15
Charles W. Brumskine and Harrison Karnwea, was said to have been counted
in favor of the Unity Party. Attached is the photo of the wounded Liberty Party
Poll Watcher, as complainants' Exhibit "O."
7. Two young men, who do not appear to be NEC officials, but in any case
unaccompanied by a Police Officer, are [seen] wading in a body of water with
sealed ballot boxes on their heads. Attached is a copy of the photo of the two
young men with the ballot boxes marked as complainants' Exhibits "P."
8. Individuals, whether they are NEC officials or not, in a canoe carrying ballot
boxes, are unaccompanied by a Police Officer, as shown in a photo, which is
hereto attached as complainants' Exhibits "Q".
9. In District #4, Klein Town, Polling Center # 09085, Polling Place #1 in Grand
Bassa County, ballots were cast in a bathing tub, instead of a sealed ballot box.
The Presiding Officer, Mary Yarkpawolo, admits that a sealed ballot box was
not used, but claims that what she used was an unsealed "Polling kit" and not
a bathing tub. She claimed that a ballot box is not "sensitive material."
Attached hereto is copy of a transcript of a recording by a local journalist who
interviewed a Party Supervisor during the voting, as complainants' Exhibit "R."
If need be, the local journalist will be subpoenaed during the hearing. Also,
attached hereto is copy of the Minutes of a Magistrate hearing, during which
the Presiding Officer confirms that she did not use a sealed ballot box, as
complainants' Exhibit "S."
10. In District #4, Kennedy Town, Polling Precinct 09039, Polling Place #2 in
Grand Bassa County, ballots were cast in a carton box, instead of a sealed
ballot box. The Presiding Officer, Patrick K. Ninwillay, admits that a sealed
ballot box was not used, but claims that what he used was an unsealed "Polling
kit" and not a cartoon. Attached hereto as Complainants' Exhibit "T" are copies
of the minutes of the hearing of the candidate's complaint, during which the
Presiding Officer confirmed using an unsealed "Polling kit."
11. In District #13, Montserrado County, voters cast their votes in a box that
was not one of the regular ballot boxes. But what is of greater significance is
that the box was open while voters cast their votes. Copies of the photos of
the box are hereto attached as complainants' Exhibit “U”.
12. Because of the high percentage of invalid ballots, complainants hereby
gives notice that during the hearing they will require a review of all invalid
ballots. 88,400 votes have been declared invalid, constituting about 5.4% of
the votes cast. This, petitioner says, among others, significantly impacted the
election results.
13. Complainants say that numerous other incidents occurred which violated
the constitutional rights of the voters, and which have also been reported by
independent and credible election observers, such as the European Union
Election Observation Mission, referenced in in Count 1.1(a) above, and the
Women's Situation Room. Complainants hereby pray that judicial notice be
taken of the public statement issued by the Women's Situation Room (a nonpartisan and neutral based forum organized pursuant to UNSCR 1325), issued
on October 16, 2017, and entitled "Statement by the Women's Situation Room
— Liberia on the Conduct of the October 10, 2017 Presidential and
Representative Election in Liberia." The relevant portion of said statement is
quoted verbatim below:
"However, reports from our observers across the country as well as data
received from the public via the 1010 short code in our Call Centres pointed