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Keep Focused on the Truth
November 9th, 2020, Promulgated by Diane Harris
No evidence? Now we have kickoff! Here is opening section of a 23-page filed document #1. Much more to come.
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Great Lakes Justice Center
STATE OF MICHIGAN
IN THE CIRCUIT COURT FOR THE COUNTY OF WAYNE
CHERYL A. COSTANTINO and EDWARD P. COMPLAINT AND
McCALL, Jr., APPLICATION FOR SPECIAL
Plaintiff, LEAVE TO FILE QUO
WARRANTO COMPLAINT
-vs-
EXPEDITED CONSIDERATION
CITY OF DETROIT; DETROIT ELECTION REQUESTED
COMMISSION; JANICE M. WINFREY, in
her official capacity as the CLERK OF THE FILE NO: 20- -AW
CITY OF DETROIT and the Chairperson of
the DETROIT ELECTION COMMISSION; JUDGE
CATHY M. GARRETT, in her official
capacity as the CLERK OF WAYNE
COUNTY; and the WAYNE COUNTY
BOARD OF CANVASSERS,
Defendants.
/
David A. Kallman (P34200)
Erin E. Mersino (P70886)
Jack C. Jordan (P46551)
Stephen P. Kallman (P75622)
GREAT LAKES JUSTICE CENTER
Attorneys for Plaintiff
5600 W. Mount Hope Hwy.
Lansing, MI 48917
(517) 322-3207/Fax: (517) 322-3208
There is no other pending or resolved civil action arising out of the same transaction or
occurrence as alleged in the complaint.
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Great Lakes Justice Center
APPLICATION FOR SPECIAL LEAVE TO FILE
QUO WARRANTO COMPLAINT
NOW COMES the above-named Plaintiffs, CHERYL A. COSTANTINO AND EDWARD P.
MCCALL, JR., by and through their attorneys, GREAT LAKES JUSTICE CENTER, and for their
application for leave to file a complaint for quo warranto relief, and for their complaint, hereby
states as follows:
1. Pursuant to MCL 600.4545(2), Plaintiffs respectfully request that this Honorable
Court grant them special leave to file Counts II and III of this complaint for quo warranto for all
the reasons as stated in their complaint, motion for temporary restraining order, supporting
affidavits, exhibits, and accompanying brief, which are all incorporated herein by reference.
2. Plaintiffs request this relief as recognized in Shoemaker v City of Southgate, 24
Mich App 676, 680 (1970).
WHEREFORE, Plaintiffs request that his application for special leave to file Counts II and
III of this complaint for quo warranto relief be granted and that this Honorable Court grant such
other and further relief as appropriate.
Dated: November 8, 2020. /s/ David A. Kallman
David A. Kallman (P34200)
Attorney for Plaintiffs
COMPLAINT
NOW COMES the above-named Plaintiffs, CHERYL A. COSTANTINO AND EDWARD P.
MCCALL, JR. (hereinafter “Plaintiff”), by and through their attorneys, GREAT LAKES JUSTICE
CENTER, and for their Complaint hereby states as follows:
INTRODUCTION
1. The election was held on November 3, 2020 and approximately 850,000 votes were
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reported as cast in Wayne County, Michigan.
2. Plaintiff brings this action to raise numerous issues of fraud and misconduct that
occurred in order to protect the rights of all voters in Michigan, especially Wayne County.
3. In summary, this Complaint raises numerous instances of fraud, including, but not
limited to:
a. Defendants systematically processed and counted ballots from voters whose name
failed to appear in either the Qualified Voter File (QVF) or in the supplemental
sheets. When a voter’s name could not be found, the election worker assigned the
ballot to a random name already in the QVF to a person who had not voted.
b. Defendants instructed election workers to not verify signatures on absentee ballots,
to backdate absentee ballots, and to process such ballots regardless of their validity.
c. After election officials announced the last absentee ballots had been received,
another batch of unsecured and unsealed ballots, without envelopes, arrived in trays
at the TCF Center. There were tens of thousands of these absentee ballots, and
apparently every ballot was counted and attributed only to Democratic candidates.
d. Defendants instructed election workers to process ballots that appeared after the
election deadline and to falsely report that those ballots had been received prior to
November 3, 2020 deadline.
e. Defendants systematically used false information to process ballots, such as using
incorrect or false birthdays. Many times, the election workers inserted new names
into the QVF after the election and recorded these new voters as having a birthdate
of 1/1/1900.
f. On a daily basis leading up to the election, City of Detroit election workers and
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Great Lakes Justice Center
employees coached voters to vote for Joe Biden and the Democrat party. These
workers and employees encouraged voters to do a straight Democrat ballot. These
election workers and employees went over to the voting booths with voters in order
to watch them vote and coach them for whom to vote.
g. Unsecured ballots arrived at the TCF Center loading garage, not in sealed ballot
boxes, without any chain of custody, and without envelopes.
h. Defendant election officials and workers refused to record challenges to their
processes and removed challengers from the site if they politely voiced a challenge.
i. After poll challengers started discovering the fraud taking place at the TCF Center,
Defendant election officials and workers locked credentialed challengers out of the
counting room so they could not observe the process, during which time tens of
thousands of ballots were processed.
j. Defendant election officials and workers allowed ballots to be duplicated by hand
without allowing poll challengers to check if the duplication was accurate. In fact,
election officials and workers repeatedly obstructed poll challengers from
observing. Defendants permitted thousands of ballots to be filled out by hand and
duplicated on site without oversight from poll challengers.
PARTIES, JURISDICTION, AND VENUE
4. Plaintiff Cheryl A. Costantino is a resident of Wayne County, voted in the
November 3, 2020 election, and was a poll challenger.
5. Plaintiff Edward P. McCall, Jr. is a resident of Wayne County, voted in the
November 3, 2020 election, and was a poll challenger.
6. Defendant City of Detroit is a municipality located in Wayne County tasked with
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the obligation to hold all elections in a fair and legal manner.
7. Defendant Election Commission is a department of the City of Detroit.
8. Janice M. Winfrey, in her official capacity, is Clerk of the Defendant City of Detroit
and the Chairman of the Defendant Detroit City Election Commission and is the city official who
oversees and supervises all elections in the City of Detroit.
9. Cathy M. Garrett, in her official capacity, is the Clerk of Defendant Wayne County,
and is the county official who oversees and supervises all elections in Wayne County.
10. Defendant Wayne County Board of Canvassers is the appointed body that is
responsible for canvassing the votes cast within the county they serve. The Board members certify
elections for all local, countywide and district offices which are contained entirely within the
county they serve.
11. This action is properly filed in Wayne County Circuit Court pursuant to MCR
3.306(A)(2), Mich. Const. art. 2, sec. 4, par. 1(h), MCL 600.4545, and MCL 600.605. Venue is
proper pursuant to MCR 3.306(D).
GENERAL ALLEGATIONS
12. Wayne County used the TCF Center in downtown Detroit to consolidate, collect,
and tabulate all of the ballots for the County.
13. The TCF Center was the only facility within Wayne County authorized to count the
ballots.
Forging Ballots on the Qualified Voter List
14. An attorney and former Michigan Assistant Attorney General was a certified poll
challenger at the TCF Center (Exhibit A – Affidavit of Zachary Larsen).
15. As Mr. Larsen watched the process, he was concerned that ballots were being
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Great Lakes Justice Center
processed without confirmation that the voter was an eligible voter in the poll book because of
information he had received from other poll challengers (Exhibit A).
16. Mr. Larsen reviewed the running list of scanned in ballots in the computer system,
where it appeared that the voter had already been counted as having voted. An official operating
the computer then appeared to assign this ballot to a different voter as he observed a completely
different name that was added to the list of voters at the bottom of a running tab of processed
ballots on the right side of the screen (Exhibit A).
17. Mr. Larsen was concerned that this practice of assigning names and numbers
indicated that a ballot was being counted for a non-eligible voter who was not in either the poll
book or the supplemental poll book. From his observation of the computer screen, the voters were
not in the official poll book. Moreover, this appeared to be the case for the majority of the voters
whose ballots he personally observed being scanned (Exhibit A).
18. Because of Mr. Larsen’s concern, he stepped behind the table and walked over to a
spot behind where the first official was conducting her work. Understanding health concerns due
to COVID-19, he attempted to stand as far away from this official as he reasonably could while
also being able to visually observe the names on the supplemental poll book and on the envelopes
(Exhibit A).
19. As soon as Mr. Larsen moved to a location where he could observe the process by
which the first official at this table was confirming the eligibility of the voters to vote, the first
official immediately stopped working and glared at him. He stood still until she began to loudly
and aggressively tell him that he could not stand where he was standing. She indicated that he
needed to remain in front of the computer screen where he could not see what the worker was
doing (Exhibit A).
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Great Lakes Justice Center
20. Both officials then began to tell Mr. Larsen that because of COVID, he needed to
be six feet away from the table. He responded that he could not see and read the supplemental poll
book from six feet away, and that he was attempting to keep his distance to the extent possible
(Exhibit A).
21. Just minutes before at another table, a supervisor had explained that the rules
allowed Mr. Larsen to visually observe what he needed to see and then step back away. Likewise,
on Election Day, he had been allowed to stand at equivalent distance from poll books in Lansing
and East Lansing precincts without any problem. With this understanding, he remained in a
position to observe the supplemental poll book (Exhibit A).
22. Both officials indicated that Mr. Larsen could not remain in a position that would
allow him to observe their activities; the officials indicated they were going to get their supervisor
(Exhibit A).
23. When the supervisor arrived, she reiterated that Mr. Larsen was not allowed to stand
behind the official with the supplemental poll book, and he needed to stand in front of the computer
screen. Mr. Larsen told her that was not true, and that he was statutorily allowed to observe the
process, including the poll book (Exhibit A).
24. The supervisor then pivoted to arguing that Mr. Larsen was not six feet away from
the first official. Mr. Larsen told her that he was attempting to remain as far away as he could while
still being able to read the names on the poll book (Exhibit A).
25. The supervisor then stood next to the chair immediately to the left of the first
official and indicated that Mr. Larsen was “not six feet away from” the supervisor and that she
intended to sit in the chair next to the official with the poll book, so he would need to leave (Exhibit
A).
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Great Lakes Justice Center
26. This supervisor had not been at the table at any time during the process, and she
had responsibility for numerous ACVBs. Further, the supervisor’s choice of chairs was
approximately three feet to the left of the first official and therefore in violation of the six-foot
distance rule (Exhibit A).
27. Accordingly, Mr. Larsen understood that this was a ruse to keep him away from a
place where he could observe the confirmation of names in the supplemental poll book. The
supervisor began to repeatedly tell him that he “needed to leave” so he responded that he would
go speak with someone else and fill out a challenge form (Exhibit A).
28. After Mr. Larsen observed and uncovered the fraud that was taking place and had
the confrontation with the supervisor, he left the counting room to consult with another attorney
about the matter around 1:30 p.m. to 2:00 p.m. (Exhibit A).
29. It was at this point that election officials stopped permitting any further poll
challengers to enter the counting room, including Mr. Larsen (Exhibit A).
30. Election officials never allowed Mr. Larsen to re-enter the counting room to fulfill
his duties as a poll challenger after he had discovered the fraud which was taking place.
Illegal Voter Coaching and Identification Issues
31. An election employee with the City of Detroit was working at a polling location for
approximately three weeks prior to the election. This City of Detroit employee directly observed,
on a daily basis, other City of Detroit election workers and employees coaching voters to vote for
Joe Biden and the Democrat party. This employee witnessed these workers and employees
encouraging voters to do a straight Democrat ballot and witnessed these election workers and
employees going over to the voting booths with voters in order to watch them vote and coach them
for whom to vote (Exhibit B – Affidavit of Jessy Jacob).
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32. During the last two weeks while this same employee was working at the polling
location, she was specifically instructed by her supervisor never to ask for a driver’s license or any
photo I.D. when a person was trying to vote (Exhibit B).
Changing Dates on Ballots
33. All absentee ballots that existed were required to be inputted into the QVF system
by 9:00 p.m. on November 3, 2020. This was required to be done in order to have a final list of
absentee voters who returned their ballots prior to 8:00 p.m. on November 3, 2020. In order to
have enough time to process the absentee ballots, all polling locations were instructed to collect
the absentee ballots from the drop-box once every hour on November 3, 2020 (Exhibit B).
34. On November 4, 2020, a City of Detroit election worker was instructed to
improperly pre-date the absentee ballots receive date that were not in the QVF as if they had been
received on or before November 3, 2020. She was told to alter the information in the QVF to
falsely show that the absentee ballots had been received in time to be valid. She estimates that this
was done to thousands of ballots (Exhibit B).
Illegal Double Voting
35. The election employee observed a large number of people who came to the satellite
location to vote in-person, but they had already applied for an absentee ballot. These people were
allowed to vote in-person and were not required to return the mailed absentee ballot or sign an
affidavit that the voter lost the mailed absentee ballot (Exhibit B).
36. This would permit a person to vote in person and also send in his/her absentee
ballot.
37. Prior to the election, the Michigan Secretary of State sent ballot applications to
deceased residents and to non-residents of the State of Michigan.
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First Round of New Ballots
38. At approximately 4:00 a.m. on November 4, 2020, tens of thousands of ballots were
suddenly brought into the counting room through the back door (Exhibit C – Affidavit of Andrew
Sitto).
39. These new ballots were brought to the TCF Center by vehicles with out-of-state
license plates (Exhibit C).
40. It was observed that all of these new ballots were cast for Joe Biden (Exhibit C).
Second Round of New Ballots
41. The ballot counters were required to check every ballot to confirm that the name on
the ballot matched the name on the electronic poll list; this was the list of all persons who had
registered to vote on or before November 1, 2020 and is often referred to as the QVF (Exhibit D –
Affidavit of Bob Cushman)
42. The ballot counters were also provided with Supplemental Sheets which had the
names of all persons who had registered to vote on either November 2, 2020 or November 3, 2020
(Exhibit C).
43. The validation process for a ballot requires the name on the ballot to be matched
with a registered voter on either the QVF or the Supplemental Sheets.
44. At approximately 9:00 p.m. on Wednesday, November 4, 2020, numerous boxes of
ballots were brought to TCF Center (Exhibit D).
45. Upon information and belief, the Wayne County Clerk’s office instructed the ballot
counters to use the date of birth of January 1, 1900 on all of these newly appearing ballots.
46. None of the names of these new ballots corresponded with any registered voter on
Excellent post-election summary can be found on Church Militant. Looking for Truth? Don’t miss hearing this update from someone whose input we’ve come to respect. Check out
https://www.churchmilitant.com/news/article/post-election-special
On MSNBC, former Obama official Ben Rhodes said that Biden is already “having phone calls” with foreign leaders. LifeSiteNews states: “This is treason. They have no right to do this. Nothing has been certified. They are actively undermining our country’s sitting president.”
LifeSiteNews adds: “To their eternal shame, the U.S. Conference of Catholic Bishops is also going along with this hoax. They sent a letter this past weekend congratulating Joe Biden on becoming the second “Catholic president” in American history. Perhaps they’ve forgotten, but Joe Biden has officiated several gay “marriages.” He’s also pledged to drag the Little Sisters of the Poor back to court and is fully in favor of the LGBT “Equality Act,” a bill that would threaten the religious liberty of Catholic schools across the country. Joe Biden’s certainly not a Catholic in good standing. Shame on our bishops for supporting this nonsense.”
Citing psychological manipulation, LifeSiteNews further reports: “They want those of us on the political right to simply give up while making sure the left is so thoroughly convinced that Biden won, that, should things end up going in Trump’s direction later on, they’ll be so furious that they’ll go out and riot with Antifa and Black Lives Matter and burn the country down. The Democrat strategy all along has been to create such a massive amount of chaos and fraud that it’d be impossible to trace and then to get the media and Big Tech to ignore and censor those exposing it. They wanted, quite simply, to break the system.
Read full article here: https://www.lifesitenews.com/blogs/the-real-reason-mainstream-media-is-falsely-pushing-narrative-that-biden-is-president-elect?utm_source=LifeSiteNews.com&utm_campaign=1b2e7904ab-Daily%2520Headlines%2520-%2520U.S._COPY_891&utm_medium=email&utm_term=0_12387f0e3e-1b2e7904ab-401405353
https://www.lifesitenews.com/news/trump-team-lawyer-sidney-powell-explains-why-ballot-counting-suddenly-stopped-on-election-night?utm_source=LifeSiteNews.com&utm_campaign=c7bfef0a00-Daily%2520Headlines%2520-%2520U.S._COPY_897&utm_medium=email&utm_term=0_12387f0e3e-c7bfef0a00-401405341
https://www.churchmilitant.com/?mc_cid=2d05a136c0&mc_eid=87b0370dca