations are
identifiable due to patterns observed as follows: 1) donors are frequently
listed as “Not Employed” 2) multiple donations are made more than once
per day, 3) small donations are spread out to hundreds of candidates and
committees and 4) donations are made to candidates and committees that
are outside of the state of residency of the donor. [Exhibit X-1, page 2].
The contributors that are donating in this manner make up over half of the
individual donations made in Maryland from 2019 to 2023. “ [Exhibit X-1,
page 2].
This evidence is public information stored in official Federal Election
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JA372
Commission (FEC) databases and therefore the names of all contributors to all elections
may be, and have been, subject to analysis and review by Plaintiffs Expert engineering
witness, Lisa Batsch-Smith, P.E. (See, Exhibit X-1 pg. 6 of 6 ).
Although the money donated was obviously not fungible, nevertheless the
dollars were traceable from the source recorded in the FEC database to the distribution,
even in the bulk to the organization transmitted, by the notations and dollar
apportionment appearing on the transmittal electronic documents. This fact enabled the
expert opinions contained in the engineer’s opinion appearing in Pie Charts on Pages 3
and 4 of her report (See, Exhibit X-1).
II. STATEMENT OF POINTS AND AUTHORITIES

IN SUPPORT OF THIS MOTION TO TRANSFER OF THIS CASE TO THE
MULTIDISTRICT LITIGATION PANEL (MDL):
1. The facts contained in the above body of this Motion, including the
Expert Opinion of Lisa B. Smith, P.E., are incorporated by this reference into these points
and authorities.
2. Also notable is that in this entire analytical engineering process, data
controls were maintained which allow confidence that the computer transaction counts
and dollar totals appearing on the Chart sorted by the thirty-two highest volume donators,
remained accurate throughout the review process, Exhibit X-1, Page 5 of 6 and further
defined in the Expert’s work papers. The methodology used by the engineer to
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accomplish this entire analysis, although proprietary, will be made available as needed by
the Court, or opposing counsel, pursuant to appropriate Order of Court.
3. Accordingly, plaintiffs submit that the engineering calculations are
simply indisputable as to the patterns found to exist, and allow a soundly based
mathematical engineering conclusion as to the probable motives and intent of these high
volume donors in making these apparently illegal donations over the period examined.
4. To the extent any doubt remains in what has actually occurred, in regard
to the individual voters and their donations, for example as a criminal investigation
matter, for example, if so required by the Court or before a jury. Such as, for example, to
determine the magnitude of injury resulting from a specific RICO member’s unlawful
donations, or the magnitude of any specific persons money laundering or alleged wire or
computer fraud, it is expected that each such defendant (and in particular the highest
volume donators) would be subject to subpoena of themselves and their records, for
further example, by the FBI, and deposed regarding the actual source of the money
donated, the methodology used and thereby whether or not, and to what extent these
excessive donations are excessive (or not) is expected to be rare instances of a valid
lawful excuse for such activity.
5. As a conclusion, therefore it is clear as a bell, that Mrs. Smith’s
engineering opinion is not only sound, but is verifiable as such to whatever extent the law
standard of proof requires to determine exactly the extent of the unlawful activity and to
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JA374
what extent each voter/financier violated any one of the existing money laundering and/or
voter financing laws.
6. Further, all previously placed hurdles preventing such abuses are now
overcome by this technology and there is no excuse whatever to delay analysis, except an
unlawful, and indeed evil, attempt by those who have usurped power to continue the
Cheat. That result, is nothing less then a concerted criminal activity to thwart the intent
of our sacred Constitution of the United States of America.
7. The unlawful intent, structure and application of this scheme are striking
when viewed as an unlawful RICO Enterprise conspiracy involving multiple RICO
Enterprise Breaches of the various civil and criminal code.
8. As a Summary of the Case, the Court will please See the pictorial
presentation in PDF format as required for filing with the Court (See Exhibits X-1).
“The Big Cheat”, 6 Pages, is an example of this information is from Expert Lisa Smith,
Engineer, as her Exhibit X-1, Page 6, explains as follows:
“The donations are fractured into small donations for hundreds of

committees and campaigns. The donations made directly to individual
campaigns and then again to the same campaigns via processing platforms,
such as ActBlue and WinRed. The distribution of these donations is
expansive and made in amounts frequently less than $0.25 each. This
activity breaks the visible chain of donation tracing that would allow an
auditor to easily review donations to determine that all campaign finance
laws are being upheld. [See Exhibit X-1, Page 6].
To further obfuscate the ability to trace the donations, the donor

names are not standardized and contain permutations. Many names are
improperly entered and addresses slightly altered. These same permutations
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JA375
are used from year to year so that a simple string search of the donor’s legal
name will not reveal the total number of donations attributed to the donor.”
[See Exhibit X-1, Page 6].
III. Transfer to the Multi-District Litigation (MDL) Panel:
(1) Plaintiffs respectfully request that the United States
District Judge approve the veracity, relevance and materiality of this
Motion, and RECOMMEND APPROVAL OF Transfer to MDL for multi-
district processing of this case. About 600 cases in both State and Federal
Courts are or have been litigating the same issues, or issues likely affected
by the new evidence disclosed herein.
(2) About 10 separate groups in 10 separate states have
learned of this case and have expressed serious interest in joining this effort.
Three letters of intent have been received from now active litigants in the
process of forming committees and drafting complaints.
(3) No advertising efforts have been made to date, primarily
because this evidence and report was not available until today, despite
diligent efforts to accumulate and process the underlying massive evidence.
(4) This Motion is in the obvious economy and practical
interest of the federal court systems, each state, and all honest law abiding
citizens of each and every political party. It shall be opposed only by those
nefarious persons who benefit, either by unlawfully usurping power they do
not deserve or attempt to overthrow our existing Republic and
Constitutional form of Government.
-6-
JA376
(5) In short, this motion favors the overall health, welfare and
all citizens of our beloved United States of America, with order and justice
for ALL lawful political parties and organizations, and all citizens of both
parties who are in favor of law, order and justice for all.
IV. Related Housekeeping Matters.
(1) Plaintiffs allege in that the new evidence demonstrates the
existence of RICO Money Laundering, wire and computer fraud,
conspiracy, banking fraud, violations of the voting finance laws of all states
by acceptance of excessive and/or laundered funds, foreign money, union
and corporate money and camouflage of money donors names, and bribery,
uttering and forgery of documents and likely other RICO violations in
Maryland and similarly in all states.
(2) Those violations shall be proven beyond a reasonable
doubt, or whatever standard is deemed applicable by the Honorable Court to
the variety of criminal and civil abuses found to exist. These findings shall
be proven at any appropriate hearing convened for that purpose, with just
one element necessary for completion.
(3) Subpoenas for evidence pursuant to and preceding several
30(b)(6) depositions with the associated subpoenas for the variety of
evidence needed for the hearing(s) are deemed necessary to separate out the
expected relatively small number of innocent persons who just happen to
appear to be violating the various money laundering laws.
-7-
JA377
(4) This will be done using routine application of normal
discovery principles will undoubtedly exist, which are to a presently
unknown fully total dollar extent. However, the extent to which such
horrific abuses is measured to exist in the original analysis of the ‘low
hanging fruit” appearing in experts initial reports, based upon irrefutable
evidence boggles the imagination entirely. These injuries are to an extent
that leads any reasonable person to consider as entirely possible the eminent
downfall of the Republic.
(5) Amended Pleadings to Incorporate the new Evidence
Are In Process. Although the previous versions of these plaintiffs’
Complaints alleged RICO Enterprise violations of law, including election
law, these specific violations of Money laundering, Wire, banking and
Computer fraud are based upon newly discovered evidence and are
therefore new charges. The RICO activities disclosed apply to all states and
have been in existence since at least 2012.
V. Bulky Evidentiary Matters:
Subject to the acceptance by the MDL Panel, plaintiffs move
the Acceptance of the Bulk Evidentiary Files for all states presently stored
in original form in the FEC databases. Plaintiffs expect to arrange with the
FEC to convert this evidence to the required PDF format for transmission,
or delivery by bulk storage drives, to be submitted as evidentiary
-8-
JA378
attachments, as soon as such may be arranged with the Pacer organization
and the FEC, to convert and to upload the files in acceptable format.
These files are federal records, but not presently stored in
PDF format, at the FEC. Those files shall be converted, en bulk, to PDF for
filing when arranged with Pacer by Plaintiffs expert data processing
witnesses. This process is subject to verification and change to the extent
needed by Court Officials or Pacer and is known to be routine.
However, these files are Bulky, and are therefore the subject
of a separate motion which may take several days to arrange and file.
Plaintiffs, counsel and Expert engineering witness hereby aver that these
files shall be transferred intact, and are true and correct to the best of our
present information and belief.
VII. CONCLUSION:
The Court is requested to grant the Motion for Transfer to
MDL with approval of all contentions of fact therein, subject to challenge at
any time or further Order of Court. The District Court of Maryland should
accept the references and oral Motion to accept as evidence into the record
of this case for all purposes of the data contained in the FEC data bases, that
evidence however being subject to impeachment, or superceding evidence
required to protect the interests of Justice for all Parties.
A ruling accepting the ECF data for the years subsequent to
-9-
JA379
2012, as genuine and verified, for all purposes to application and supporting
an application for and entry of partial summary judgment and/or for
presentation of facts used for a scheduling order by the MDL, or
alternatively this Court in the event the MDL denies the Transfer.
Setting of a hearing on equitable relief as to timing and issues
should be entered for purposes of focusing future hearings and narrowing
the issues to those relevant to all remaining issues in this case. An Order
accomplishing these objectives is attached.
V III. Verification of Counsel
I hereby declare under the penalties of perjury that all facts as
stated herein are true and correct to the best of my present knowledge,
information and belief and that further, the Attachments hereto are genuine
and based upon true and accurate information and data also.
Walter T. Charlton, Md United States District Court Bar # 07638,

Electronic Signature
Walter T. Charlton,

CPA, Md, DC,
Member of the Bar, Supreme Court of the United States of America, March
28th, 1977.
-10-
JA380
11213 Angus Way,

Woodsboro, Maryland 21798
email, charltonwt@comcast.net
Telephone, 410 571 8764
Certificate of Service
I hereby certify that I filed this Motion in the Pacer System of the
United States District Court for the District of Maryland, on the 23rd day of
February 2023 with the expectation that all matters herein including the
Expert opinion of plaintiffs’ expert witness Lisa B. Smith would be served
upon all defendants by the electronic service in the Pacer System.
Walter T. Charlton,
-11-
JA381
In the
* * * * * * * * * * * * * * *
Plaintiffs, *
MARYLAND STATE BOARD OF *
ELECTIONS , MARYLAND STATE *
PROSECUTOR’S OFFICE *
et al *
Defendants. *
* * * * * * * * * * * * * * * * * *
ORDER
Upon consideration of Plaintiffs Motion to Transfer this case,
pursuant to the Federal Rules of Civil Procedure, Part V, regarding
Multidistrict Litigation, and 28 U. S.C. § 1407 (c) (ii) and it appearing
based upon engineering testimony and newly discovered evidence that the
claims of violations in multiple judicial district are similarly and supported
by genuine evidence contained in federal records stored in the files of the
Federal Election Commission, and that further, the issues raised by
plaintiffs pleadings, as amended to date and expected to be further amended
in the near future to contain such evidence as is referenced in verified
allegations contained in this Motion, now therefore, the Court grants this
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JA382
Order approving this Transfer, and further; hereby Orders that this Order
and recommendation requires a Second Amended Complaint to be filed in
this case within 21 days of entry of this Order and that further; service of
process shall be allowed to the single unserved party, the Chicago
Corporation, CTCL as soon as possible utilizing the United States
Marshall’s service which shall be served by Plaintiffs with a copy of this
Order, and it is further Ordered, that the Multidistrict Panel of the United
States Shall be served with a Certified Copy of this Order by the Clerk of
the United States District Court for Maryland.
___________________________ ______
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JA383
Case 1:22-cv-01642-SAG Document 94-1 Filed 02/23/23 Page 6 of 6 Exhibit X-1

Page 6 of 6
Case Number: 1:22-CV-01642-SAG, Exhibit X-1

February 22, 2023
Lisa Batsch-Smith
Electrical and Computer Engineer, P.E
Over 18 years of experience in Electrical and Control Engineering. Professional Engineer licensed in the state of
Florida.
Experience Highlights
August 2022 - Present
Sr. R & D Engineer • DRG Technical Solutions • Asheville, NC
Engineering support for internal development projects for electric power, ITER Control System design, FEMA
project support
March 2021 - Present

Principal Operational Technology Architect • Xcel Energy • Denver, CO
Developed structure for the Operational Technology communications for grid scale OT networks at Xcel Energy.
April 2019 – March 2021

Sandia National Labs • Senior Cyber Research Engineer • Albuquerque, NM
LDRD Idea Selected for FY2021, Received Sandia National Labs Safety Award, Fall 2019, Worked on grid research
related projects with Q/SCI clearance.
December 2008 – March 2019

Control System Engineer • Mitsubishi Hitachi Power Systems Americas • Orlando, FL
Leading, designing, programming & testing controls projects for the MHPSA gas and steam turbine fleet.
2012 - 2013
Adjunct Professor • Seminole State College • Sanford, FL
Taught Computer Operating Systems as community outreach for 2 semesters.
1992 – 1994
Instrumentation and Control Engineer • Raytheon Engineers and Constructors • Alpharetta, GA
Designed control wiring logic and engineering support for nuclear power plants and fossil power plant upgrades.
Education
2008 – present
PhD CpE (in progress) • University of Central Florida • Orlando, FL
2005 – 2010
MSCPE • University of Central Florida • Orlando, FL
1994-1997
MSEE • Mercer University • Atlanta, GA
1987-1992
BSEE • North Carolina State University • Raleigh, NC
Licenses and Patents

➢ FL Professional Engineer Lic#82195
➢ US Patent 11,070,064: Power Plants Using Incongruent Load Imbalance Response
➢ US Patent 11,053,849: Anti Icing Method and Apparatus
➢ US Patent 10,021,072: Security System and Communication Control Method
➢ US Patent 10,753,287: Active Inlet Turbine Control
JA384
Exhibit X-2
Page 1 of 6
Attachment X-2
3/13/2023
Maryland Campaign Finance Review

Methodology
Lisa Batsch-Smith, P.E.
Methodology for Data Collection and Analysis
The data collected for analysis was obtained through the Federal
Election Commission website (https://www.fec.gov). The web interface
for this URL allows for searching the reported contributions and is
located here:
https://www.fec.gov/data/receipts/individual-contributions
This web interface allows for filtering of reported donation entries and
downloading the filtered reported entries for searches containing up to
500,000 entries for each individual search.
In order to obtain all of the files for the donations made in Maryland for
the years 2019 through 2023, the dates were spaced so that each of the
files was as close to 500,000 entries as possible.
The files recorded include the entries show in the following figures:
JA385
Doc: 44
THE BIG CHEAT
Filed: 07/31/2023
RICO ENTERPRISE DATA
MARYLAND & SELECTED STATES
Pg: 395 of 482

A NATION WIDE UNLAWFUL CONSPIRACY TO LAUNDER MONEY AND FINANCE THE ELECTION THEFTS FOR DECADES, UTILIZING TAXPAYERS’
STATE FUNDS IN VIOLATION OF THE FEDERAL CONSTITUTION AND STATE LIMITATIONS ON CORPORATE AND FOREIGN MONEY, BRIBERY,
FORGERY, UTTERING OF BALLOTS AND ELECTION DATA, USING ELECTRONIC DEVICES WITH ON-LINE INTER-ACTIVE VOTING MACHINES.
CASE: 1-22-CV-01642-SAG, ATTACHMENT X-3, R2
JA386
Election Finance Process and Areas of

Opportunity for Malfeasance
Doc: 44
Large
Donor Disbursement back to
Money Disbursement to PACs and campaigns
Earmarked
Filed: 07/31/2023
Funds
Purchase of legitimate
Centralized
NGO 1 mail-in ballots to be cast
collection and
by NGO
distribution
Disbursement to Payment to mules for
Pg: 396 of 482

Discretionary NGO 2 drop box delivery of
Funds absentee ballots
Real and
NGO 3 Voter roll inflation with
Fictitious
fictitious voters
Donor Money
Samples listed here of a larger set.
THE BIG CHEAT 3/13/2023
2
JA387
Sample Contributor Donation Breakdown Charts
Doc: 44
The following charts are in sets of 3.
Each set is for a single contributor in Maryland.
Filed: 07/31/2023
The first slide is a bar chart that shows the total dollar number of contributions made
each year from 2019 to 2022. The colors also shows the permutations if names,
addresses or occupations used for these donation entries.
The second is a breakdown of the committees that received the donations from 2019
to 2023.
Pg: 397 of 482

The third is a breakdown of the committees that were earmarked to received the
donations made through ActBlue or WinRed.

3
JA388
Doc: 44
Filed: 07/31/2023
Pg: 398 of 482
Nancy Doonan
Maryland

4
JA389
Doc: 44
Filed: 07/31/2023
Pg: 399 of 482
THE BIG CHEAT 3/13/2023 5
JA390
Co nt1
r i bu t ion Amount by Committee IN ame 20 119-2023
~
Doc: 44
I DN.C SERVlCES CORP I _ 0:28% ""\
VPPOJ0,4ti!, l
DOOINAN, NAINCY DEMOCRATIC MA.KL 01J.81l6 , \ g 1Ul
SWAlW'EilJL FOR ,c_ _o,_§:8'!(;,~ \ l \u,
PR0GR£SSIVE f _ 0..75,"1!, ~
SEA'N PATRI.CK MAlON.EY FOIL
$217',324.34 0.96~ ---..,

IFilGHIT il'~E R.-_1-?'11, --..._,,
PAC iO iHE.... '0.2Bl'II, -----......
Filed: 07/31/2023
Sum of oontri but io n_receipt _amo unt FRIENDS O_ t 39'11, --......_
SCHIF:F FCL 1.52'11, -----
MARCH IL U4.'I!;,----.
EMILY'SUSil'
11.136''11, - -
NANCV IPElOSI FOR C...
U6'!!;,
1DSOCUS'I!;, - ---- ACJBl.UE 55;0.5-
CArHERINE CORJEZ MA... ..,,,..-

1.99'11,
DEMDCRATICVlCJCIRY PAC. IL __/

.4..lil"ll,
Pg: 400 of 482

octt a.oa'l6,_/

6
JA391
Doc: 44
Filed: 07/31/2023
Pg: 401 of 482
7
JA392
Doc: 44
Filed: 07/31/2023
Pg: 402 of 482
Kathleen Knepper
Maryland

68
JA393
Doc: 44
Filed: 07/31/2023
Pg: 403 of 482
THE BIG CHEAT 3/13/2023 69
JA394
Doc: 44
Filed: 07/31/2023
Pg: 404 of 482
70
JA395
Doc: 44
Filed: 07/31/2023
Pg: 405 of 482
71
JA396
Doc: 44
Sample of
contributors only
from Maryland
Filed: 07/31/2023
Pg: 406 of 482
84
JA397

MARYLAND CTCL GRANT AMOUNTS
AND MARYLAND BLANK BALLOTS CAST- EL45A DATA EXHIBIT Y1
Page 2 of 6
BREAKDOWN OF BALLOTS CAST - BLANK
MONTGOMERY COUNTY MARYLAND
Figure 1.
41,680 Ballots Cast in Montgomery County, MD were classified as “BLANK”
These “BALLOTS CAST – BLANK” comprise 7.77% of all Ballots Cast
JA398
Case 1:22-cv-01642-SAG Document 95-6 Filed 03/17/23 Page 3 of 6EXHIBIT Y1

Page 3 of 6
PRELIMINARY REPORT ON MARYLAND ELECTIONS BLANK BALLOTS

A. BALLOTS CAST – BLANK EXPLAINED
1. The following is a breakdown of the ballots cast in the 2020 November Election for
a single precinct in Baltimore County Maryland. This data was extracted from the
OFFICAL RESULTS ES&S Precinct Summary Report in Detail. This election results
report is referred to as the EL30A report.
The red rectangle represents the total votes cast that were classified as “BALLOTS
CAST – BLANK”. This category of BALLOTS CAST – BLANK can be seen as reflected
in each of the five ballot categories. EV, ED, MB1, Prov, MB2
The blue circled numbers reflect the following:

 Total Number of Blank Ballots Cast
 Blank Ballots as a Percentage of All Ballots Cast In This Precinct
 Blank Ballots Cast In Early Voting
 Blank Ballots Cast On Election Day
 Blank Ballots Cast by Mail in Ballot Category 1
 Blank Ballots Cast as Provisional Ballots
 Blank Ballots Cast by Mail in Ballot Category 2
FIGURE 1
Every single ballot that was cast by a Maryland voter and then
classified as a “BALLOTS CAST – BLANK” is the ballot of a voter being
disenfranchised.
JA399
Exhibit
Case 1:22-cv-01642-SAG Document 95-6 Filed 03/17/23 Page 4 of 6 Y1
Page 4 of 6
Blank ballots being cast in such large numbers are a clear indicator of either voting
system machine hardware errors, software accuracy errors, machine tampering, or
some other illegal activity used to materially affect the outcome of an election.
In this particular precinct in Baltimore County Maryland over 25% of all the ballots
cast by voters have been classified as “BLANK BALLOTS”. See Previous Page
Figure 1.
JA400


And ) Case No. 1:22-CV- 01642 SAG
Who have been Injured in their Business or Property)
By actions of the RICO Enterprise, by Chairman, )
Lewis T. Porter, Investigator/Voter )
et a1 Including all others similarly situated )
Class Representatives who have been injured in their )
Business or Person representing all others Similarly )
Situated, et al; )
)
PLAINTIFFS )
V. )
The State of Maryland, et al )
And )
A RICO Enterprise, de facto operating for at least )
Since 2012, for the unlawful purposes of destruction )
of the Constitutional Rights and voters rights and )
property rights of American People who are Citizens )
entitled to rights, both express and implied by )
The Constitution of the United States and the )
Constitutions of each the Several States )
And )
A Second RICO Enterprise, Containing )
the State of Maryland, )
and/or Methodology to Rig Votes, and Launder )
Money, Used to Rig Votes, et al: )
And/or )
Federal or State Government Employee, with the )
-i-
JA401
NOT Acting with guilty knowledge of the actual facts )

nevertheless, intentionally, or by a conspiracy to alter, )
individually, to place false or knowingly, incorrect, )
materials from the voting process or accountability )
records, or to falsely pay others to falsify or do so )
alone, or in conspiracy with others, thereby aiding and )
abetting the unlawful violations of any citizen’s voting )
rights in any state or jurisdiction, by aiding and )
knowingly or negligently, thereby abetting paying for )
And; )
And )
those classes or Classes of Defendants )
of their Own Acts has aided and abetted the creation or )
And )
-ii-
JA402
And; )
identified as both State of Federal Government )
employees, or private Foreign or Government )
in Fact operating as subsidiary RICO Enterprises, )
numbering in the many dozens, Foreign and Domestic, )
who, by good and verified admissions and verified )
evidence, or at trial on the merits have been convicted )
of criminal acts and/or shall be demonstrated to have )
conspired and/or be found to have or currently are )
activities in violation of Civil or Criminal Due Process )
of Law, to have participated and/or complicit in )
Sedition or Treasonous Acts and/oar knowingly )
Aided and Abetted the Activities Complained of )
herein; have thereby violated the civil and Criminal )
Laws of\r the Constitution of the State of Maryland )
applicable: )
And; )
And: )
The Office of the State Prosecutor, that has )
Enterprises in its Jurisdiction, for Whatever Reason; )
And )
Linda Lamone, Administrator and Director of )
The Maryland State Board of Elections in her personal )
Capacity and as a State Official Alleged to be Directly )
Responsible for both In-State and Multi-State )
Management of Multiple RICO Enterprise activities. )
)
DEFENDANTS )
)
PLAINTIFFS’ MOTION FOR A PRELIMINARY INJUNCTION

AND TO SUPPLEMENT THE RECORD FOR NEWLY DISCOVERED
MATERIAL EVIDENCE OF FRAUD, MONEY LAUNDERING
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JA403
WITH (LIKELY) NATIONAL SECURITY RAMIFICATIONS
THE BIG CHEAT
I. Preliminary Statement: Purpose of this Motion

To Add Supplemental Evidence to the Record:
(Please See, Exhibit X, Overview and Details, Exhibits X-1, Y and Z)1
Between the time this case was filed, on July 4, 2022 plaintiffs volunteers,
assisted by counsel and experts of many disciplines have conducted an investigation of
the various issues of this case centering upon election integrity of the systems and
evidence.
In the meantime a second cycle of election results has become available.
Plaintiffs determined that their investigation would focus upon the last two election cycles
beginning in 2019 and ending now March 2023.
Luckily, much evidence was available for this investigation through federal
government records and, although greatly compromised as to results and integrity of data,
the records of the Maryland State Board of Elections were usable as data sources.
Supplemental information as to methodologies and available evidence across the nation
will be commented upon as appropriate. These sources were also used by volunteers
whenever a key question of representations by election authorities, or outright falsities
were encountered. Unfortunately, unreliability, usually based upon self-preservation,
1
Evidentiary Exhibits X through Z, include Opinions on the veracity and accuracy of
Election Results in Maryland by an Electrical Engineer, who is a certified P.E. All data cited was
derived from official federal and state records and is deemed unassailable. (See Exhibit X to
start review).
-2-
JA404
proved to be the rule rather than the exception. In the meantime, this underlying case was
dismissed by the honorable court for among other things, a technical defense of alleged
"lack of standing to sue". Given the new evidence, leading to a myriad of new claims, a
“Second Amended Complaint is in preparation. Unfortunately, the page count on that
new complaint have now exceeded 110 pages leading to present efforts to consolidate and
shorten the document.
All new evidence confirms plaintiffs initial claims, usually with astounding
similarity. At this time plaintiffs intend to proceed with the path this case is now on,
subject to modifications should some technical error appear at a later time,
The present status of the case is pending reinstatement pursuant to plaintiffs
motion under Rule 59(e) to alter or Amend the Order dismissing the case, primarily for
“lack of standing to sue”. Undaunted, plaintiffs proceeded with the investigations.
The findings of these experts are presented in this motion to supplement the
record because their findings were entirely based upon irrefutable evidence gleaned
directly from government documents. Those findings are horrifying in implications.
With the exception of several technical loose ends that need further verification the thrust
of their findings support their conclusions, the implications are well-established, and
ready for an evidentiary hearing before the Court. Several evidentiary subpoenas and
depositions will complete trial preparation expected to not take more than 90 days. At the
requested hearing for a Preliminary Injunction plaintiffs seek to present existing, or easily
-3-
JA405
obtainable, evidence, and be ready, with the cooperation of defense counsel and a Court
scheduling Order in the quoted 90 days.
The several loose ends remain to be validated by discovery and specificity
verified, before the exact magnitude of the civil damages, irreparable harm, criminal acts,
and most of all national security implications, are fully ready for presentation to the
judicial system. Of course, this is only a sophisticated estimate because of the well-
known explosion of such cases nationwide. Plaintiffs’ experts in this corrective effort
also confirm the present estimate, that about 90 days would be required for this pre-
preliminary injunction effort.
A Concern suggested for consideration among others by the Honorable
Court is: damage to the Nations’ integrity. Although beyond the original scope of this
case, but now appears in the present context of many, many millions of dollars of
unidentified money flowing into a system in a concealed manner. This aspect needs a
very small relative amount of discovery before it can be fully presented to the Court.
This corrective effort is now greatly simplified, in the now strongly
indicated context of a fraud and Racketeering (RICO Enterprise) situation now
uncovered. In that context the ongoing civil investigation concerns plaintiffs sufficiently,
to include such apparently criminal or treasonous evidence in what was, perhaps by
accident, perhaps by divine providence, disclosed in the records now available for
presentation to this Court.
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In the meantime, similar and many times virtually identical evidence of
frauds upon the voters and Courts across the Nation, and frauds upon virtually every
State’s election processing arm have been identified. Those corruptions, and frauds are of
about 9 separate types. If this case proceeds to trial, plaintiffs are prepared to present
evidence on all of those 9 separate fraudulent schemes to cheat citizen voters out of the
effectiveness of their votes.
But, most surprisingly, the methodologies to subvert and corrupt data and
results are sufficiently similar, and the key actors sufficiently identical to indicate with
virtual certainty that the frauds complained of herein are universally applicable across the
country. There seems to be, based upon a large data sample to date, few if any variations
in this statement of fact.
The national interest is implicated because ancillary evidence of influencing
elections, espousing the overthrow of the existing status quo and the Constitution of the
United States has long been known to be the interests of communist foreign powers. And
recent sparse and covered-up evidence recently revisited is that the money laundering
aspect of this revelation below, was known and commented upon by no less than Fox
News in late September 2020 with no follow up (as plaintiffs have now done) and
(apparently) suppressed ever since. This leads to at least a strong suggestion of
implication of fraud, dishonest or worse (Treason) in both the media and arms of this
Nation’s security services, or higher.
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In this regard, the controls over processing of foreign money, indeed
processing all money have been compromised to an extent that this implication of
criminal misconduct of government workers and/or leaders is certain and way beyond
refuting. This is because this conclusion is not an opinion based upon a sample of data.
Virtually all of the data reported by defendants, and all other state data which is kept by
the Federal databases has been reviewed, at least all of the known and reported data.
These facts are believed to be complete and state what actually did occur. So, the
question remains only one. Does this Nation want fair elections or not? If yes, simply
review this data, and let’s have a hearing to test our data and conclusions, and then give
us the power to fix it and we will do so by the next presidential election cycle.
Given that assumption, the only remaining question that needs to be
determined as a factual matter is the identity of the Racketeers, the thieves, and the
magnitude of the threats to national security. And finally, just how can the damages be
mitigated because they are continuing, and what needs to be done to correct the other
destructions of usefulness and integrity of the vote of each citizen in past elections and in
the elections in the foreseeable future.
Most respectfully, they, the State Board of Election workers actually work
for us, not we for them, and by their own rules they have not done their job, leaving the
entire State in this sorry mess. The standard for election results as stated in official
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regulations2 is that each system to be certified must be re-certified each year. And
Maryland simply has not gone through the proper certification for many years.
But, in the information furnished by the Maryland systems, if this question
has been answered correctly in the data furnished, none of the Maryland results are
certifiable for the last two election cycles. According to the standards published the
burden is on the state Board of elections to prove reliability. But they have not performed
these certification tests. And defendants cannot do this, because if they do so, not only
will they fail because the system is beyond redemption. Moreover, the entire “Big Cheat”
scheme (Exhibit X) shall be exposed beyond denial. The data obtained (see Exhibits
series Y-1 following) is simply devoid of any semblance of the required accuracy.
Either that information was furnished to the public incorrectly, or it has
been amended or, for some other unknown reason our logical conclusion is wrong, or not.
If not, which at this stage is the answer of record,then the entire system MUST be
decertified in its entirety along with all results for the past two election cycles. For in that
event all results were obtained unlawfully and in the presence of fraud upon the voters.
Let some intellectually honest person refute this statement if they can, or the need for
decertification to conform to the law has been established. Leaving the wrong results
2
Election System and Software, EVS 5,2,0.0. Certification Report, Election Systems and
Software, page 24 of 27. Excerpt from Maryland State Board of Elections Certification Report,
dated 12/4/2014, never updated and never met requirements. Therefore, it appears that the
monies paid Md’s contractors, ES&S by the federal government were HAVA Grants were
another major government fraud of at least several million dollars.
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stand is simply not in conformance with the law.
Amazingly, this conclusion is entirely independent of the other reasons for
decertification, like using demonstrably corrupt and un-certifiable and unverifiable
machines and data. For example, the last two cycles a total of 98,095 voter ballots in the
2020 election were reported to be blank and a total of 82,356 were found to be blank in
the next, 2022 (last interim) election (See Exhibit Y-1, page 1of 6 Two right column
totals, 98,095 and 82,356).
What this means is that the system was demonstrably either non-functional
or is being manipulated on the machine level. Also, that each blank ballot is either one
voter who has been de-franchised as a voter, or worse, one voter whose vote was turned
upside down by machine manipulation with an undisclosed vote for the opposite
candidate.
Even worse, the computer programs allowing such manipulation were sold
to Maryland and those programs have in fact been reported as de-certified since about
2015 by the Federal Election Commission. The inescapable conclusion is that, at least in
Maryland the ES&S (Expensive) system is so corrupted and incorrect in results as to
require (under its own rules) decertification of all election results as simply not provable
as true and correct by election officials. And the election officials, under the law have
that duty to us, not we to them, nor has any audit been performed or allowed.
This evidence is supplemented by evidence already of record to the effect
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that three separate engineers in the last election cycle recorded on line activity in voting
machines that have been sworn to be impossible of functioning on line. Therefore, the
election officials making a claim of reliability are also either unreliable, lying or more
precisely members of the cabal which is the RICO Enterprise.
Accordingly, the conclusion as a take away on this over all tale of
corruption is that the entire system for the State of Maryland needs to be scrapped,
perhaps with a salvage of the voter rolls subject to a complete audit before any further
corrections can even be logically contemplated. Details follow:
Fortunately, given the technological advances in accounting, auditing, and
forensic investigation of banking and identification of money and people alike, solutions
are available, but only if the legal community and the judicial process in the United States
of America can be trusted. Unfortunately, given the depth of the corruption of the control
mechanisms purportedly set up to control these matters this is indeed a daunting task.
With this preamble plaintiffs respectfully proceed to a description of the newly
discovered evidence.
II. Impact of the Rico Interest Upon Standing

of Each Voter/Citizen’s Right to Sue:
With this filing the proffered RICO Evidence is now before the Court,
verified by two data processing experts and undersigned Counsel. Whether that evidence
meets the standard for acceptance under the federal rules of evidence, is respectfully, a
jury question of mixed law and fact.
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That proffer includes: alleges and offers definitive transactional proof from
federal official records, of money laundering and related activities, damaging,
diminishing, and degrading each citizen’s right to vote, and statutory violations of both
property and liberty rights of each of the plaintiffs to pick their own government. Those
same transactions demonstrate the conspiratorial nature of the acts by which the vote
manipulations occurred.
These plaintiffs certainly did not delegate any of those rights to a State or
Federal agency, nor the alleged RICO Enterprise. which now controls the entire voting
process with its money, which has allegedly bought both manipulable on-line voting
machines (from ES&S) and fake ballots from printers and manipulating programmer
Runbeck and its associates. Thereby losing several other Constitutional liberty and
property interests impacted by the allegedly RICO Enterprise’s existence since about at
least 2012.
Upon a formal finding of the empirical fact, demonstrated to be true by this
document, that there exists a hidden RICO Enterprise has huge implications of a national
security breach. That is, there exists, right now, control of our voting systems and
through that control, de-facto governance our entire society, at the whim of that
Enterprise. Thereby, the coup is complete. All actual unlawful or excessive campaign
donations are under the control of sources aided and abetted with untold, unknown and
unchecked in flow, or amounts of foreign money. And the intent of those acts is well
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known, financing the downfall of our society.
And input to this money laundering scheme is the perfect vehicle for such
nefarious RICO Enterprise activities3.
III. Immediate and Irreparable Harm has Occurred and Is Continuing:
(1) The Relief Sought Is for a Preliminary Injunction and Equitable Relief (Pursuant to
F.R.. Civ. P. 64, 65 (a) and (b));
(2) For Preservation of Evidence: By Seizures of Election Materials, Equipment and
Evidence to Prevent Destruction by the State and Each City and County Government,
With the Intent to Obstruct Justice; and;
(3) Acceleration of the Trial Process to Facilitate the Issuance of Necessary Declaratory
Judgment(s) to Excise Money Laundering From Our Election Systems.
(4) The irreparable harm is of vote manipulation and financial frauds by a RICO
Enterprise impacting national security by allowing the unlawful monies entering the
system to destroy and all citizen’s rights to self-governance. That right is a personal
property right guaranteed by the very existence of the Constitution of the United States of
3
Boyle v. United States, 556 U.S. 938 (2009)(The existence of a RICO Enterprise
is of the essence of a RICO Claim). These plaintiffs have standing if the RICO
Enterprise exists, by reason of injury to their personal and business property rights by the
existence of a money laundering operation that finances corrupted voting machines,
printing of fake ballots purchases manipulation of ballot results (like the blank ballots,
and thereby fixes elections). The resulting corrupted governance (If found to be true) is
the loss of a valuable real and intangible personal property right, the loss by each voting
citizen who there byhas the right to sue under RICO. This Motion so alleges.
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America.
(4) Also, Plaintiffs allege violations of those rights guaranteed under State law, of each
of the discrete states affecting that person who is, or may be personally here, temporarily
or permanently and therefore seized of rights under the Maryland Constitution. One of
those rights is available in the Maryland Constitution, by actions of the Maryland
legislature, in establishing the Constitutionally Created Office of the Maryland State
Prosecutor (MSP).
(5) That office (MSP) has the duty to keep Maryland elections fraud free. That failure is
why that office was sued in this case. They certainly failed in that duty, the reason or
excuse is immaterial and inexcusable. But that failure shall continue so long as the
legislature of Maryland is dominated by one political party who, so far appears to have
failed to adequately fund the MSP. With a budget as small as it is, it is no wonder that
fraud has occurred for decades without any adequate audit, leading to no published
information existing concerning the abuses contained and detailed in this lawsuit. This
oversight is addressed herein as a specific matter because it is a necessary correction to
ever have any hope of a continuing a non-corrupt government of this state.
(6) Accordingly, this matter is strongly suggested for corrective measures as a part of the
Equitable Relief requested herein.
IV. REASSERTION OF STANDING TO SUE:
(7) Plaintiffs allege that the matters listed above evidence immediate and irreparable
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harm, and all of the other matters not so immediate complained of herein, have been
suffered by, to one extent or another, all of the plaintiffs herein, and were caused, to one
extent or another equally by each and every RICO participant as defined by actions of the
RICO Enterprise, each member of which acted knowingly and with malice to create the
harms, and therefore each plaintiffs herein has at least a scintilla of standing to bring this
lawsuit, and that combined each such plaintiff has the actual fact based standing to assert
any and all of the RICO claims, pursuant to Federal Code.
(8) And those RICO acts simultaneously carry with the particular violation the fact that it
is ALSO, a specific violation of federal and state election law. Each such unlawful act
grants standing jurisdiction under both election law and federal Code for RICO. Those
code sections are: 18 U.S.C. §§ 1962-1964 of the RICO act and all such state election
law violations for example the regulations requiring certification of voting machines prior
to any use in a “live” election. (See footnote # 2, page # 6 above).
(9) If these injured voters do not have standing to sue to correct these matters, just who
does. All of the normal law enforcement officials have abdicated the field of battle. Who
is left? Only the citizens with the cohoes to assert their claims. Or maybe the Court
thinks we should just quit and give the Country to the (few) Communists. We think
NOT!
V. ENGINEERING DETAILS OF THE “BIG CHEAT”
A. Exhibit X- The Big Cheat:
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Exhibit X is a flowchart presenting a summary of the RICO Enterprise
viewed for what it is, a description of “The Big Cheat”, in summary pictorial form. The
Chart shows how fungible donated funds are reported to the Federal Elections
Commission (FEC). Identically structured data base files exist in all States.
But that purported source money is reported in large part from sources other
than the person identified as the donor.
In other words, the actual sources are covered up. Those outside sources
are hidden by the large number of donations in very small amounts. Thereby, without
revealing the true and likely unlawful sources of the funds (Read Soros) the donations
utilize multiple names, and apparently automated collection method in the donation
process. The collection system thereby evades detection in the existing federal banking
systems and also as the alleged citizen voter’s name is being used to camouflaged actual
sources, some legal and some illegal. Thereby unlawful funds are injected, laundered, as
it makes its way through the existing state and federal collection process applicable in
Maryland and from, by and to other states.
Also startling is the fact that the “money hose”goes both ways. The excess
funds, i.e. profits from the “RICO Enterprise” are sent BACK whence they come labeled
as “refunds” tracing of such funds also show up in the same transfer records. This
research is now under way! (March 17, 2023)(Again, where is the FBI when we need
them-OTL). Now back to the present task.
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Before starting the review of the explanations of each part of this complex
scheme of election fraud and RICO operations, it is suggested that the Court or reader
refer to the one page power-point summary, Exhibit X, as an overview appearing on the
Flow-Chart Summarizing the known RICO objectives to the date of this filing.
Also, the Honorable Court will please note that the publically disclosed
information on this secret plan to cheat the American Voter is still quickly evolving in the
face of strong opposition by the Criminal Elements and their highly financed legal
experts. The good news is that there are many more honest voters, even in a purportedly
one party state like Maryland, as compared to members of the RICO Enterprise.
And the Honorable Court will also please note that nowhere in this analysis
is a distinction made between Democrat or Republican in either the data or voters.
Criminals and honest folks come in all varieties, Republicans, Democrats, and others.
But this data analysis, and a large number of subpoenas, shall easily separate the honest
citizens from the dishonest few, even in Maryland. That indeed, is the remaining trial
task.
Accordingly, the relief requested in this Motion is necessary to stop the
unlawful bleeding, and should be forthwith Granted. Or more reasonably, as a matter of
an agreed TRO by opposing counsel with the State absorbing all necessary recovery costs.
Indeed, if it takes a trial to force the State to do the right thing, then it will necessarily get
very expensive for the State in costs and Attorney’s fees, because truth will eventually
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win.
The Court is requested to note, that a Motion for leave to file a “Second
Amended Complaint is still in process and nearing completion. But the fire hose of data,
and complexities have now blown-up the complaint to 111 pages, plus hundreds of pages
of evidentiary Exhibits. Because massive Criminal and Civil developments continue to
occur each day, NATIONWIDE, ALL LINKING AND RELATED. (Duplicate sentence
deleted)
The continued indulgence of the Court is appreciated, in allowing time to
finish this massive analysis which is now complete, except for the clean-up. The
continued refraining from ruling based upon an incomplete record while editing and
incorporating those facts into the new complaint is appreciated. The newly discovered
facets of this situation continue to be incorporated into that complaint.
But now it appears that the most massive injury and damages to our great
nation, and each citizen individually must be stopped. And also the nature of the new
evidence and is understood, as this report appears to indicate, the time for a hearing on a
scheduling order approaches. For that reason, plaintiffs request the Court set a hearing on
all matters contained herein, for the near future. Hence, plaintiffs file this request for
relief “to stop the bleeding” forthwith.
VI. Evidentiary Details of this Emergency Motion Follow:
Exhibit X is an Opinion of Plaintiffs Expert Engineer as an Overview of the
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now known situation in Maryland and, in the data as it travels through the RICO system
of laundered money.
Report X-1 (pages and charts one through seven):
Exhibit X-1 is an Engineering Report by plaintiff's Volunteer, Electrical
Engineering and Data expert Lisa Batsch-Smith. P.E. This report describes millions of
small donations, filed in Maryland, as recorded in the files of the Federal Government
Agency, the Federal Election Commission (FEC). The authenticity of the data is thus
unassailable as proffered “Evidence”.
This data reports the many thousands of campaign contributors by specific
donations to recipients, and how the process utilizes camouflaged small donations, in
harvested false (or real) cover names to avoid flagging detection. Thereby all legally
applicable supposed voter, prohibited foreign money and prohibited corporate
contribution controls, and limits placed upon particular candidate contributors, are
EVADED in violation of State voter law, creating the RICO money laundering
mechanism. This technique also evades routine banking and IRS cash control
mechanisms by using a multiplicity of small changes to names and addresses, attempting
to thwart routine alphabetic sorting to identify violations and violators by name and
address.
Those unlawful by-passing evasion mechanisms violate the banking
systems of the United States, the Internal Revenue Service (IRS) control mechanisms of
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the United States. And also are purportedly used to control unlawful transactions in the
banking system linking to drug, and human trafficking money making its way through the
voting contribution collection system leaving in passing through, the evidence in records
of the Federal Election Commission (FEC).
Thereby, every citizen in the United States is damaged in their businesses
and personal property, indeed their entire health and welfare as well as their property.
Accordingly, each citizen in the entire United States (if they have a bank account or use
money) has standing under the CIVIL RICO Statute,
18 U.S.C. §1964 (c)4 to bring this lawsuit.
This report also reveals apparent corruptions have taken place on a massive
scale throughout the United States, in the distribution of the laundered funds everywhere.
That is everywhere needed to buy cheating ensuring a key victory. Accordingly it is
alleged that these records are in fact empirical evidence as appearing in the Federal
Governments’ own records of FEC. This evidence standing alone, demonstrates the truth
4
RICO Act, 2-18-2023 Version: 18 U.S.C. § 1964 (c):
Any person injured in his business or property by reason of section 1962 [listing specific
violations of RICO] may sue therefore in any appropriate United States District Court and
shall recover threefold the damages he sustains and the cost of the suit including a
reasonable attorney ‘s fee....[inapplicable].
Quite obviously, a jury (or a US District Judge) may find as a fact, and thereby assign any
reasonable value to the theft of a persons right to vote, it could be as small as the cost of gasoline
to get to the voting booth, or even to get to the drop box to deposit your ballot. That’s all it takes
to obtain “standing” jurisdiction under a statute. But here, the damages are much greater, the loss
of the Country and that voter’s part of it. How much value will a jury assign to a voter right to
that intangible personal property from now until the end of time? Using this ploy to thwart
discover is just more of the cheat.
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of the abuses herein and self-evidently authorizes all citizens, of whatever party or state,
to sue to protect their own small part of the American Dream. Any citizen has standing
under the constitution to stand for protection of the sanctity of uncorrupted federal
records. And legal niceties on this subject should be deemed simply inapplicable as a
matter of the rule of law itself.
Exhibit X also depicts graphically, the financial flow of what actually
occurred in at least the prior two election cycles. But ample evidence exists of a much
longer existence of the “Enterprise”, it just takes more time and money to sort the existing
FEC data which goes back for several decades and which is available as a part of a lawful
analysis as RICO evidence, under the extended law of the statute of limitations of the
RICO act, 10 years.
To rephrase what purported president Biden actually said, the “Big Cheat”
is actually a highly effective scheme and scam, for processing unlawfully contributed
sums which have evaded virtually all controls over the money flow into the campaigns in
this wonderfully intricate and crooked system (as admitted to exist by Biden).
Plaintiff's allege that not only are the purported controls over funding
ineffective, it is likely and quite feasible to actually prove (upon a complete analysis by
duly authorized and competent auditors) that the great majority of some campaign funds
are derived from these unlawful sources. Those illegal sources are now available for
impeachment of the entire election results for the past two cycles. This result would be
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expected to be included when verified in simple but massive numbers of sampling using
by a routine subpoenas5 for all suspicious items. This process includes corporations,
unions, foreign money, and fund contributions far exceeding limitations of state law
applicable to individual contributors.
Exhibit X-1, page 4, is a list of the 30 top contributors in Maryland, by
name, since January 2019, to March 2023, the last two election cycles. Again, these data
are sorted extractions from government public files, accumulating reports for the
number(s) of contributions made by voting person. The numbers are so great, to be
virtually impossible to have been done without the aid of computerized assistance.
For example, the highest donation number in Maryland in the last two
election cycles, is one individual with 21,831 donations with a total dollar amount of
$ 217,324.34, to the lowest contribution frequency of 31,041 with a total dollar
contribution of $ 34,944 93.
Since purported names for contributors are furnished for all contributions,
explanations of the actual fraud (or not) is readily available. Examples of this
information to pin-point use of identity theft in the corruption of these official federal
(FEC) reports, is therefore a demonstrated accomplishable fact, and a matter of routine
audit performance. This same technique for audit is therefore available nationwide. It is
5
By whom, or what responsible federal or state government agency?, is left as a
“hanging” question (no pun intended) in the absence of a functional GAO or FBI?
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merely an exercise involving time and money to stamp out the obviously wide spread
laxity in honesty controls. The only question is the overall magnitude of these
small donations which also are available in the list of 30 top abusers, also appearing on
page 4 of Exhibit X-1. At first glance appears massive, that is in the many,
many millions of dollars of actual money laundered by the millions of individual
mislabeled donations from (as of yet unidentified actual, but camouflaged actual donors
using the harvested name of real voters. All of these factual donations are subject to
simple analysis to obtain the real source of the funds, again using subpoenas and the
discovery process, for identifying the money mules.
Aside from these individual cheaters (or victims, appearing to be mainly the
elderly), the main actors, the managers of the Enterprise are known. They are: Act Blue,
the Attorney’s for and the Democrats National Committee (DNC) and the heads of all of
the collaborating organizations as co-conspirators.
The Number of Individuals and Unlawful Donations:
The reported contributions, when totaled after being sorted by each donors’
multiple name variations, range in dollar amount depicted on the same page: from a high
of $2,318,426.34, made in 12,004 42 separate donations, to a low of $ 21,739.83, made
in 5,047 separate donations. (Report. Exhibit X-1, pg. 4). The top 30 such donors in
Maryland appear on Exhibit X-1, page 4, Table 1.
The opinion of Electrical Engineer, and data expert Smith appears on page
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5 of Exhibit X-1. That opinion also states that the "pattern of donations"are unlikely to be
natural human behavior" Engineers Smith's credentials and summary of experience
appear on page 6 of Exhibit X-1.
A description of the methodology for data collection and analysis is
described on attachment X-1 (page 1 of 6).
Report X-1, (pg. 1) reveals a total of 9,483,733, donations for the State of
Maryland (only) between 2019 and 20236 most in very small separate dollar amounts.
These dollars incoming to the Enterprise, appear to be and therefore are alleged to be
largely machine created7. This conclusion appears virtually certain, simply because the
huge number of donations by a single person, many in Maryland alone total in the thousands
of separate donations. It is expected that “canvassing” (interviews with contributors) or
minimal discovery efforts, will disclose that the norm of these transactions is a form of
identity theft, unwitting elderly persons names being used to launder other persons
unlawfully contributed money, like corporations or foreign funds, (some of which has
already been randomly discovered in diverse jurisdictions (Michigan, several examples
reported by investigators).
Report X-2: Report X-2 is included as an evidentiary Excerpt from Federal
data files showing the data source. Also, this electronic file which is contained in the
6
Evidence extracted from the Federal Elections Commission Website.
7
“Machine created” means, although the exact metrology remains unknown pending the
expected testimony on the subject by the exact creators, plaintiffs look forward to the
methodology which, if done by hand would mean the “donators” would be substantially occupied
in making donations using normal credit card payment channels for days each month.
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electronic data file furnishes detailed support of the report figures and charts if anyone
needs to verify any of the reported results of the data analysis depicted by the graphs and
charts. If such a review is needed by any party or the public, here are data summaries and
the entire database of supporting electronic information.
Those six pages also include a detailed explanation of how the expert(s)
summarized the data and the methodology used.
CONCLUSION:
The state of Maryland since at least the election cycle of 2012 has
functioned under an utterly inaccurate and corrupted voter system containing voters
records, addresses and other information purportedly preventing a corruption free and
accurate vote count. Because of errors and objections and obvious intentional unlawful
acts like falsification of the existence of voters and malfunctions of voting machines
contributing to the data inaccuracies, along with failure to perform a mandatory
certification check on each machine, the election process is an utter failure and must be
decertified and scrapped. Once a Court comes to this inevitable truthful conclusion, some
sanity can return to this part of America, but not before.
These inaccuracies reach the point for the election of 2020 that citizen
unrest and anger is cause to be formed various organizations for the purpose of correcting
known and in investigating for unknown causes of the observed inaccuracies.
This group of plaintiffs, assisted by dozens of volunteers and a small group
of about 10 experts have analyzed in a scientific manner, subjected to engineering and
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accounting controls the date of obtained from official government records and determined
the results outlined here in above, and produced virtually incontrovertible data
demonstrating that:
1. Massive money laundering of donations has occurred in the last two election
cycles for which data was analyzed. Given the known results for those two cycles it is
apparent that the patterns of abuse of various types began no later than about 2012.
2. Financed by what appears to be massive money laundering intentional abuses
have occurred including, but not limited to:
a. falsification of records of donations;
b. Likely criminal falsification of donation records and eligible voters;
c corrupted printing contracts with known and caught cheaters, Runbeck;
d. ballots and summary counts obtained from inaccurate and on-line gerrymandered
voting machines unlawfully connected to the Internet,
e. a very large error rate producing "Blank ballots" which are unlikely to occur but for
unlawful interference with the voting process. The blank ballot numbers, standing alone,
are sufficiently large to influence and perhaps determine the outcome of at least some
close local elections;
d, the failure to certify the accuracy of the election machines which is a legal requirement
for each voting cycle has not occurred since (reportedly) 2014.
3. According to the federal guidelines for certification of voting machines all of
the results for Maryland in the last two cycles should be decertified use of uncertified
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machines and in addition for the use of uncertified computer programs by which those
machines can be manipulated as to operations and results of vote counting. B
4. Apparently the management of the Maryland State Board of Elections has no
compunction about misinforming the legislature or the public on matters of management
or integrity of voting systems, if any of these misstatement were sworn, criminal sanctions
would appear to be approprite./
5. Each County although purportedly under independent management is actually
totally controlled in its operations by the state Board of elections. As a management
matter the results speak for themselves, absurd and embarrassing to the State, we can do
much better.
VII, RELIEF REQUESTED
1. At the earliest possible time the court should consider the emergency
relief necessary to prevent continuing unlawful acts as outlined relating to donations and
record keeping necessary to prevent and continuation of the money laundering operation
disclosed by the engineering reports herein.
2. A temporary restraining order should be issued preventing any person or
organization dealing with voters registration and election control records from destruction
of any records or any equipment recording or reflecting in any way election results
beginning at January 1, 2019 to date, under penalties of obstruction of justice of a
criminal and civil complaint in this Honorable Court.
3. At the earliest possible time a hearing on plaintiff's motion for a
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preliminary injunction should be scheduled, however a short period of time estimated at
90 days should be allowed for limited issuance of subpoenas and inspection and analysis
of of election equipment used in every election in the state of Maryland since January 1,
2019.
4. At the earliest possible time a hearing on a preliminary injunctive with
the single subject of money laundering in the collection process shall be held and a
determination made at that hearing as to whether or not a RICO enterprise exists in the
collection process involving the state of Maryland, and all counties and cities therein, and
the alleged multiplicity of collections apparently designed to camouflage disclosure of
unlawful sources of money. Prior to this injunction hearing the state of Maryland shall be
ordered to show cause why all of the costs of discovery on the alleged money laundering
should not be borne by the state of Maryland.
5. In the event the state of Maryland fails to carry its burden of proof as to
the allegation of money laundering, these assessments of cost to date shall follow granting
of partial summary judgment and thereafter all costs shall be borne in discovery by the
state of Maryland jointly with any other alleged RICO entities found to be participating in
the money laundering scheme.
6. At the earliest possible time the court shall issue a scheduling order for
the discovery process both prior to the hearings on a preliminary injunction's and other
matters..
7. At the earliest possible time either before the scheduling order or part of
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it, the Court should authorize the issuance of subpoenas, and depositions pursuant to
Federal Rules of Civil Procedure 30 B6, and the inspection and examination of all voting
machines and electronic equipment utilized in the past two election cycles.
VIII. VERIFICATION
I, Lewis T. Porter, am a named plaintiff in this case, and I am over the age of 18, a
Citizen of the State of Maryland, and otherwise qualified to testify before this Court; I
hereby swear under the penalties of perjury that all of the facts appearing herein, and as
attached to this Complaint and Requests for Injunctive relief are true and correct as stated
and each evidentiary attachment hereto is a genuine document to the best of my current,

Lewis T. Porter, June 28, 2022, as Amended March 17, 2023.
IX. JURY DEMAND
Plaintiffs hereby demand a Jury Trial for all claims, damages and issues, for
which a jury trial is available for any issue of fact or law. Further, Plaintiffs demand a
Grand Jury be convened to investigate and act upon all matters for which the Constitution
of the United States makes such relief available.
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JA429
X. INJUNCTIVE AND REMEDIAL RELIEF
Plaintiffs demand equitable, legal, remedial and injunctive relief designed
to make all plaintiffs whole and legal relief to punish the wrongdoers, should any RICO
Entity, or a group of them be found to exist by the Court or, if allowable under law, the
Jury, whether civil or criminal. Plaintiffs pray, that the Honorable Court consider the
irreparable harm to the perceived integrity of our Great Nation, and its proud citizens, and
their progeny, who will continue to suffer such irreparable harm in the event this Court
fails in its perceived duty by these plaintiffs, and the host of others, born and unborn, who
shall suffer egregious harm if the wrongs merely outlined in this complaint are allowed to
persist and prevail. These facts utterly destroy the rights to freedom and equality of
power flowing from the creator which are the now shaken foundations of our great
Constitution.
Walter T. Charlton, Electronic Signature,
June 28, 2022, as Amended, July18, 2022.

DC Bar # 186940,
-28-
JA430

,,,,,,

And ) Case No. 1:22-CV- 01642 SAG
Who have been Injured in their Business or Property )
et a1 Including all others similarly situated )
Class Representatives who have been injured in their )
Business or Person representing all others Similarly )
Situated, et al; )
)
PLAINTIFFS )
V. )
The State of Maryland, et al )
)
STATEMENT OF POINTS AND AUTHORITIES

FOR PLAINTIFFS’ MOTION FOR INJUNCTIVE RELIEF AS NECESSARY
TO PRESERVE EVIDENCE OF MONEY LAUNDERING AND
OTHER ALLEGED CRIMINAL ACTIVITIES
IN THIS CASE:
A. Statement of Facts in Support of A Temporary Restraining Order and

Preliminary Injunction:
1. All of the facts contained in the preceeding Motion is incorporated by this

reference.
2. See Declaration of Christopher Gleason, data researcher for a listed of sources of
evidence used to demonstrate the facts alleged in this case, the existence of a RICO
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JA431
Enterprise, use of defective voting machines and data manipulation allegedly financed by
foreign money, and overall unworkability as a system of governance and national
security. 3. The evidence sought to be protected by this motion is alleged to have been
used to subvert election departments and related institutions of our state, Maryland, and
both local and national governments. A summary of that evidence is presented following,
and in more detail in an accompanying Motion for leave to file a Second Amended
Complaint herein, and attachments.
4. There is no doubt whatever that an evidentiary hearing before a jury, and likely a
grand jury regarding criminal actions of alleged RICO actors, whether acting alone or in
concert with co-conspirators, is in the national interest.
5. An evidentiary hearing at the earliest time possible, with the acceleration of trial
evidence is requested. In the meantime, a protective order for these materials, including
seizures of evidence and equipment is deemed critical.
6. The newly discovered evidence is also to be contained in Evidentiary Attachments X,
Y, and Z to the contemporaneously filed Draft Second Amended Complaint in this case,
and also available for Transfer to the MDL panel. A transfer Motion for Transfer to the
MDL panel has been filed earlier in this case and is still pending.
7. In argument herein, the authors attempt to summarize the findings and implications of
the evidentiary attachments to the voluminous (in excess of 110 pages plus hundreds of
pages of Exhibit Attachments) of the current draft of plaintiffs Second Amended
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Complaint.
8. At the evidentiary hearing requested herein, plaintiffs proffer that these allegations
shall be subjected to whatever verification level of detail is deemed appropriate by the
Court to support a comprehensive, “beyond any reasonable doubt whatever” conclusion
by a jury of these admittedly unusual, and indeed astounding facts of subversion of our
governmental functions, both State and Federal.
9. This is because in this unprecedented situation, the truth and veracity of the evidence
submitted in support of this Motion, including the allegation of compromises and
corruption of election data records of the federal government as well as Maryland and
essentially all of the other states is verified by both the expert witnesses, and fact
witnesses, undersigned counsel, but based almost entirely upon official government cash
transfer records. But these records are not really cash, they are mostly credit care and
electronic transfer records based upon purportedly tight cash controls.
10. It is those controls that have been short-circuited by the RICO Enterprise.
B. SCOPE OF THE INJUNCTIVE RELIEF REQUESTED
11. It is Plaintiffs understanding based upon current information and belief, that a
particular defendant CTCL, a purported tax exempt IRS Code Section 501(c)(3) charity,
functioning out of a home base in Chicago, Illinois, has also operated in many other so-
called "swing states" during the presidential election of 2020, and continues to operate in
various locations across the nation today.
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JA433
12. Based upon evidence of record herein, Exhibit 5 to the original complaint,
incorporated into this filing by this reference, and related contract arrangements known to
exist with each recipient County recipient, that organization, CTCL, has de-facto
participated in the suborning of the election processes in Maryland.
13. Specifically, Exhibit 5, previously of record as an attachment to the original
complaint, and incorporated by this reference, is a list of about 730 alleged “Mules” who
distributed false ballots into drop boxes in Maryland with funds traced to the Grant
furnished by CTCL.
14. CTCL should therefore be named as a RICO conspirator, and held responsible as a
prime member of the RICO Enterprise, unless and until vindicated at a trial on this
subject, among others yet to be discovered.
15. Further, it is recognized that similarly situated persons, even other charities but in
reality, RICO entities who are a part and parcel of this RICO Entity are also in fact,
subversive organizations may be performing identical or very similar unlawful acts.
16. In that event, as found by this Court, or other constitutional entity, those components
of the RICO Enterprise alleged herein, are likely to exist elsewhere. The result is the
same, regardless of subsidiary camouflage and classification as a RICO Enterprise with
intent to destroy our way of government. This Motion and case seek to halt that demise.
C. DECLARATORY JUDGMENT(S) OF THE EXISTENCE OF A RICO

ENTERPRISE, AND ANY PERSONS HELD TO BE MEMBERS WHEN
IDENTIFIED AS SUCH FOR UNLAWFULLY INFLUENCING ELECTIONS:
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The RICO Enterprise definition fits and should be liberally applied to
render such operations wheresoever found, unlawful and prohibited. The scope of this
complaint therefore, is suggested and requested to the Honorable Court as requiring a
flexibility of jurisdiction and venue across the country due to the fact that the transfers of
funds go both directions. This case is proceeding in accordance with the existence of
these evil elements of our society, destructive of our nation as a whole as a matter of
planned policy and intent.
D. Subpoenas are requested to be authorized and expected to be served upon
each County or Jurisdiction receiving Grant funds from CTCL, and CTCL itself.
E. Ancillary thereto, subpoenas for the financial information for all persons to
which such “Grants”, or other payments for services purporting to be for vote collection,
distribution or delivery of forms is necessary evidence. Such evidence is obtainable from
any organization or person receiving funds purporting to be for election related services.
And as such, it is a very small, but highly illegal but an effective step to influence a
person short of funds, food or medicine, to vote for the candidate furnishing the benefit.
In consideration of all of these practical difficulties, expedited permission
for a F.R. Civ. P. 30(b)(6) subpoena and depositions of at least each of the three example
Counties are hereby requested as a permissive matter within the limited scope of the
Temporary Restraining Order, with a view toward completion before, and therefore
usable at the projected hearing on the Preliminary Injunction, or even at an accelerated
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JA435
trial on the merits.
17. Additional Argument
Using the Conclusion of Part One, as a starting point, with this viewpoint as
the only known standard, the injunctive relief demanded, or some reasonable compromise
thereto, should be granted. The status quo of the evidence in this case must be preserved
in order that the obvious and egregious errors of the past are not repeated resulting in the
decent into permanent chaos by our great Republic. Indeed we are not and must not
become a banana republic. But we are on our way.
First as a Temporary Restraining Order, and as expanded, corrected, and
modified on a continuing basis, subject to legislative changes to the existing flawed
system if not merely apparent but, respectfully required for surficial of our way of life.
So the modifications to our structure of election mechanics and laws must necessarily be
viewed as not whether a fix is required, but what kind and to what extent.
There can be no reasonable argument that the past events involving
unlawful acts, if indeed they did occur, must cease. Preventing further destruction of
needed probative evidence as is allowed by the existing “destruct” schedule, applicable to
each county or voting jurisdiction in the State of Maryland is a start.
This principle should be extended into the other judicial Districts in the
United States. The existing Federal Law is based upon normal times. These facts are
apparently typical for the entire Nation, and obviously were not meant to operate in the
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JA436
presence of the massive fraud, and massive dishonesty as indicated by these demonstrated
facts. And those facts are expected to be expanded at the Preliminary Injunction hearing,
and later at Trial if such is necessary.
Second, although, the relief requested herein is within the guidelines of
Rule 65, the necessity for a comprehensive review for propriety of the applicable
Constitutional Bounds and Equity of Result, by this Honorable Court for all upcoming
elections obviously necessary.
But without preservation of the evidence, there shall be no decision possible
as based upon destroyed evidence. Accordingly, that evidence needs to be preserved
beyond the normal destruction date of September 3, 2022.
Third, unless exposed for what it is, faulty and lacking in basic control
mechanisms, the failures of our voting system and governance, the evidence of what
occurred in the 2020 election, will occur again, by application of the same faulty or
erroneous counting principles and/or outright dishonest activities.
Indeed, recent actions of the Maryland legislature are to the effect that drop-
box usage is to be greatly expanded. Absent the relief requested here, that portends a
massive increase in the magnitude of use by dishonest elements to unlawfully control the
election, rather than a correction. Unless we all have truly lost our minds this cannot
continue.
A. RULE 65, RESTRAINING ORDER IS REQUESTED:
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JA437
Immediately after the Seconded Amended Complaint is accepted by the
Court, a Temporary Restraining Order should issue forthwith from the Court, for Service
by United States Marshall’s Service, as if the plaintiffs herein are acting either en forma
pauperis, or alternatively as a de-facto attorney general. Immediate and Irreparable Harm
will result if the evidence, in any jurisdiction where the practices outlined herein are even
suspected to have existed. And, as a practical matter;
There will be no possible material harm from this injunction simply because
there will be no major upset in the preservation except a slight delay in scheduling for
destruction in each voting jurisdiction, if indeed, no fraud or violation of federal election
law was later found applicable to that jurisdiction.
But on the other hand, massive harm will result if indeed, the same or
similar violations exist in the evidence to be preserved. If destruction of ballots or
electronic images occurs, it will be lost forever. Therefore, the balancing required by the
Court for injunctive relief is more than satisfied.
Walter T. Charlton, Electronic Signature,
March 17, 2023

DC Bar # 186940,
-7-
JA438

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JA439
DRAFT ORDER FOR EQUITABLE RELIEF
Upon the conclusion of the evidentiary hearing requested in Plaintiffs
Motion for an Emergency Protective Order and Equitable Relief an Order for
Sequestration of election materials and evidence shall issue: The draft suggested Order,
presumed to be modified by the Court, prior to and at the requested hearing on a
Preliminary Injunction. That Order shall contain the following suggested provisions.
1. It is hereby Ordered that Each named defendant in this case shall be notified by first
class mail that in Each Voting Jurisdiction in the State of Maryland that the deadline of 22
months for preservation of all voting related evidence, is hereby reinstated for all
defendants in this case, and shall continue subject to further order of this Court.
2. The donor corporation, Center for Tech and Civic Life (CTCL),233 N Michigan Ave.,
Suite 1800 Chicago, Il. 60601; shall be served with a copy of this Order along with all
complaints filed in this case by U. S. Marshall’s Service, the cost of such service shall be
billed to CTCL by the Marshall’s service.
3. A list of materials of whatever description is relevant to all claims in this case against
that particular defendant shall be filed under seal with the pacer system.
4. When served, that list as it applies to the particular person or entity served shall be
Attached to a subpoena duces tecum to that entity for production of the item forthwith.
5. Seizures, or production, or inspection of election materials:
Ballots and other items pertaining to elections shall be submitted to counsel for the
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JA440
entity
6. The subpoenas duces tecum, with attached lists, shall be served, confidentially and that
counsel shall be personally responsible to arranging with the counsel for the defendants
the identification, marking and production of said items on the list without any prior
notice to defendants of the specifics of said process.
7. Any breach of the confidentiality presumed in this order shall be considered a grave
and intentional matter, and subject to a forthwith show cause order for Sanctions. If
substantiated, sanctions shall be jointly assessable against the defendant and counsel.
8. Plaintiffs may serve notice of a subpoena Duces Tecum, coupled with a sufficient
number of Rule 30 (b)(6) depositions upon, the person(es) designated by the Chief
Executive of each particular voting jurisdiction in Maryland, or nearest equivalent for that
particular jurisdiction most knowledgeable of the subject matter thereof of said noticed
deposition, following the federal standards pertaining to Rule 30 (b)(6) depositions; and
subpoenas accompanied by the necessary documentary information, and shall require:
(a) the highest officer of each particular jurisdiction to identify, under oath, by the
person or persons most likely to possess such knowledge (a sworn response, and lists,
identifying and indexing in easily legible form, in English, or suitable electronic word
processor, each type of record evidence existing as of November 3, 2020 and three
months before and at all times thereafter, and the custodian thereof of, describing without
limitation of any kind, the following or all other information necessary to describe:
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(i) All paper ballots and associated envelopes; or, if such exist, any paper or other
written depictions of any purported individual ballots.
(ii) All electronic or optical or other storage media of voting materials.
(iii) All financial records pertaining to monies or items of value in any way related
to voting records or the voting documents themselves, including, but not limited to Grants
from any Outside of that particular jurisdiction source including federal government
agencies.
(iv) the names, social security numbers, addresses and date of birth of each person
receiving pay, or anything of value, and the amount thereof for performance of any duty
at all pertaining to the presidential election of November 3, 2020, or thereafter, if this
case lasts that long;
9. (b) A certification under the penalties of perjury, by the Officer(es) described in
paragraph (a) above, that the items furnished conform in substantial compliance with the
requirements of full and complete disclosure of the requirements of this Order.
( c) That the materials required shall be delivered to the respective United States
District Court by electronic means, in PDF format within 21 days of service upon each
such person, or an alternate with explanations as to the substitution or failure to be
furnished within 7 days of the due date thereof.
10. Physical Seizure shall occur, of all Voting Machines and all electronic devices,
servers or machines by whatever names utilized which hold, support, furnish power or
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JA442
transmit messages in any form whatever shall be identified wherever said machines exist,
on both the receiver and transmittal end or each communication, in any way contributing
to the vote or address recording process.
11. As an alternative to outright seizure, if agreed by Counsel those items shall be subject
to inspection, cataloging and/or tagging and thereafter examination for the necessary
evidence by qualified experts. Once this identification process is complete, a plan for
verification or seizure, or expert evaluation and inspection of the attributes of each item
of equipment purported to not be on-line equipment shall be made if deemed so
determinable.
12. It is hereby Ordered that a positive finding of the Existence of a RICO Enterprise
with the following known members does in fact exist, and has existed for at least the
dates____ to ____. Members of that enterprise preliminary decided at the evidentiary
hearing and Accelerated trial are found to be :_________________________________
13. A magistrate judge or Master is hereby assigned to serve determine the management
of this case until such time as the MDL panel assumes that responsibility, or thereafter is
subject to a later date.
14. Cost and Attorney’s Fees shall be apportioned based upon the proportion of hours
and other incidental costs billed by plaintiffs and counsel. Each defendant shall pay
within 15 days of the bill rendering and the statutory rate of interest maximum thereafter
upon the unpaid balance compounded daily.
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JA443
15. A criminal referral of all of the names participating in any way in the operation or
planning of the activities of the RICO Enterprise shall occur forthwith. The State of
Maryland shall be billed $________________ for all costs and damages, and penalties to
date, for re-distribution to Counsel for the Plaintiffs with due consideration of applicable
fee standards both contingent, hourly and the Laffey Standards. Assessment against
RICO members shall consider proportionate contributions from each known RICO
member of the Enterprise assessed judgments contributing proportionately with its own
annual budget, which shall include all State Employees who shall be retired, or terminated
for malfeasance also paying their apportioned share of costs and attorneys’ fees.
16. Any requests for modifications of this Order shall first be referred to the appointed
manager of this case for resolution with opposing counsel.
So Ordered,
_________________________
For Applicable Jurisdiction.
(Here), Mary land.
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I hereby certify that I filed that I filed in the Pacer system of the Court, with
the expectation that it would be served upon all Defendants, on this 19th, day of March,
2023 including CTCL, a copy of the Motion an Emergency Preliminary Injunction and
Temporary Restraining Order (TRO) with an Accelerated Presentation of Trial Evidence,
regarding preservation of Evidence and for Seizure of Evidence and Materials relevant to
voting and national security, with Newly discovered evidence of RICO Allegations and
alleged Voting System Money Laundering and Vote System violations of regulations and
unlawful acts.
Walter T. Charlton
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JA445

) Case 1:22-CV- 01642-SAG
)
PLAINTIFFS )
)
V. )
)
The State of Maryland and Several Agencies of the )
State, Including at least the State and County Boards )
of Elections in the Specific Counties Listed herein )
et al )
DEFENDANTS )
)
VERIFIED MOTION IN THE NATURE OF A DEMAND FOR

COURT’S CORRECTIVE ACTION, VERIFIED BY COUNSEL
(FOR THE COURT’S ERROR IN IGNORING THE EFFECT OF THE

RULE 59(e) MOTION IN CLOSING THE CASE RECORD)
VERIFIED MOTION FOR A CORRECTIVE ORDER
I, Walter T. Charlton, A member of the bar of this Court, do hereby declare
under the penalties of perjury that I filed, the foregoing Statement of Facts in support of
an Order demonstrating that the entry by the Assigned Judge of this Court, is clearly in
Error, contrary to the Rule of Law, and the provisions of Federall Rule of Civil Procedure
59(e), and Out of Order as in disregard of the clear facts of Record. The Motion to Alter
and Amend the Judgment Entered on January 13th, 2023 (Docket entry # 74, pg. # 13),
Plaintiff’s Motion to Alter/Amend the Judgment pursuant to Federal Rule
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of Civil Procedure 59(e) was entered on “01/13/2023". The entry of the Motion to
Alter/Amend was on the 28th day after the entry of the Honorable Court’s Order
dismissing this case. The dismissal was by (Docket entries #s 72 and 73) on December
16th 2022.
The entry of the Motion to Alter/Amend was therefor timely and therefore
legally effective to extend both the time for appeal and the effect of dismissal of the case.
And further, there never has been any Order entered upon the Docket of this
case, to this date ruling that the Court denies the Motion to Alter and Amend. Therefore,
as a matter of black letter law, this case is still open as of this time and was never legally
closed, nor should it have been. Therefore, all actions based upon that error are, as a
matter of law, void ab initio.
Therefore, Plaintiffs demand an Order in the nature of a corrective
injunctive or mandamus Order correcting the effects of the Court’s closing the case, and
accepting all matters excluded based upon that error, from the record of this case on the
grounds as stated above, as having been entered without the jurisdiction of the District
Court to declare the case closed and bar entry of materials into the record as was correctly
and timely done by plaintiffs herein.
And further relief should be granted by Ordering the District Court to
remove the block on the link to this case, and Serving All Parties in accordance with the
Normal Procedures for Pacer filing and further to accept all materials filed in the interim
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JA447
in the event any such materials remain blocked from entry into the live pacer docket and
records of filings in this case.
And the further, should any person declare otherwise as to subsequent
entries into the record, the docket entries, immediately following the timely entry of the
Motion to Alter or Amend the Judgment, the set of Motions (Docket Entries #s 75 and 76,
entered on January 16th and 17th respectively, have no bearing on the Motion filed
previously (the Motion to Alter or Amend the Judgment) whatever, nor was any such
intention or connection ever intended, nor any other Motion to excise that Motion to Alter
and Amend ever so intended.
Walter T. Charlton, Electronic Signature, March 21, 2023

DC Bar # 186940,
Member of the Bar of the Supreme Court of the United States of America (Since 1977)
United States District Court Bar, District of Maryland , # 07638
Walter T. Charlton & Associates, CPA/Attorney (District of Columbia and Maryland)
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I hereby certify that I filed, pursuant to instruction of the Court, copies of

this motion requesting an Order in the nature of a corrective Motion to Conform to the
Federal Rule of Civil Procedure 59(e) with the expectation that it would be served on all
parties of record in this case, on the 23rd day of March 2023.
Walter T. Charlton
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JA449

*
*
Plaintiffs, *
v. *
*
et al., *
*
Defendants. *
*
* * * * * * * * * *
MEMORANDUM OPINION
Plaintiffs Lois Ann Gibson, Maryland 20-20 Watch, Charlton Scientific Educational and
Engineering Foundation Inc., and others 1 (collectively “Plaintiffs”) filed this lawsuit against a
variety of defendants, primarily the Maryland Board of Elections, various Maryland counties
(collectively, “Maryland Counties”), and the Center for Tech and Civic Life (“CTCL”), a Chicago-
based non-partisan non-profit that provided grants to local governments in the 2020 election for
the purpose of operationalizing safe and secure election administration. ECF 1 at 1–3; ECF 1-4 at
1. In their Amended Complaint, Plaintiffs principally alleged that the Maryland Counties accepted
the CTCL funding with the agreement that they would use the funding to pay individuals to
fraudulently place ballots in ballot boxes for the purpose of influencing the 2020 general election
in favor of Democratic candidates. ECF 9 at 5.
1
Other named plaintiffs include “A Committee of Injured Citizens/Voters for Themselves and All
Others Similarly Situated,” “Any, Presently Unknown State Agency which was Duped by the
Multiple Frauds Alleged Herein,” and “All Others Similarly Situated Injured Persons.” ECF 1.
JA450
On December 16, 2022, this Court granted Defendants’ motions to dismiss on the basis
that Plaintiffs lacked standing. See ECF 72, 73. On January 13, 2023, Plaintiffs filed a motion to
alter or amend judgment under Rule 59(e) of the Federal Rules of Civil Procedure. ECF 74.
Multiple Defendants have filed responses in opposition to Plaintiffs’ motion. 2 Plaintiffs replied.
ECF 93. For the reasons explained below, Plaintiffs’ motion to amend judgment will be DENIED. 3
I. LEGAL STANDARD
Federal Rule of Civil Procedure 59(e) authorizes a district court to alter, amend, or vacate
a prior judgment. See FED. R. CIV. P. 59(e). There are three limited grounds for granting a motion
for reconsideration pursuant to Rule 59(e): (1) to accommodate an intervening change in
controlling law; (2) to account for new evidence; or (3) to correct a clear error of law or prevent a
manifest injustice. See U.S. ex rel. Becker v. Westinghouse Savannah River Co., 305 F.3d 284, 290
(4th Cir. 2002). However, a Rule 59(e) motion “may not be used to relitigate old matters, or to
raise arguments or present evidence that could have been raised prior to the entry of judgment.”
Pac. Ins. Co. v. Am. Nat’l Fire Ins. Co., 148 F.3d 396, 403 (4th Cir. 1998) (citation omitted).
“[M]ere disagreement does not support a Rule 59(e) motion.” Hutchinson v. Staton, 994 F.2d 1076,
1082 (4th Cir. 1993). “[G]ranting a motion for reconsideration is an extraordinary remedy, which
2
See ECF 77 (Maryland Board of Elections); ECF 79 (Anne Arundel County); ECF 81 (Maryland
State Prosecutor); ECF 82 (Calvert, Washington, Carroll & Kent Counties); ECF 83 (Harford
County); ECF 84 (Baltimore County); ECF 85 (Caroline, Dorchester & Talbot Counties); ECF 86
(Wicomico County); ECF 87 (Montgomery County); ECF 88 (Garrett County); ECF 89 (Howard
County); ECF 92 (Prince George’s County).
3
While Plaintiffs’ motion to amend judgment was pending, Plaintiffs filed three motions, ECF 94,
96, 98, and one letter to the Court, ECF 100. As explained by this Court in an Error Order, ECF
99, Plaintiffs could not file motions while the case remained administratively closed. Even if
Plaintiffs could file these motions in a closed case, this Court would not have had jurisdiction to
rule on the motions given that Plaintiffs lack standing for the reasons explained below.
2
JA451
should be used sparingly.” Sullivan v. Washington Metro. Area Transit Auth., No. 19-00300, 2020
WL 5500185, at *2 (D. Md. Sept. 11, 2020); see also Pacific Ins. Co., 148 F.3d at 403. “Clear
error or manifest injustice occurs where a court ‘has patently misunderstood a party, or has made
a decision outside the adversarial issues presented to the Court by the parties, or has made an error
not of reasoning but of apprehension[.]’” Wagner v. Warden, No. 14-791, 2016 WL 1169937, at
*3 (D. Md. Mar. 24, 2016) (quoting King v. McFadden, No. 14-91, 2015 WL 4937292, at *2
(D.S.C. Aug. 18, 2015)).
II. DISCUSSION
This Court previously dismissed Plaintiffs’ claims because they failed to allege any
concrete, particularized harm from the alleged RICO election conspiracy and therefore lacked
standing to sue. ECF 72 at 10. Plaintiffs asserted the CTCL grants harmed them because they
helped to elect political candidates that Plaintiffs opposed, however, Plaintiffs did not allege that
they supported a particular candidate or even that they voted in any past election. Id. This Court
explained that “[m]erely alleging that the grants may influence the election result and lead to
possible disenfranchisement is not an injury-in-fact.” Texas Voters All. v. Dallas Cnty., 495 F.
Supp. 3d 441, 452 (E.D. Tex. 2020); see also Minnesota Voters All. v. City of Minneapolis, No.
CV 20-2049, 2020 WL 6119937, at *7 (D. Minn. Oct. 16, 2020) (concluding plaintiffs lack
standing when they merely assert that the urban-biased distribution of the CTCL grants favored a
particular demographic group); Pennsylvania Voters All. v. Ctr. Cnty., 496 F. Supp. 3d 861, 869
(M.D. Pa. 2020), appeal dismissed sub nom. Pennsylvania Voters All. v. Cnty. of Ctr., No. CV 20-
3175, 2020 WL 9260183 (3d Cir. Nov. 23, 2020), and cert. denied sub nom. Pennsylvania Voters
All. v. Ctr. Cnty., Pennsylvania, 141 S. Ct. 1126 (2021) (same); Election Integrity Fund v. City of
Lansing, No. 1:20-CV-950, 2020 WL 6605987, at *2 (W.D. Mich. Oct. 19, 2020) (same).
3
JA452
Plaintiffs devote nearly the entirety of their present motion to explaining the “new material
and relevant evidence” they assert was not previously available. ECF 74 at 2. However, this new
evidence does not remedy their jurisdictional defect. Even assuming without deciding that this
evidence was not previously available, Plaintiffs again fail to allege a particularized harm
sufficient to confer Article III standing. Plaintiffs assert that “all Americans as victims of . . . the
unlawful conspiracy resulting in a RICO Enterprise” have standing to sue. ECF 74 at 2. They argue
that Plaintiffs’ “voting rights were falsely ripped from them, altered by machines controlled by
dark money, laundered by intentional false statements and thousands of transactions of cheating
recorded and falsely tabulated in on-line machines.” Id. at 3. However, as this Court previously
explained, there must be a particularized harm suffered by Plaintiffs, specific and individualized
to them and not “all Americans.” 4 See ECF 72 at 9. “[A]n asserted right to have the Government
act in accordance with law is not sufficient, standing alone, to confer jurisdiction on a federal
court.” Whitmore v. Arkansas, 495 U.S. 149, 160 (1990) (quoting Allen v. Wright, 468 U.S. 737,
754 (1984)); see also United States v. Hays, 515 U.S. 737, 743 (1995) (“[W]e have repeatedly
refused to recognize a generalized grievance against allegedly illegal governmental conduct as
sufficient for standing to invoke the federal judicial power.”). Plaintiffs do not assert that this
4
In their Reply, Plaintiffs point to 18 U.S.C. § 1984, which provides a cause of action for “[a]ny
person injured . . . by reason of a violation of section 1962.” ECF 93 at 3. This statutory provision,
however, does not (and cannot) subvert the Article III standing injury-in-fact requirement. See
Lujan v. Defs. of Wildlife, 504 U.S. 555, 577 (1992) (noting that Congress cannot “convert the
undifferentiated public interest in executive officers’ compliance with the law into an ‘individual
right’ vindicable in the courts”); see also Spokeo, Inc. v. Robins, 578 U.S. 330, 341 (2016), as
revised (May 24, 2016) (“Congress’ role in identifying and elevating intangible harms does not
mean that a plaintiff automatically satisfies the injury-in-fact requirement whenever a statute
grants a person a statutory right and purports to authorize that person to sue to vindicate that
right.”).
4
JA453
alleged RICO conspiracy affects them more than any other American, thus, they have no concrete
injury-in-fact and lack standing to sue.
III. CONCLUSION
For the reasons stated above, Plaintiffs’ motion to amend judgment, ECF 74, is DENIED.
A separate Order follows.
Dated: March 29, 2023 /s/

5
JA454

*
*
Plaintiffs, *
v. *
*
et al., *
*
Defendants. *
*
* * * * * * * * * *
ORDER
For the reasons stated in the accompanying memorandum opinion, it is this 29th day of
March, 2023, ORDERED that Plaintiffs’ motion to amend judgment, ECF 74, is DENIED. The
case remains CLOSED.
/s/
JA455

NOTICE OF APPEAL
to the
UNITED STATES COURT OF APPEALS

FOR THE FOURTH CIRCUIT
JA456

Lois Ann Gibson, a Private Citizen/Voter Frederick,
Maryland; )
And )
) Case No. 1:22-cv-01642-SAG
Who have been Injured in their Business or Property )
And )
A Maryland Citizen/voters, and the Citizen Voters in )
All States Who have Been Injured by Actions of the )
been Injured in Their Business or Property by actions )
of the RICO Enterprise for themselves and all others )
similarly situated in any State of Federal Election, )
Acting Under their Standing to Sue, and Pursuant to )
Federal Rule of Civil Procedure Rule 23, )
and the Federal Rules of Civil Procedure Part V )
Multi-District Litigation Sections, Consisting of a )
Putative Class of similarly situated Voters in )
Maryland and Elsewhere in Past Elections in )
Maryland and Elsewhere in the United States of )
America, who are Similarly Situated, as defined by )
Federal Rule of Civil Procedure 23, and denied )
or reduced or, entirely superseded in their vote, )
and/or Right to Vote, and/or Injured by Abrogation of)
His/Her Voting Power and/or Constitutional Right to a )
Fair and Honest Vote, and/or Shall be and/or are now )
being Immediately and Irreparably Harmed and/or )
Likely to be further Injured by the Continuing Ongoing)
Frauds described herein specified and/or specifically )
detailed herein, forming one or more Rule 23 Classes )
of persons; And/or )
Any, presently unknown State Agency which was )
Duped by the Multiple Frauds Alleged herein )
-i-
JA457
And )
whatever State or County they reside, with Money )
Laundering and hereby bribery and vote influencing )
crossing state lines and therefore creating inter-state )
Inter-State and Multi-District Litigation for False Vote )
Tabulation; Deceased Voter and Voters Address Roll )
harvesting, )
Conspiracy; for Money Laundering and for False Vote )
Bribery; Totaling or Tabulation Manipulation with )
Causing Immediate and Irreparable harm to )
Government Credibility, Confidence in Present )
and Future Elections by Placing False Financial )
Information into State or Federal Financial Records )
and/or Voting Rolls, as Attested to by )
Several Unnamed Whistle Blowers, also injured in )
their Business or Property and/or Who Wish to )
Remain Anonymous for Reasons of Security )
And )
Amicus Curiae, Charlton Scientific Educational and )
Engineering Foundation, Inc; )
)
PLAINTIFFS )
)
V. )
)
Frederick County Maryland, )
And )
Howard County, Maryland, )
And )
Carroll County, Maryland )
)
Additional Defendants: )
The Other 18 additional Counties alleged to participate )
in the fraudulent procedures, receiving bribery )
and unlawful influencing by compromised “Grants” )
to Maryland Vote Workers of Unlawfully Declared )
To Be tax free funds, by Reason of Internal Revenue )
Law Violated by Both Federal Workers and The )
RICO Enterprise of Which they are Alleged to be )
Either a Part of the Actions or Complicit by )
-ii-
JA458
Conspiracy to Aid and Abet Violations of Federal )

Tax Law and/or to Unlawfully Influence Tainted )
Elections and Election Processes and Deliveries )
Crossing State Lines of False Ballots these are: )
Allegheny, Anne Arundel, Baltimore City, )
Baltimore County, Calvert, Caroline, Cecil, Charles, )
Dorchester, Garret, Harford, Howard, Kent County )
Board of Elections, Montgomery, Prince Georges, )
Queen Anne’s, Talbot, Washington, Wicomico; )
And; )
A RICO Enterprise, Containing the State of Maryland, )
and/or Methodology to Rig Votes, et al: )
And/or )
Federal or State Government Employee, with the sole )
Acting without guilty knowledge of the fraudulent facts;)
or, nevertheless, intentionally, and/or with scienter )
or/and participation in any conspiracy to alter, )
individually, or to place false or knowingly, incorrect, )
evidence or materials from the voting process or )
accountability records, or to falsely pay others to )
falsify or do so alone, or in conspiracy with others, )
thereby aiding and abetting the unlawful violations of )
any citizen’s voting rights in any state or jurisdiction, )
by aiding and knowingly or negligently, thereby )
abetting, paying for or creating fraudulent schemes )
And; )
-iii-
JA459

And )
those classes or Classes of Defendants )
of their Own Acts have aided and abetted the creation or)
)
Defendants. )
And )
And; )
identified as both government employees, or private )
in Fact RICO Enterprises, numbering in the many )
dozens, Foreign and Domestic, who, by good and )
verified admissions and verified evidence, or at trial )
shall be demonstrated to have conspired and/or be )
found to have or currently are conducting Civil or )
Criminal Process of Law, to have participated and/or )
knowingly Aided and Abetted the Activities )
Complained of herein; have thereby violated the civil )
and Criminal Laws of the Constitution of the State of )
applicable, forming a de-facto oligarchy by incestuous )
Bribery of Courts, State and Local Governments, )
and gangs and subservient RICO Enterprises with one )
-iv-
JA460
Purpose, Unlawfully buy the Elections to Obtain )

Unlawful Control of Our society for use to benefit )
THEM, not the citizens, all in contradiction to our )
constitution and Due Process of Law in Accordance )
With Our Sacred Constitution and THEIR OWN )
SACRED TRUST )
And; )
And: )
The Office of the State Prosecutor, that has )
Enterprises in its Jurisdiction, for Whatever Reason; )
And )
Linda Lamone, FORMER, Administrator and Director )
of The Maryland State Board of Elections in her )
personal Capacity and as a State Official Alleged to be )
Directly Responsible for both In-State and Multi-State )
Management of Multiple RICO Enterprise activities. )
Which have Subverted Our Nation to the Forces of )
Oligarchy, Evil, Foreign Interests and to a Material )
Extent Control of Our Lives and Subversion of Our )
Rights in this Case as violations of Due Process of Law )
Both State, Local and Constructional Military and )
Chemical Control of Our lives; and all others who have )
knowingly and willingly aided and abetted these )
criminal or treasonous acts; known and unknown. )
)
DEFENDANTS )
)
NOTICE OF APPEAL
Each named Citizen/Plaintiff in Maryland and Elsewhere, hereby Appeal to
the Fourth Circuit Court of Appeals, each and every denial of Injunctive Relief, and each
Substantive Decision made by the Court in this case as based upon incorrect and
essentially False information placed before the District Court by a subverted Election
System in Maryland. The number of plaintiffs represented by named Plaintiffs even if
-1-
JA461
confined to Maryland is, at least in the hundreds of thousands voters. These appellants
seek to acts as, both individuals and Class Representatives of a putative Class or classes
of Injured Citizen voters, hereby Appellants, through their Class Representatives and
Attorneys. The identity of the Plaintiffs is further described with specificity in the
Caption of This Case as Plaintiffs as described above. Those names are hereby adopted
by this reference in both capacities. Further specificity as to names and descriptions of
the class or classes they seek to represent, are yet to be determined by the District Court
as a procedural matter.
Similarly, defendants are members of a RICO Enterprise now known to be
functional in all 50 States, with only those locally identified listed in the caption of this
case. To the extent specificity is required by this Appeal Notice, again, Plaintiffs adopt
by this statement the identifies named in the Caption, however, the functional members of
the class of defendants, for commission of unlawful acts is very numerous with dozens of
additional defendants being located each passing day from existing accurate records,
Accordingly, the RICO and Class Action nature of the parties cries out for
MDL Treatment, which was erroneously labeled by the District Court as “Erroneously
Filed” because the “case was closed”. These procedural and substantive rulings are also
being appealed as a matter of inter-alia, violation of Constitutional and procedural Due
Process of law.
Plaintiffs also hereby appeal the interlocutory rulings against each principal
-2-
JA462
participant in the alleged RICO Criminal and Civil Enterprise event this Case. And
further as a principal and participant in any Multi-District Litigation (MDL) Appellants in
this Appeal, and each individual appellant and each committee group, through counsel,
thereby Appeal every Interlocutory denial and Order issued in this case, and further allege
that the Judge in this Case was biased and or misinformed by falsies constituting a fraud
upon this United States District Court, and all of the Judges therein. Therefore, in
summary all of the actions taken, both substantive and procedural, interlocutory or final,
must be considered void as a matter of Law, as are the Original dismissal of all claims for
lack of standing, on December 16th, 2022, Docket Numbers 72 and 73.
And that further, the F.R. Civ. P Rule59(e) Motion filed on January 13,
2023 was timely filed and, as a matter of law prevented the Court from lawfully closing
this case, as jurisdictionally ultra-vires. And that, given that as an admitted fact,
consequently all intervening Motions, effectively hiding the new evidence of Treason and
Corruption is a matter of established legal fact. Accordingly, those normally routine
housekeeping matters become matters of extreme consequence in the context wherein
they exist, these are indeed criminal matters not normally part of a mere “ Notice of
Appeal”. However, this matter implicates exactly what this case is all about in this
appeal. That is the actual record on appeal is right now corrupted by hidden critical data
which must come before this Court before it has before it the facts necessary for its very
first decision.
-3-
JA463
That is just what is the appeal the Court is Docketing? Placing newly that
discovered evidence, which was effectively quashed into the Record of this case is
therefore of the essence of this notice of appeal, and ensuring that the correction of the
evidentiary submissions to date were (now) correctly placed therein.
And also, the motion to transfer this case which was appears to have been
never delivered to the MDL panel and therefore excluded from the public record was also
prevented from that disclosure as a matter of violation of due process of law by the
District Court. The Motion Denying Transfer to MDL or The failure to notify the MDL
of this case or the evidence therein of Treason and/or Subversion of Our Election Systems
by Corrupt Election Officials in Maryland, Notice (Docket # 94, filed 2/23/23 is also
appealed by this notice of appeal as a matter of violation of due process of law along with
all such previously incorrectly (and unconstitutional) denials of publication of the newly
discovered criminal acts by this District Court is hereby Appealed along with the denials
of all Injunctive Relief for Immediate and Irreparable Harm, Including the Certification of
the Elections in the State of Maryland of the Election of November, 2022.
And finally, the Denial of Plaintiffs Motion to Alter/Amend (Docket # 102,
and preceding Memorandum Opinion of like date, docket # 101 Admit as a Matter of
Law, the Existence and Legal Efficacy of all of the true and correct pleadings to date by
Plaintiffs in this case.
-4-
JA464
Respectfully submitted ,
Walter T. Charlton, April 1, 2023
Walter T. Charlton
Post Office box 370
Woodsboro, Maryland 21798
Counsel for Plaintiffs and the Class or
Classes they Seek to Represent
I hereby certify that I filed that I filed in the Pacer system of the Court, with
the expectation that it would be served upon all Defendants, including CTCL, a copy of
the Notice of Appeal, on this first st day of April, 2023.
Natalie Abbas
Natalie Abbas, Paralegal
-5-
JA465
USCA4 Appeal: 23-1369 Doc: 31-1 Filed: 06/15/2023 Pg: 1 of 2 Total Pages:(1 of 8)
FILED: June 15, 2023
UNITED STATES COURT OF APPEALS

FOR THE FOURTH CIRCUIT
___________________
No. 23-1369
(1:22-cv-01642-SAG)
___________________
LOIS ANN GIBSON; MARYLAND 20-20 WATCH, FREDERICK,

MARYLAND; CLASS REPRESENTATIVES PURSUANT TO FEDERAL
RULE OF CIVIL PROCEDURE 23, AND/OR PUTATIVE CLASSES OF
SIMILARLY SITUATED VOTERS OF MARYLAND AND/OR ELSEWHERE
IN THE UNITED STATES OF AMERICA; ALL OTHERS SIMILARLY
SITUATED INJURED PERSONS, IN WHATEVER STATE OR COUNTY
THEY RESIDE, DEPRIVED OF THEIR CONSTITUTIONALLY
GUARANTEED, FREEDOM, LIBERTY, EXPRESSION AND RIGHT TO AN
EFFECTIVE VOTE BY THE ACTS OR ACTIONS OF THE DEFENDANTS
HEREIN
Plaintiffs - Appellants
v.
THE STATE OF MARYLAND and Several Agencies of the State, Including at

least the State and County Boards of Elections in the Specific Counties Listed
herein; A STATE AND NATIONAL RICO ENTERPRISE, IN PART LOCATED
IN MARYLAND, AND/OR DOING BUSINESS AS PART OF THE
COMMERCE IN MARYLAND WITH COUNTIES, I.E., FREDERICK,
HOWARD COUNTY, CARROLL COUNTIES, MARYLAND AND 18
ADDITIONAL COUNTIES OR VOTING JURISDICTIONS; CENTER FOR
TECH AND CIVIC LIFE (CTCL), A Chicago IRS Code 501 (c) (3) Corporation;
PRESENTLY UNKNOWN DEFENDANTS; THE STATE OF MARYLAND
OFFICE OF THE STATE PROSECUTOR;KENT COUNTY BOARD OF
ELECTIONS; CALVERT COUNTY; WASHINGTON COUNTY; CARROLL
COUNTY, MARYLAND; HARFORD COUNTY; MONTGOMERY COUNTY
Defendants - Appellees
JA466
USCA4 Appeal: 23-1369 Doc: 31-1 Filed: 06/15/2023 Pg: 2 of 2 Total Pages:(2 of 8)
___________________
ORDER
___________________
Upon consideration of the consent motion to supplement the record, the
court grants the motion and supplements the record on appeal pursuant to Federal
Rules of Appellate Procedure 10(e) and Local Rule 10(d) with the documents filed
at ECF 94, 95, 96, 97, 98, and 99 in the U.S. District Court for the District of
Maryland case number 1:22-cv-01642-SAG. The clerk is directed to transmit a
copy of this order, together with a copy of the motion to supplement, to the district
court in order that it may supplement the record.
For the Court--By Direction
/s/ Patricia S. Connor, Clerk
JA467
USCA4 Appeal: 23-1369 Doc: 31-2 Filed: 06/15/2023 Pg: 1 of 6 Total Pages:(3
Pages:(1 of 8)
6)
IN THE UNITED STATES COURT OF APPEALS FOR THE

FOURTH CIRCUIT
_____________________________________
)
Appallants ) Case # 23-1369
)
The State of Maryland and Several Agencies of )
the State, Including at least the State and County ) US DISTRICT COURT FOR
Boards of Elections in the Specific ) DISTRICT OF MARYLAND
Counties Listed herein, et al; ) Case 1:22-CV- 01642-SAG
)
Appellees )
________________________________________)
CONSENT MOTION
-------------------
MOTION TO SUPPLEMENT THE RECORD
BY SIX NECESSARY MOTIONS, (WITH VOLUMINOUS ATTACHMENTS)
FILED IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF
MARYLAND
I. Summary of Situation In this Case:

This Honorable Court has granted Appellants an extension of time
for the filing of briefs and Appendix in this case, until July 12, 2023.
Among the issues on appeal are substantial evidentiary matters
involving, as the essence of this appeal, of allegations contained in newly
discovered evidence. A substantial amount of such evidence and related issues
was omitted from the record of this case as transmitted to the Fourth Circuit Clerk
by the United States District Court via the Pacer system. This evidence and
arguments contained in issues to be brought is considered important, even vital,
to Appellants allegations and the relevant issues of this case. Some of that new
-1-
JA468
Pages:(2 of 8)
6)
evidence is contained in six motions filed in the pacer system subsequent to

the filing of Plaintiff/Appellants timely filed Federal Rule of Civil Procedure
59(e)
Motion to Alter/Amend the Judgment of dismissal for failure to state a claim.
Counsel for Maryland, Daniel Korbin has consented to this Request to
Supplement the Record for the Six Motions and Attachments thereto, which are
voluminous in nature, all likewise filed in the Pacer system subsequent to the
filing of Plaintiff/Appellants Rule 59(e) Motion.
... six of the Motions to which this Order was applicable

(See Attachment 1 hereto), red-lined and marked circled on the
accompanying Docket Sheets) are, in the judgment of undersigned
lead counsel, necessary for a full disclosure in the appeal of this
case having likely nation-wide ramifications. And must therefore be
included in the Appendix to be filed in this case...
The District Court's actions in this matter also dis-enabled transmittal
of the six motions with all attachments to the record submission to the Fourth
Circuit Court of Appeals in this case. For this reason, the District Courts’
assistance in transmitting the subject materials to the Fourth Circuit has been
requested in a Letter Communication to the Court as filed in the District Court
record, today also.
Opposing counsel in this case, Daniel Korbin, Esq., for the Maryland
defendants/appellees a supplementing of the record to include the six motions
plus all attachments there to. These attachments are voluminous and for that
-2-
JA469
Pages:(3 of 8)
6)
reason it is considered prudent to request the copies of the precise filings with the
pacer system, re-enabled for reproduction and filed by pacer itself to the Fourth
Circuit for inclusion in the appendix as plaintiffs this supplement of the record of
this appeal.
A description of this material to be supplemented is identified with
specificity in the Docket Sheets, circled in red is attached to enable a precise
identification of the omitted materials as attachments and arguments filed in
Pacer, See Attachment # 1 hereto.
Walter T. Charlton,
Walter T. Charlton, Esq., DC Bar # 186940,
United States District Court Bar, District of Maryland , # 07638 Walter T. Charlton &
Associates, CPA/Attorney (District of Columbia and Maryland) 11213 Angus Way,
Woodsboro, Maryland 21798 Telephone, 410 571 8764, email, charltonwt @
comcast.net Post Office Box # 370, Woodsboro, Maryland 21798.
Telephone # 410 571 8764
email, charltonwt@comcast.net
-3-
JA470
Pages:(4 of 8)
6)
I hereby certify that I filed, pursuant to instruction of the Court, copies

of this letter in the Pacer system, to the Clerk of the Court, United States Court of
Appeals for the Fourth Circuit,
And that further, I served a copy of this Consent Motion to the Clerk,
United States District Court for the District of Maryland in Case Number, Case 1:22-
CV- 01642-SAG, as an attachment# 1, to a Letter Communication on or about the
14th day of June, 2023.
Walter T. Charlton
-4-
JA471
Pages:(5 of 8) 6)
of Maryland (C l\ ! f..C f Liw· :<cx1G en 1.6) https :/iecf.m dd. uscourts.gov /cgi-bin/DktRpt. pl? 1545 883 92563 876- ...
Case 1:22-cv-01642-SAG Document 109 Filed 06/15/23 Page 7 of 8 '
Pro ~d O,d~L. .2.:_d<=r Granting Consent Motion)(Charlton, Walter) (Entered: 02/08/2023)
02/09/2023 91 ?.~('">ERLE_.:
ORDER ranting 90 Mot ion for Ext ns ion of Time to File Response/Reply 74
~ fer/A mend Jud gment. Signed by .rcl8ge Stephanie A. Gallagher on 2/9/2023 .
,.,:,,.eJ.,:tE,. ",h "C
(rnls, Chambers) (Entered: 02/09/2023)
02109 : . o::. ~., .. RES PO"\ iSE re 74 MOTION to Alter/Amend Judgment with points and authorities, evidence,
aml pruposed Order reinstating case filed by Prince George's Count);'.: (Attachments: # J_ Text
of Proposed Order Proposed Order)(Saint PoJ~fy-aieu, GuyJ( ~ d: 02/09/2023)
~ REPLY to Response to Motion re 74 MOTION to Alter/Amend Judgment with points and
authorities, evidence, anc'J5geo,red Order reinstati~ ase Re ply with attachments of Evidence
relevant to standing and response to defendants oppositions to Alter and Amend Judgement
with Draft Order. filed by A Committee ofl n·u ed Ciitzens/Voters for Themselves and All
Others Similarly Situate . ttac unents: l Exhibit List of the- leged Mules with Payments,
# 2 Exhibit Working Document from Expert, # J Exhibit Information Data X, # 1 Exhibit
Information Data Xl)(Charlton, Walter) Modified on 2/22/2023 (ols, Deputy Clerk). (Entered:
/'"\ . 02/21/2023)
-an =.:a;:.....~~~~~~=~c
- Corr
. ' correcte Mai ocumen,,:.t~'PJ'M
Unedited Versiion of This Document Was Uploaded in Error, This Document Corrects and
Replaces the Main Document# 95 That Was filed in Error by me on 3/17/2023, Appologies
f'J
Walter T Charlton by A Committee of Injured Ciitzens/Voters for Themselves and All Others
Similarly Situated(Charlton, Walter) Modified on 3/21/2023 (ols, Deputy Clerk). (Entered: ~
03/19/2023)
QC NOTICE: 95 M_otion for Prelimif.larx Injunction filed by A Committee of Injured
Ciitzens/Voters for Tnemselves and All Others Similarly Situated, 96 Motion for Leave to File,
filed by A Committee of Injured Ciitzens/Voters for Themselves and All Others Similarly
Situated, 2A Motion to Transfer Case, filed by A Committee of Injured Ciitzens/Voters for
Themselves and All Others Similarly Situated was filed incorrectly.
* *This case was closed on 12/16/2022 and parties cannot seek an inj11nctio11 in a closed case.
It has been noted as FILED IN ERROR, and the document link has been disabled. (ols, Deputy
Clerk) (Entered : 011Zl72ubf
en ,e 6y Co unse y A Committee ofl njured Ci ,tzens oters for hemsel ves aDd A ll Others
Similarly Situated, All Others Similarly Situated Injured Persons, Any, Presently Unknown
State Agency which was Duped by the Multiple Frauds Alleged herin, Charlton Scientific
Educational and Engineering Foundation Inc., Amicus Curia, Lois Ann Gibson, Maryland
20-20 Watch (Attachments: # l Text of Proposed Order) (ols, Deputy Clerk) Modified on
15 of 16 3/31/2023, 1:3:Z AM
JA472
Pages:(6 of 8) 6)
Case
of Maryland (CM 1:22-cv-01642-SAG
'ECF Live Ne,.,Gen 1.6) Document 109 http s:Filed
//ecf.m 06/15/23 Page 8 of 8
dd. usc owts .gov/cgi-bin/DktRpt.pl? 1545883 92 5638 76-_.
R. Signed by Judge Stephanie A. Gallaoher on 3/24/2023.

Filed in Error Document) (ols, Deput/C lerk) (Enter :
I)" _9 _023
I PACER Service Center

I Transaction Receipt
I 0313 1120230 1:31:ss _
jPACER Login: jcharl tonwt [Client Code: __ ___ 'J_ _ _ _ _ _ ,
jDescription: !Docket Report !Sea rch Criteria: j 1:22-cv-O 1642 -SAG

[Billable Pages: !14 jcost: j J.40
16 of 16 3/31/2023 . 1:32 AM
JA473

Gibson Vs Maryland Joint Appendix

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Gibson Vs Maryland Joint Appendix

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USCA4 Appeal: 23-1369 Doc: 44 Filed: 07/31/2023 Pg: 1 of 482

United States Court Of Appeals

ON APPEAL FROM THE UNITED STATES DISTRICT COURT

Walter T. Charlton, I Daniel M. Kobrin Wendy L. Shiff

GibsonMoore Appellate Services, LLC

Philip E. Culpepper Edward B. Lattner

Guy S. P. Maydieu David M. Wyand

Kevin B. Karpinski Elizabeth L. Adams

District Court Docket Sheet [1:22-cv-01642-SAG] ...................................... JA1

Plaintiffs’ Emergency Motion for a

1. Proposed Order [DE2-1] ............................................................ JA87

2. Memorandum of Points and Authorities in Support of

Plaintiffs’ Motion to Alter and Amend the Denial of a TRO

1. Grants to 21 Maryland Counties and

2.1 Declaration of Lois Ann Gibson

2.2 Redacted Declaration,

2.3 Declaration of Jean-Elizabeth Ellis [DE9-4] ........................ JA185

3. Declaration of Newly Non-Resident, Kurt Kolb,

4. Frederick and Carroll County

5. Howard County, List of Payments [DE9-7] ......................... JA195

6. Mail-In Ballot Requests by County

7. Mail-in Ballot Requests by County

8. Verification of Harford County Canvas of 2020

9. Verification Report, Ballot Images and

10. Curriculum Vitae, Dr. Douglas G. Frank

10A. Description of the Specificity Requirements of

10B. Supreme Court Rule

Third Motion for a Temporary

A. Letter from Linda Lamone

Defendant State of Maryland’s Response in Opposition to

Plaintiffs’ Reply Memorandum to Defendants’ State of

Plaintiff’s Memorandum in Opposition to Defendants State of

Defendants’ Reply to Plaintiffs’ Opposition to

Motion to Alter and Amend the Order Dismissing this Case;

C. Affidavit of Lisa Batsch Smith

Defendant Maryland State Board of Elections

Reply to Defendants’ Oppositions to Rule 59(e) Motion to

Plaintiffs’ Motion to Transfer this Case to the

X-1. Lisa Batsh-Smith CV

X-2. Excerpts of Maryland Campaign Finance

X-3. Excerpts of The Big Cheat RICO Enterprise Data

Y-1. Excerpts of MD CTCL Grant Amounts &

Plaintiffs’ Motion for a Preliminary Injunction

Plaintiff’s Motion for Emergency Relief and for

6/29/23, 11:02 AM District of Maryland (CM/ECF Live NextGen 1.6)

Query Reports Utilities Help Log Out

U.S. District Court

Gibson et al v. Frederick County Maryland et al Date Filed: 07/05/2022

6/29/23, 11:02 AM District of Maryland (CM/ECF Live NextGen 1.6)

6/29/23, 11:02 AM District of Maryland (CM/ECF Live NextGen 1.6)

Anne Arundel County represented by Philip E Culpepper

6/29/23, 11:02 AM District of Maryland (CM/ECF Live NextGen 1.6)

6/29/23, 11:02 AM District of Maryland (CM/ECF Live NextGen 1.6)

Patricia Lisehora Kane

6/29/23, 11:02 AM District of Maryland (CM/ECF Live NextGen 1.6)

6/29/23, 11:02 AM District of Maryland (CM/ECF Live NextGen 1.6)

The State of Maryland represented by Daniel Michael Kobrin

Date Filed # Docket Text

6/29/23, 11:02 AM District of Maryland (CM/ECF Live NextGen 1.6)

6/29/23, 11:02 AM District of Maryland (CM/ECF Live NextGen 1.6)

6/29/23, 11:02 AM District of Maryland (CM/ECF Live NextGen 1.6)

6/29/23, 11:02 AM District of Maryland (CM/ECF Live NextGen 1.6)

6/29/23, 11:02 AM District of Maryland (CM/ECF Live NextGen 1.6)