King v. Whitmer CIVIL 20-13134 (E.D. Mich. Aug. 25, 2021) Cir. 2019) (citations omitted) (explaining that “reasonable inferences from the evidence” are allowed but not “mere speculative inferences”); see also id. (quoting Cold Metal Process Co. v. McLouth Steel Corp., 126 F.2d 185, 188 (6th Cir. 1942) (“An inference is but a reasonable deduction and conclusion from proven facts.”)). b) Counsel's presentment of conjecture and speculation as evidentiary support for factual assertions Plaintiffs' counsel presented affidavits that were based on conjecture, speculation, and guesswork. To support the allegation that “unsecured ballots arrived at the TCF Center loading garage, not in sealed ballot boxes, without any chain of custody, and without envelopes, after the 8:00 PM Election Day deadline, ” Plaintiffs quote the affidavit of Matt Ciantar (“Ciantar Affidavit”), 52, 53 which is a masterclass on making conjectural leaps and bounds: 52 (ECF No. 6 at Pg ID 943 ¶ 190(k) (citing IIC); see IIC - “Additional Violations of Michigan Election Code That Caused Ineligible, Illegal or Duplicate Ballots to Be Counted, ” Subsection 7 - “Election Workers Accepted Unsecured Ballots, without Chain of Custody, after 8:00 PM Election Day Deadline, ” ECF No. 6 at Pg ID 906 ¶ 103 (quoting Ciantar Affidavit, ECF No. 6-7 at Pg ID 1312-14).) 53 Plaintiffs also reference the Gustafson and Meyers Affidavits to support this allegation. (ECF No. 6 at Pg ID 905-06 ¶¶ 100-03.) For the reasons discussed above (see supra 58, 63-64), these two affidavits are of little to no evidentiary value. The afternoon following the election[, ] as I was taking my normal dog walk (midafternoon), I witnessed a dark van pull into the small post office located in downtown Plymouth, MI. I witnessed a young couple . . . pull into the parking lot . . . and proceed to exit their van (no markings) . . . and open[] up the back hatch and proceed[] to take 3-4 very large clear plastic bags out . . . and walk them over to a running USPS Vehicle that appeared as if it was “waiting” for them.... There was no interaction between the couple and any USPS employee which I felt was very odd....They did not walk inside the post office like a normal customer to drop of[f] mail. It was as if the postal worker was told to meet and standby until these large bags arrived.... [T]he bags were clear plastic with markings in black on the bag and on the inside of these clear bags was another plastic bag that was not clear (could not see what was inside) .... [There were] what looked like a black security zip tie on each back [sic] as if it were “tamper evident” type of device to secure the bag.... [B]y the time I realized I should take pictures of the bags once I noticed this looked “odd[, ]” they had taken off. The other oddity was that [sic] the appearance of the couple. After the drop, they were smiling, laughing at one another. What I witnessed and considered that what could be in those bags could be ballots going to the TCF center or coming from the TCF center .... (ECF No. 6-7 at Pg ID 1312-14 (emphasis added).) When the Court asked Plaintiffs' attorneys how any of them, as officers of the court, could present this affidavit as factual support of anything alleged 30

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