Great Lanes Justice CenTeR STATE OF MICHIGAN IN THE CIRCUIT COURT FOR THE COUNTY OF WAYNE, CHERYL A. COSTANTINO and EDWARD P. MeCAl SUPPLEMENTAL BRIEF IR {UPPORT OF MOTION FOR ‘TEMPORARY RESTRAINING iMINARY, Plaintits, CITY OF DETROIT; DETROIT ELECTION FILE NO: 20-014780-AW COMMISSION: Janice M. Winfrey. in her officia capacity as the CLERK OF THE. HON. TIMOTHY M, KENNY CITY OF DETROIT and the Chairperson of the DETROIT ELECTION COMMISSION; Cathy M. Garrett, in her official capacity as the CLERK OF WAYNE COUNTY; and the WAYNE COUNTY BOARD OF CANVASSERS, Defendants, David A. Kallman (P3420) Brin E, Mersino (P 70886) Jack C, Jordan (Pa6sst) Stephen P. Kallman (P75622) Great Lakes Justice Center Attorneys for Plaintiff ‘3600 W. Mount Hope Hwy. Lansing, MI 48917 (517) 322-3207/Rax: (517) 322-3208 ENTAL BRIEF IN SUPPORT OF MOTION FOR TEMPORARY RESTRAINING ORDER AND PRELIMINARY INJUNCTION Plaintiffs just received an Affidavit from Melissa Carone, Ms. Carone was a contractor for Dominion Voting Systems to do IT work at the TCF Center. Ms. Carone was at the TCF Center from 6:15 am. on November 3, 2020 to 4:00 am, on November 4, 2020, She then went home to jet 8 few ours sleep and worked again at the TCF Center from 10:00 a.m, until 1:45 p.m. onGREAT Lakes Justice CentER — November #®. Ms. Carone states that she “witnessed nothing but fraudulent actions take place” (Exhibit H), Further, Ms. Carone states: 3. The counters (which were trained very ite or not at all), were handed a "batch" (tack of 50) of mail-in ballots in which they would run through the tabulator. The tabulators would get jammed 4-5 times an hour, when they jammed the computer ‘would put out an error that ells the worker the ballot number that was jammed and ‘ives an option to either discard the batch or continue scanning at which the counter should discard the batch, put the issue ballot on top of the batch and rescan the entze batch. 1 witnessed countless workers rescanning the batches without discarding them first which resulted in ballots being counted 4-5 times. 4. Atapproximately midnight I was called over to assist one ofthe counters with a paper jam and noticed his PC bad a number of over 400 ballots scanned- which ‘means one batch was counted over 8 times. This happened countless times while I wwacat the TCF Center. I conftonted my manager, Nick Ikonomakis saying how big, cof « problem this was, Nick told me he didnt want to hear that we have a big problem, He told me we are here todo assist with IT work, not to run their election, 5. The adjudication process, from my understanding there's supposed to be a republican and a democrat judging these ballots. I overheard numerous workers talking during shift change in which over 20 machines had two democrats judging ‘the ballots-resulting in an unfair process. ‘9, When a worker had a ballot that chey either could not read, or it had something spilled oni, they would go toa table that had blank ballots oni and fill i out. They ‘were supposed to be filling them out exactly lke the one they had received but this was not the case tall. The workers would also sign the name of the person tha the ballot belonged to-which is clearly illegal 13. called the FBI and made a report with them, I was told that Iwill be getting a call back. Ms. Carone’s sworn statement provides further evidence that fraud and misconduct ‘occurred at the November 3, 2020 election. Plaintiffs request that their Motion for TRO and Preliminary Injunction be granted Respectfully submited, Dated: November 10, 2020 ‘4 David A, Kallman. David A. Kallman (34200) ‘Attorney for PlattsEXHIBIT HSTATE OF MICHIGAN [BCTHE CIRCUIT COURT POR THE COUNTY O¥ WAYNE MELLISA A. cARONT, AgTIDAMITOF MILLIS. Phin, anon, CITY OF DETROFT: DETROIT ELECTION er fla capacity asthe CLERK OF THE, CITY OF DETROIT se the Chairperion of mer ‘The DETROTT ELECTION COMMISSION; (CATHY Mt. GARRETT, ner of Capac tthe CLERK OF WAYNE COUNTY BOARD OF CANVASSERS, nant Rasa Or aescan Defendants, ermine 1284 ins Sw Sere David A, Katinas @ss200) rie E: Merino ern) ack. Jordan eruessty Stepan. Katiman ornse2) (GREAT LAKES JUSTICE CENTER, Attraeys for Plat ‘5600 W. Mount Hope Hy ansng, M8917 (517) 32252071 Fae (17) 32-208 AbpDAvIT ‘The Afi Malis A. 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