Ex. 3). Apart from a screenshot of Mr. Braynard’s tweets that day, Plaintiffs offer nothing further about Mr. Braynard’s identity, qualifications, or methodologies used in conducting his telephone “survey.” But according to the Briggs’ report, Mr. Braynard conducted his survey of unknown size and to unknown persons in Georgia, Michigan, Wisconsin, Arizona, and Pennsylvania regarding absentee ballots, and his “findings” were conveyed to Mr. Briggs. (Id.) In concluding that there were “clearly a large number of troublesome ballots in each state,” Mr. Briggs assumed Mr. Braynard’s “survery [sic] respondents [were] representative and the data [was] accurate.” (Id.) This cavalier approach to establishing that hundreds of thousands of Arizona votes were somehow cast in error is itself troublesome. The sheer unreliability of the information underlying Mr. Briggs’ “analysis” of Mr. Braynard’s “data” cannot plausibly serve as a basis to overturn a presidential election, much less support plausible fraud claims against these Defendants.
The Complaint is equally void of plausible allegations that Dominion voting machines were actually hacked or compromised in Arizona during the 2020 General Election. Plaintiffs are clearly concerned about the vulnerabilities of voting machines used in some counties across Arizona and in other states. They cite sources that attest to knowledge of “well-known” vulnerabilities, have included letters from concerned citizens, Arizona elected officials, and United States senators. Plaintiffs even attach an affidavit of an anonymous witness with connections to the late Venezuelan dictator Hugo Chavez claiming to be privy as to how officials in Venezuela rigged their elections with the help of a voting systems company whose software “DNA” is now used in voting machines in the United States. (Doc. 1-1, Ex. 1). These concerns and stated vulnerabilities, however, do not sufficiently allege that any voting machine used in Arizona was in fact hacked or compromised in the 2020 General Election. Rather, what is present is a lengthy collection of phrases beginning with the words “could have, possibly, might,” and “may have.” (Doc. 1 ¶¶ 8, 53, 55, 57, 60, 66, 77, 88, 91, 108, 109, 122). To lend support to this theory, Plaintiffs offer expert Russell Ramsland, Jr., who asserts there was “an improbable, and possibly impossible spike in processed votes” in Maricopa and Pima Counties at 8:46 p.m.
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