King v. Whitmer CIVIL 20-13134 (E.D. Mich. Aug. 25, 2021) shortly after the election and well-before his report was filed here.67 A reasonable attorney, seeing 68 Official Results for November 3, 2020 Ramsland's striking original figures, would inquire into their accuracy or at least question their source. 2020, 2:11 PM), https://perma.cc/A8MY- 67 Ramsland fails to identify the source of his figures in the initial affidavit presented in this case, indicating only that he and his General Election, City of Detroit (Nov. 19, FZEJ. 69 Official Results for Ottawa County Precinct, Ottawa County (Nov. 11, 2020, 4:20 PM), at PDF Pg 918-54, https://perma.cc/3W57-D33G. colleagues “have studied the information 70 Official Results for Muskegon County that is publicly available concerning the Precinct, Muskegon County (Nov. 13, November 3, 2020 election results.” (See 2020, 5:55 PM), at PDF Pg 466-67, ECF No. 6-24 at Pg ID 1573 ¶ 9.) He https://perma.cc/9MAA-J6RU. astoundingly claims, however, that “[s]ome larger precincts in Wayne Co[unty] and others are no longer publicly reporting their data[.]” (Id. at Pg ID 1574 ¶ 11.) And after it Ramsland's was widely figures reported were that grossly inaccurate, Plaintiffs' counsel submitted new numbers from Ramsland in an “expert report” filed December 3, 2020, where Ramsland claims that “[t]he source of that original data was State level data that no longer exists [f]or some unexplained reason” and, for the first time, identifies those purported sources. (ECF No. 49-3 at Pg ID 3123 ¶ 6.) Even the most basic internet inquiry would have alerted Plaintiffs' counsel to the wildly inaccurate assertions in Ramsland's affidavit. For example, in comparison to the voter turnout of 139.29% in the City of Detroit claimed by Ramsland, the official turnout was recorded on or before November 19, 2020 as being 50.88%.68 Ramsland reported that voter turnout in Zeeland Charter Township was a whopping 460.51%, when an official report ran on November 11 showed that the average turnout for the four precincts within the township was 80.11%.69 And unlike Ramsland's assertion of an eye-popping 781.9% turnout in the City of North Muskegon, the two precincts in the city had a turnout of 73.53% and 82.21%, averaging 77.78%, as indicated as of November 13, 2020.70 And before Plaintiffs' counsel presented Ramsland's affidavit here, there was more to alert them as to the unreliability of Ramsland's figures and to put them on notice that further inquiry was warranted. Specifically, attorneys used an affidavit from Ramsland in Wood's challenge to the presidential election results in Georgia. See Aff., Wood v. Raffensperger, No. 20-04651 (N.D.Ga. Nov. 18, 2020), ECF No. 7-1. But there, Ramsland represented data as being from Michigan when, in fact, the townships listed were in Minnesota. See id. at Pgs. 3, 6. Moreover, it was widely publicized before Plaintiffs' counsel offered Ramsland's affidavit here that even for the Minnesota locations, Ramsland's conclusions about overvotes was not supported by official data from the State.71 71 See, e.g., Aaron Blake, The Campaign's Much-Hyped Trump Affidavit Features a Big, Glaring Error, Washington Post (Nov. 21, 2020, 7:39 AM), https://perma.cc/E6LY-AL44. It is true, as Plaintiffs' attorneys assert to defend their use of Ramsland's affidavit, that Ramsland adjusted his voter turnout figures in a subsequently filed report. (See ECF No. 157 at Pg ID 5396; ECF No. 49-3 at Pg ID 3124.) However, counsel never drew attention to this modification in the reply brief to which Ramsland's updated report was attached, or anywhere else. (See ECF No. 49.) But more importantly, this does not 36