Election Fraud Lawsuit Filed - Pennsylvania

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Total of 91 pages. I will post the Defendants and Intro only. Should be available publicly soon.

 

 

 

STATE OF PENNSYLVANIA
IN THE COURT OF COMMON PLEAS FOR DELAWARE COUNTY
RUTH MOTON,
FRIENDS OF RUTH MOTON INC.,
LEAH HOOPES, GREGORY STENSTROM,
Plaintiffs,
v.
FORMER SECRETARY OF STATE KATHY BOOCKVAR, in her official and individual capacity, DELAWARE COUNTY, DELAWARE COUNTY BOARD OF ELECTIONS, DELAWARE COUNTY BUREAU OF ELECTIONS, JAMES BYRNE, in his official and individual capacity,
GERALD LAWRENCE,
in his official and individual capacity,
ASHLEY LUNKENHEIMER, in her official and individual capacity,
CHIEF CLERK FOR THE DELAWARE COUNTY BUREAU OF ELECTIONS, LAUREEN HAGAN, in her official and individual capacity, DELAWARE COUNTY DIRECTOR OF ELECTIONS, JAMES P. ALLEN,

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in his official and individual capacity,

MARYANNE JACKSON, INTERIM DIRECTOR OF ELECTIONS, in her official and individual capacity,

CHIEF CUSTODIAN AND VOTING MACHINE WAREHOUSE SUPERVISOR JAMES SAVAGE,

in his official and individual capacity,

THOMAS GALLAGER,

in his official and individual capacity,

JAMES A. ZIEGELHOFFER, in his official and individual capacity,

CRYSTAL WINTERBOTTOM, CHIEF CLERK OF VOTER REGISTRATION, in her official and individual capacity, CHEVON FLORES, MAIL-IN BALLOT COORDINATOR, in her official and individual capacity, JEAN FLESCHUTE, in her official and individual capacity,

STACY HEISEY-TERRELL, in her official and individual capacity,

CHRISTINA IACONO,

in her official and individual capacity,

CHRISTINA PERRONE, in her official and individual capacity, DELAWARE COUNTY RETURN BOARD, KAREN REEVES, in her official and individual capacity, DONNA RODE, in her official and

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individual capacity, NORMA LOCKE, in her official and individual capacity, JEAN DAVIDSON, in his official and individual capacity, S. J. DENNIS, in his official and individual capacity, MARILYN HEIDER, in her official and individual capacity, TOM GALLAGHER, in his official and individual capacity, LOUIS GOVINDEN, in his official and individual capacity, DOUG DEGENHARDT, in his official and individual capacity, MARY JO HEADLEY, in her official and individual capacity, JENNIFER BOOKER, in her official and individual capacity, KENNETH HAUGHTON, in his official and individual capacity, JAMES A. ZIEGLELHOFFER, in his official and individual capacity, REGINA SCHEERER, in her official and individual capacity, CATHY CRADDOCK, in her official and individual capacity, MAUREEN T. MOORE, in her official and individual capacity, PASQUALE CIPPOLLONI, in his official and individual capacity, and GRETCHEN BELL, in her official and individual capacity, DELAWARE COUNTY CLERK, ANNE COOGAN, in her official and individual capacity, ET AL.

Defendants.

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NOTICE TO DEFEND

You have been sued. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this complaint and the attached notice are served by entering a written appearance personally or by an attorney and filing in writing with the court your defenses or objections to the claims set forth against you in this complaint. You are warned that if you fail to do so the case may proceed and a judgment may be entered against you by the court, without further notice, for any money being sought in the complaint, and/or for any other claims or relief requested by the plaintiffs bringing this action. You may lose money and/or other property or rights important to you. You should take this notice and complaint to your lawyer at once. If you do not have a lawyer or cannot afford one, you may seek help by contacting the following office:

DELAWARE COUNTY BAR ASSOCIATION Lawyer Referral Services 335 W. Front Street Media, PA 19063

(610) 566-6625

COMPLAINT

NOW COMES Plaintiffs, RUTH MOTON, LEAH HOOPES, AND GREGORY

STENSTROM, for their complaint for declaratory, injunctive, mandamus, quo warranto,

and any and all other legal remedies available pursuant to law, and other relief as specified

INTRODUCTION

herein, state as follows:

As provided in this Complaint, Defendants intentionally and fraudulently conspired

to destroy, delete, secrete, and hide November 3, 2020, election data, materials, and

equipment to prevent discovery of election fraud and election law violations in Delaware

County, which the Defendants also conspired to commit and did commit while carrying

out the November 3, 2020, election. In furtherance of this conspiracy, Defendants

intentionally created chaos surrounding the November 3, 2020, election so that they would

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be able to then carry out the acts of election fraud and the election law violations described

herein undetected.

Defendants did this, in part, by placing incompetent or underqualified individuals

with no training in positions of responsibility so that they would be able to hide their fraud

under the pretense of the incompetence of election day workers/volunteers in the event the

election fraud and election law violations were discovered.

Moreover, when a May 21, 2021 Right to Know (RTK) request for election

information and data was made with respect to information that is by federal and state law

to be kept and preserved, the Defendants fraudulently and intentionally deleted, changed,

adulterated, manipulated and/or obscured the information, data, and materials produced in

response to the RTK request in order to hide their fraud and election code violations

because they knew that they could not reconcile the previously fraudulently reported

November 3, 2020 election results with the actual responsive information that they had in

their possession and which they were required to preserve and produce in response to the

Right to Know request.

Plaintiffs know this to be the case and can document this and demonstrate this by

showing, among other things, that November 3, 2020 election, data materials, and

equipment was destroyed including but not limited to V-Drives, Return Sheets, machine

tapes/proof sheets/result tapes, Mail-In Ballots, Ballots Destroyed, voting machines, hard

drives, paper documentation, Blue Crest data, correspondence concerning the November

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1. Plaintiff, RUTH MOTON, is a legally registered voter and was a candidate for

Pennsylvania State Representative, District 159, in the November 3, 2020 election,

appearing on the ballot in Delaware County Pennsylvania.

2. Ruth Moton resides in Delaware County, Pennsylvania, and voted in the November

3, 2020, election.

3. FRIENDS OF RUTH MOTON, PAC.

4. Plaintiff, LEAH HOOPES, is a legally registered voter who resides in Delaware

County, Pennsylvania, and who voted in the November 3, 2020, election. [Exhibit A].

5. Plaintiff, GREGORY STENSTROM, is a legally registered voter who resides in

Delaware County, Pennsylvania, and who voted in the November 3, 2020, election.

[Exhibit B].

6. Mr. Stenstrom was appointed as the sole GOP poll watcher for 36 precincts (1-1

through 11-6), located in Chester City, Pennsylvania. Id., ¶ 5.

7. The Delaware County Board of Elections provided Mr. Stenstrom with a certificate

of appointment as a poll watcher. Id., ¶ 6. [Exhibit C].

8. During the November 3, 2020, election, Mr. Stenstrom was able to inspect and

observe 22 precincts. Id., ¶ 5.

9. Defendant, Kathy Boockvar, was Pennsylvania’s Secretary of State during the

November 3, 2020, election. In this role, Secretary Boockvar leads the Pennsylvania

Department of State. As Secretary, she was Pennsylvania’s Chief Elections Officer and a

member of the Governor’s Executive Board. The Pennsylvania Constitution vests no

powers or duties in Secretary Boockvar. Perzel v. Cortes, 870 A.2d 759, 764 (Pa. 2005).

Instead, her general powers and duties concerning elections are set forth in Election Code