King v. Whitmer CIVIL 20-13134 (E.D. Mich. Aug. 25, 2021) support Plaintiffs' legal contentions directly or even by extension. Yet counsel's citation to Throckmorton is enlightening in that it reflects, as the City puts it, “that this suit has been driven by partisan political posturing, entirely disconnected from the law” and “is the dangerous product of an online feedback loop, with these attorneys citing ‘legal precedent' derived not from a serious analysis of case law, but from the rantings of conspiracy theorists sharing amateur analysis and legal fantasy in their social media echo chambers.” (ECF No. 164 at Pg ID 6143.) results34. The fact that no federal district court considering the issues at bar has found them worthy of moving forward supports the conclusion that Plaintiffs' claims are frivolous. 33 Op. & Order, Costantino, No. 20-014780- AW (Wayne Cnty. Cir. Ct. filed Nov. 13, 2020); Donald J. Trump for President, Inc. v. Sec'y of State, Nos. 355378, 355397, 2020 Mich. LEXIS' 2131 (Mich. Ct. App. Dec. 11, 2020), appeal denied 951 N.W.2d 353 (Mich. 2020). 34 See 12/7/20 Tr., Pearson v. Kemp, No. 31 (See ECF No. 164-8 at Pg ID 2 (listing 1:20-cv-04809 (N.D.Ga. filed Dec. 8, Twitter posts that state, among other things, 2020), ECF No. 79 at ¶ 41-44; Wood v. that (i) “[A]ny fraud located . . . constitutes Raffensperger, nullification of the presidential contest. (N.D.Ga. 2020), aff'd 981 F.3d 1307 (11th This means, Trump wins by default Cir. 2020); Feehan v. Wis. Elections Comm because of the vote switching by Dominion 'n, 506 F.Supp.3d 596 (E.D. Wis. 2020); Machines. Look up Throckmorton 1878.”; Bowyer v. Ducey, 506 F.Supp.3d 699 (D. (ii) “[F]raud will DISQUALIFY Biden Ariz. 2020). 501 F.Supp.3d 1310 completely and mean that Trump will be the winner of all 50 states .... There can be no other outcome. ‘Fraud vitiates everything' US v. Throckmorton ....”; (iii) “[F]raud vitities everything. Meaning one state commits voter fraud they all go down! So DJTrump wins the 2020 election.”; and (iv) “Fraud vitiates everything it touches. [THROCKMORTON] .... Thus the Biden/Harris ‘swearing in' is negated, quashed annulled, invalidated, revoked and abrogated.”).) 32 Of course, the Supreme Court did not hold in Throckmorton that “fraud vitiates everything”; rather, it merely quoted this phrase from a treatise and then held that, in fact, fraud did not justify overturning a federal district court's 20-year-old decree. 98 U.S. at 65, 68. It is not lost upon the Court that the same claims and requested relief that Plaintiffs' attorneys presented here were disposed of, for many of the same reasons, in Michigan courts33 and by judges b) Counsel's contention that acts or events violated Michigan election law (when the acts and events, even if they occurred, did not) Plaintiffs alleged that certain acts or events violated the Michigan Election Code when, in fact, they did not. To support the allegation that Defendants violated Michigan election laws by accepting “unsecured ballots . . . without any chain of custody, ”35 the Amended Complaint states that Whitney Meyers “observed passengers in cars dropping off more ballots than there were people in the car.”36 But when the Court asked Plaintiffs' counsel whether individuals other than the voter can drop off a ballot in Michigan, Campbell answered in the affirmative. (ECF No. 157 at Pg ID 5486.) And of course, anyone easily could have learned this by consulting Michigan law. See Mich. Comp. Laws § 168.764a (explaining at Step 5(c) that a household member or family member (as defined by Michigan law) may return a voter's absentee in several other “battleground” jurisdictions where Plaintiffs' counsel sought to overturn the election 24

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