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attached hereto, in bulk, copies of ballots used during the elections,
evidencing the absence of serial numbers, as Exhibit "CI. Complainants
challenge the NEC to produce the ballots used during the elections that carry
serial numbers. The complainants submit that the design of the ballots
without serial numbers was a calculated means of ensuring massive fraud, as
was conducted during the elections. This alone warrants a rerun of the
elections, and the complainants so pray.
(c) Because the ballots did not have serial numbers or the serial numbers, [and
the] ballots used in the October 10, 2017 elections remain unknown, the NEC
officials and others were at liberty to change and replace ballots at will. Seals
on ballot boxes were broken after the voters had voted, polls were closed, and
the ballot boxes were sealed.
5. The absence of Queue Controllers.
At most of the polling places there was no Queue Controller to ensure that
voters were queuing on the right line. This frustrated many voters who stood
many hours on the line to exercise their franchise, only to be told that they
were on the wrong line. Many such voters left the polling place unable to find
the right line, and without being able to vote, thus being deprived of their
constitutional right to vote. (In the past elections, 2005 and 2011, the polling
places were labeled in series with the voting numbers. So, when a person
came to vote at a polling place, s/he knew exactly what line to stand
on).Because there was no Queue Controller to assist persons with disabilities,
the elderly, and infirm, the polling officers could not give preference to such
persons at the polling place, as required by law. As examples of some
individuals who were told that they were on the wrong line after queuing for
several hours, [they] left the polling place out of frustration. Complainants give
notice that during the trial they will produce copies of the Voters ID Cards of
such individuals, and/or their affidavits.
II.
Fraudulent Acts
The complainants submit that the entire election was characterized by fraud,
evident by the analyses of some of the Record of Counts, which are hereto
attached in bulk and marked complainants' Exhibit "D," in substantiation of
this averment to form a cogent part of complainants' complaint. Notice is
given that during the hearing, the supporting Record of Counts will be
produced. We also provide other specific incidents of fraud herein below.
1. After voting ended at Precinct #30073, Barnersville Public School, Polling
Place #3, Montserrado County, the ballot box was sealed with the following
numbers, (a) Pre-046330 —front (b) Pre-046324 — right, (c) Pre-046335—
left, and party representatives left the polling place. Unfortunately for the
Presiding Officer, a poll watcher returned to the polling place only to find the
Presiding Officer's hand in the ballot box, having broken the seals. The
numbers of the second set of seals that was placed on the ballot box are (a)
Pre— 046324, (b) Pre-027338, (c) Pre-027323, and (d) Pre— 046336.
Complainants give notice that they will produce an affidavit of the poll
watcher in support of this averment during the hearing. Complainants say that
this incident clearly suggests that in many of the places where pool watchers
or observers did not return to the place where the ballot boxes were held, the
Presiding Officers could have engaged in such similar conduct and
manipulated the votes. Complainants submit that this clearly places the