77 43. Appellants/Intervenors say that the CDHO's Final Ruling is founded on the legal principle of "actual fraud" and the CDHO ignored the legal principle of "constructive fraud" or "legal fraud"; the type of evidence required for both classifications of fraud is different (37 Am Jur 2d, Fraud and Deceit, Sections 3 &4). Given the relationship between Appellants and Appellee in the October 10, 2017 elections, Appellee's violations of the Constitution and Elections Law and its own regulations to the disadvantage of Appellants/ Intervenors constitute "constructive fraud", otherwise called "legal fraud". It was therefore sufficient for Appellants/Intervenors to show that Appellee violated laws and its own regulations much to the prejudice of Appellants/Intervenors and constructive/legal fraud is thereby established. For applying the principle of actual fraud only to the facts and circumstances of Appellants/Intervenors' complaint, Appellants/Intervenors say that the CDHO committed a reversible error. And so Appellants excepted and presented the issue to the NEC Board but the NEC Board did not pass on the issue. And so Appellants/Intervenors except. 44. Appellants/Intervenors say that constructive/legal fraud requires neither actual dishonesty nor intent to deceive, being a breach of legal or equitable duty, which irrespective of the moral guilt of the wrongdoer, the law declares fraudulent because of its tendency to deceive others, to injure public interests, or to violate public or private confidence. 37 Am. Jur 2d., Fraud and Deceit, Section4. Appellants/Intervenors say that had this principle of law on constructive/legal fraud been applied by the CDHO to the evidence adduced by Appellants/Intervenors, the CDHO would have properly ruled that massive pervasive frauds were committed throughout the October 10, 2017 elections, which undermined the credibility and integrity of the entire elections. For the CDHO's failure to so rule, Appellants/Intervenors excepted and presented the issue before the NEC Board but the NEC Board did not pass on the issue. And so Appellants/Intervenors except. 45. That Appellants Intervenors say that given the relationship between them and Appellee during the October 10, 2017 elections, Appellants/Intervenors are required to prove constructive/legal fraud, not necessarily actual fraud. The burden of proof for actual fraud is different from the burden of proof for constructive fraud; and what the CDHO did in his Final Ruling, was to use the burden of proof for actual fraud, which was not in itself done well, to be the same burden of proof for constructive/legal fraud and based his Final Ruling on that assumption. So Appellants excepted and presented the issue to the NEC Board but the NEC Board did not pass on the issue. And so Appellants/Intervenors except. 46. Appellants/Intervenors says that in addition to constructive/legal fraud its evidence at the hearing fully justifies the finding that actual frauds were committed before and during the course of the October 10, 2017 elections. Appellants/Intervenors say that Liberian law is that one of the underlying elements of fraud is the conduct of a person that

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