Whether the granting of the defense of sovereign or official immunity for employees or officials that are acting outside of the authority of their office, unlawfully, or in contravention to the Georgia or U.S. Constitutions is in violation of rights protected by the First, Ninth and Fourteenth Amendments of the U.S. Constitution and Article I, Section I, Paragraphs I, II, VII, IX and XXVIII of the GA Constitution?

QUESTIONS PRESENTED ; : The case before this Honorable Court concerns the misapplication of the grant of sovereign immunity for elections officials in Georgia that have failed to perform their legal and ministerial duties in regards to funding, equipping, implementing, conducting and administering State and Federal elections in compliance with the laws and Constitutions of Georgia and the United States (“US”). The improper granting of this ; doctrine has resulted in the Petitioners’ being deprived of their constitutionally protected right to redress their grievances, right to vote and right to privacy. This case also concerns the effective federalization of our elections in violation of Article 1, Sections 1, 4 and 8, the Ninth and Tenth Amendments, via an illegal fiat by then Secretary of Homeland Security, Jeh Johnson, in January 2017, in which he characterized elections as ‘critical infrastructure’. Additionally, in 2002, the Georgia Secretary of State (“SOS”), Cathy Cox, also perpetrated an illegal and unconstitutional fiat which moved the entire voting system in Georgia ; to an electronic system without the statutorily and constitutionally required referendum votes of the ; electors. : The questions presented are as follows: 1. Whether the granting of the defense of sovereign or official immunity for employees or officials that are acting outside of the authority of their office, unlawfully, or in contravention to the Georgia or U.S. Con{ stitutions is in violation of rights protected by the | First, Ninth and Fourteenth Amendments of the U.S. | Constitution and Article I, Section I, Paragraphs I, II, | VII, IX and XXVIII of the GA Constitution? t | | ii : 2. Whether an action is brought within a Federal . or State Court, does the protection of sovereign or official immunity apply when officers and/or employees ' of a State are participating in conduct that is ultra vires or in violation of Federal and State laws and : _ Constitutions? Based on this answer, if the State Courts are responsible for adjudicating conduct that is in violation of Federal laws and the rights protected é : by the U.S. Constitution, should the State Courts be applying the rules of Ex parte Young prior to granting . sovereign or official immunity to the errant officials? 3. Whether the Court erred in its failure to apply proper analysis, and by not giving proper considera: tion to the arguments of the Action, in their determination that the case at bar was against the State . versus an Action against the Defendants, as officers who were negligent in performing, or failing to perform, their ministerial duties or functions, acting out. side of the authority of their offices, unlawfully, and/or unconstitutionally? : 4. Whether the Court erred when it failed to consider the constitutional, textual language of Article I, Section II, Paragraph IX(d) itself, and within its appropriate historical context? : 5. Whether the Court’s question regarding the | ; position or character of the Defendants is relevant? j 6. Whether the Court erred when it failed to consider the ruling of Federal District Judge Amy Totenberg, Northern District Georgia, in which she . declared the ballots produced by the current Georgia voting system are unconstitutional and non-compliant with Georgia election law in October 2020? , iii 7. Whether the voting systems in Georgia were illegally and unconstitutionally implemented and installed pursuant to State and Federal laws and Constitutions? ; 8. Whether the Secretary of the Department of Homeland Security had the authority to effectively federalize our elections by designating them ‘Critical Infrastructure’? ; |