IN THE UNITED STATES DISTRICT COURT 

FOR THE NORTHERN DISTRICT OF TEXAS 

WICHITA FALLS DIVISION 

JACKI PICK, 

Plaintiff, 

 

vs. 

BRADLEY JAY RAFFENSPERGER, 

Defendant. 

CASE NO. ____________ 

JURY TRIAL DEMANDED

 

COMPLAINT 

Plaintiff Jacki Pick hereby sues Defendant Bradley Jay Raffensperger for 

defamation as follows. 

Introduction 

Brad Raffensperger defamed Jacki Pick by publishing statements that falsely 

accused Ms. Pick of presenting “deceptively sliced and edited” video footage and 

“lies” in testimony before the Georgia state legislature when, in fact, Ms. Pick’s 

presentation of the unedited, uncut, November 3, 2020, video at State Farm Arena 

revealed that Raffensberger had spent weeks lying about what had really happened 

at State Farm Arena on election night. 

Raffensperger further claimed that Ms. Pick lied about Fulton County’s use of 

“suitcases” to store ballots, when he was aware this was term was field jargon among 

election workers. The term had been used by the state’s own election monitor for 

Fulton Co. in a report to the Georgia State Board of Elections – on which 

Raffensperger sits ex-officio. Ms. Pick’s testimony was true and her evidence 

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unedited and authentic, as Raffensperger has known from the start. He made these 

statements in his book Integrity Counts and subsequent national promotional 

interviews, from which he profited. Raffensperger’s allegations about Ms. Pick were 

knowingly false, defamatory, made with actual malice, and have caused Ms. Pick 

severe damage for which she seeks to be made whole. 

Jurisdiction, Parties, and Venue 

1. Plaintiff Jacki Pick is a Texas citizen and resident. She served many 

years on Capitol Hill as legal counsel to the Chairman of the U.S. House 

Subcommittee on the Constitution and the former Ranking Member of the U.S. House 

Commercial and Administrative Law Subcommittee. In these capacities, she advised 

on the oversight of federal agencies. At the time of her testimony before the Georgia 

state legislature, she was a Senior Fellow at the Texas Public Policy Foundation. She 

hosts an educational podcast on multiple media platforms. She has devoted her 

professional and civic life to upholding and defending the U.S. Constitution. She 

loves her country and volunteered after election 2020 to defend its rule of law and its 

free and fair elections.

2. Defendant Bradley Jay Raffensperger is a citizen and resident of the 

state of Georgia. He is sued in his individual capacity as the author of Integrity 

Counts (“Book”). This Court has personal jurisdiction over Raffensperger because he 

sold the Book to Texans through online booksellers and physical stores located in 

Texas. Raffensperger promoted Book sales through national media outlets that 

broadcast to the Texas market. 

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3. This Court has subject matter jurisdiction pursuant to 28 U.S.C. § 1332, 

because there is complete diversity of citizenship between Jacki Pick and Brad 

Raffensperger and the amount in controversy exceeds $75,000.

4. Venue is proper in the Northern District of Texas pursuant to 28 U.S.C. 

§1391(b)(2) because a substantial part of the events or omission giving rise to the 

claim occurred in this District and because the brunt of the reputational harm was 

experienced by Ms. Pick in the Northern District, which is Ms. Pick’s home district. 

Satisfaction of Condition Precedent

5. Ms. Pick has provided notice to Raffensperger as required by Tex. Civ. 

Prac. & Rem. Code §73.055 and satisfied all conditions precedent to the filing of this 

lawsuit. At the time of filing, Raffensperger has neither published a retraction, 

refutation, or apology, nor taken steps to remove the Book from the market. 

Factual Background 

Election Night 2020 

6. Georgia Code § 21-2-522(1) (2020) states the result of an election may be 

contested on the grounds of “[m]isconduct, fraud, or irregularity by any ... election 

official or officials sufficient to change or place in doubt the result.” “Whenever the 

court trying a contest shall determine that the primary, election, or runoff is so 

defective as to the nomination, office, or eligibility in contest as to place in doubt the 

result of the entire primary, election, or runoff for such nomination, office, or 

eligibility,” the court “declare[s] the primary, election, or runoff to be invalid . . . and 

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shall call for a second primary, election, or runoff to be conducted among all of the 

same candidates . . . .” Georgia Code §21-2-527. 

7. Georgia Code §21-2-483(b) (2020) states that “[a]ll proceedings” at 

tabulation centers “shall be open to the view of the public.” Georgia law requires that 

returns “be open to public inspection at the office of the superintendent as soon as 

they are received from the chief managers.” Georgia Code § 21-2-491. Furthermore, 

Georgia Code § 21-2-492 (2020) required that the superintendent give “at least one 

week’s notice prior to the primary or election by publishing same in a conspicuous 

place in the superintendent's office, of the time and place when and where he or she 

will commence and hold his or her sessions for the computation and canvassing of the 

returns . . . .” 

8. In short, Georgia law both allows members of the public to be present 

when votes are being counted and requires election officials provide notice regarding 

when ballots will be counted. 

9. Witness affidavits and press reports provide the following facts about 

election night at State Farm Arena: a person who appeared to be an election 

supervisor announced to the room of election workers, press, and partisan observers 

at approximately 10:00 p.m. that counting at State Farm Arena would stop at 10:30 

p.m. and begin again the next morning at 8:30 a.m. A second official, the Fulton 

County Public Affairs Manager, confirmed this understanding with the press and at 

least one partisan observer. 

10. Multiple contemporaneous press accounts confirm this announcement. 

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ABC News (November 3, 2020, 10:34 p.m.) 

The Atlanta Journal-Constitution (November 3, 2020) 

(https://www.ajc.com/news/atlanta-news/fulton-election-results-delayed-after-pipebursts-in-room-with-b%20allots/4T3KPQV7PBEX3JVAIGJBNBSVJY/) 

11. Two election observers from the Republican Party of Georgia were 

present at State Farm Arena election night. Their accounts, found in affidavits signed 

under penalty of perjury, also averred that they heard the announcement that 

counting would cease at 10:30 p.m. and resume at 8:30 a.m. on November 4. True 

and correct copies of affidavits from election observers Mitchell Harrison and 

Michelle Branton are attached as Exhibits A and B. The individual who made the 

announcement to the observers appeared to be an election supervisor. 

Election Observer 1, Mitchell Harrison (Affidavit Attached as Exhibit A) 

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12. Georgia law does not give observers the right to remain in ballot 

counting facilities outside of times for “proceedings,” such as when ballots are being 

processed. Therefore, the partisan election observers and the press had no choice but 

to leave State Farm Arena shortly after officials said vote tabulation would cease at 

10:30 p.m. The affiant election observers were the last to leave the public observation 

area. Before they left, they made three separate requests for a standing vote count. 

Election officials refused to provide them with a count. 

13. The affiant observers later learned that, despite the multiple 

announcements that counting was done for the evening, counting had in fact resumed 

at State Farm Arena without notice and without any members of the public being 

present. When the observers learned about this, one of them, along with a second 

witness, returned to State Farm Arena around 1:45 a.m. Security personnel 

confirmed that a few individuals had remained after 10:30 p.m. and continued 

working up until just minutes before the observers returned. It was later learned that 

ballot counting had resumed around 11:03 p.m. and ended again around 1:00 a.m. 

Neither the observers nor candidate representatives were given notice that counting 

was to resume. 

Plaintiff’s Limited Involvement in the Election Contest 

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14. Ms. Pick lives and works in Dallas, Texas and is well known through 

her podcast, philanthropic activities, political involvement, and otherwise. Until the 

defamatory statements complained of herein, she enjoyed a well-earned reputation 

for being an honest and credible voice in her personal and professional communities. 

15. Ms. Pick has long had a personal interest in protecting citizens’ votes. 

She has worked on and volunteered in elections as far back as 1994. During her 

tenure as counsel in the House of Representatives, her issue portfolio for the 

Chairman of the U.S. House Subcommittee on the Constitution included voting rights 

and election law, issues to which she has devoted literally hundreds of hours of work 

and study. 

16. Shortly after the 2020 election, Ms. Pick volunteered to assist with 

election related matters in the state of Georgia. 

17. In her capacity as a volunteer, Ms. Pick helped organize and summarize 

investigative facts and affidavits from approximately 100 witnesses who believed 

they had viewed irregularities, misconduct, and potential fraud in the administration 

of the November 3, 2020, election. At least two of those affidavits concerned perceived 

irregularities in ballot processing at State Farm Arena on November 3 and November 

4, 2020. 

18. On information and belief, on the afternoon of December 2, 2020, 

Atlanta attorney Ray Smith (the attorney litigating the election contest), obtained 

raw, uncut, unedited video footage of the vote processing and tabulation at State 

Farm Arena on November 3 and November 4, 2020, (“State Farm Video”) which had, 

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upon information and belief, become available to him for the first time. The video file 

spanned greater than twenty hours, and took, upon information and belief, numerous 

hours to download. The video did not become available to view until around 1:00 a.m. 

Upon information and belief, neither the Trump campaign nor the Georgia 

Republican party had viewed the State Farm Video prior to December 3. 

19. The more than twenty hours of State Farm Video footage appeared to 

verify the affiant election observers’ claims. While the video did not include sound, it 

showed what appeared to be an election official make an announcement to observers 

around 10:00 p.m.; press, observers, and most workers leaving around 10:30 p.m.; 

four to six officials or workers (including the person who made the announcement to 

the observers) staying behind after the observers and workers had already left; and 

those remaining persons beginning to tabulate ballots again around 11:03 p.m. The 

video appeared to show workers tabulating ballots from approximately 11:03 p.m. 

until around 1:00 a.m. No members of the public such as observers or press were 

present during this timeframe even though Georgia law gives the public the right to 

be present. The absence of press is notable because Georgia—a swing state whose 

votes had not yet fully been reported—was the focus of intense media interest at 

precisely this time. At approximately 11:52 p.m., an election monitor (whose presence 

was mandated because of prior incompetence and malfeasance in Fulton County) 

arrived. When the monitor arrived on scene, the video appears to show him agitated. 

He began taking photos of the scanner area, and then placed a phone call. Minutes 

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later at 12:15 a.m., the Deputy Chief Investigative Officer for the Secretary of State’s 

office arrived at the facility and had a conversation with the monitor. 

20. Only twelve hours after the law firm first viewed the video, the Georgia 

State Senate Election Law Subcommittee held a hearing to learn about alleged 

election irregularities, misconduct, or potential fraud in the 2020 election.1 Despite 

not having had enough time to view the entirety of the video footage, which spanned 

more than twenty-hours, Ms. Pick and others believed the video corroborated the 

press and affiants’ claims of irregularities potentially indicating a violation of Georgia 

law. Two hours before the hearing, Ms. Pick was asked if she would narrate the video 

at the hearing to explain how various points in the raw footage corroborated witness 

affidavits that the firm attached as exhibits to their lawsuit. 

21. While Ms. Pick is an attorney, she stressed at the beginning of her 

testimony that she was appearing as a volunteer and not as a lawyer. Ms. Pick was 

not retained as counsel for the Trump legal team. Rather, she was a volunteer helping 

a team led by Atlanta attorney Ray Smith with fact gathering. 

22. As part of Ms. Pick’s presentation—which lasted approximately a half 

hour—she fast forwarded or rewound the video to point out relevant time frames 

identified in the witness affidavits. It would have been physically impracticable and 

a waste of the Committee’s time to have played the entire twenty-hour plus video, 

most of which was irrelevant. 

1 A video of the December 3, 2020, hearing is publicly available at 

https://www.youtube.com/watch?v=hRCXUNOwOjw. 

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23. The video was raw, uncut, and unedited. No part of the video was deleted 

or removed. The full video was in the hearing room and available to the Committee 

to review or request to review. Ms. Pick did not play excerpts or snippets of a video 

that were spliced together, but instead was fast-forwarding and rewinding on a 

single, hours-long, video file. On the hearing video, she can be heard instructing the 

audio-visual technician multiple times to “fast-forward” or “back up” to various times 

on the video, as is obvious from either the video or the transcript of her presentation. 

The full video became public after the hearing. Raffensperger later made public 

statements that his office had seen the video before the hearing, so he knew Ms. Pick’s 

presentation of the video was raw and unedited. 

24. Ms. Pick’s testimony referred the Committee to various points of the 

video that proved out the contents of the election observers’ affidavits. 

25. Ms. Pick also used vernacular during her presentation that was used by 

Fulton County elections staff and monitors. This included the term “suitcases” to 

describe the containers in which State Farm Arena election officials stored the Fulton 

County ballots. The November 2020 affidavit of veteran Fulton County election 

worker Bridget Thorne stated that the ballots were “gathered in suitcases.” See 

Exhibit C, ¶ 23. 

26. Ms. Pick reviewed Ms. Thorne’s affidavit many times in the days prior 

to her testimony. Thorne’s affidavit is where Ms. Pick learned that the local staff 

referred to the containers in question as “suitcases.” Thorne’s affidavit was served to 

Raffensperger himself who was the defendant in the case for which the affidavit was 

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created. Upon information and belief, the gray containers in the photograph below 

hold poll pads while the black containers—or “suitcases” as the election workers 

referred to them—held ballots on election night. As the state’s own election monitor 

explained in his report to the State Board of Elections, State Farm Arena had “too 

many ballots coming in for secure black ballot boxes,” so they resorted to bringing 

ballots in “rolling bins” creating potentially a “massive chain of custody problem. It 

is my understanding that the ballots are supposed to be moved in numbered, sealed 

boxes to protect them.” 

27. Ms. Pick explained to the panel that, as the firm had only had the ability 

to view the video at 1:00 a.m. and the hearing was a mere twelve hours later, there 

had been no opportunity in those twelve hours to speak to Fulton County officials or 

others about the contents of the video. 

28. When Ms. Pick did not have the answer to a question, she let the panel 

know and properly qualified her testimony multiple times where appropriate. She 

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further testified that there were unanswered questions that the firm would be able 

to answer with more time to review the full video footage. The firm literally had not 

had possession of the video long enough to have watched it all the way through. 

29. Ms. Pick never stated that the video proved specific intent to commit 

voter fraud. She did not name election workers or allege that any particular 

individual committed a crime. As referenced in the statute above, no proof of fraud 

was necessary for the election contest and certainly not for her testimony which 

aimed to raise questions and inform the public about a matter of great public concern. 

Her testimony focused solely on questions and potential irregularities that anyone 

could observe from the video and match to the claims made in witness affidavits. Her 

observations were truthful and accurate based on the knowledge she had at the time 

of her testimony. 

30. During the presentation, Ms. Pick offered to show members of the 

Committee more of the video. Someone within the hearing room—believed to be the 

hearing chairman—is heard questioning whether members of the panel would like to 

see more of the video and then declining Ms. Pick’s offer. At multiple points Ms. Pick 

also invited and answered questions from Committee members. 

31. Ms. Pick was the only witness to present the video before the Committee. 

32. Ms. Pick’s statements were factually correct and corroborated by 

multiple press accounts from Nov. 3-4, 2020, multiple witness affidavits, the report 

of the state’s own election monitor for Fulton County, and the video which speaks for 

itself. 

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Raffensperger Defames Ms. Pick 

33. In the days and months after the December 3 hearing, Raffensperger, 

his staff, and surrogates began a campaign to malign Ms. Pick. Raffensperger claimed 

Ms. Pick presented “deceptively sliced and edited” video or “doctored” the video and 

presented false testimony. Raffensperger wrote a book entitled “Integrity Counts,” 

distributed by Simon & Schuster in Texas and elsewhere. On the Simon & Schuster 

website page advertising the Book, there is a link to various booksellers where Texas 

residents can purchase the Book, including via Amazon and several brick-and-mortar 

stores within Texas. Raffensperger sold multiple copies of the Book in Texas. 

34. In the Book, Raffensperger refers to the video presented to the 

Committee as a “SLICED-AND-DICED VIDEO.” Raffensperger states that the State 

Farm Arena video—presented to the Committee by Ms. Pick alone—“had been 

deceptively sliced and edited so that it appeared to show the exact opposite 

of reality.” Book, p. 138 (emphasis added). That is, he called Ms. Pick a liar and 

accused her of actions constituting a crime under Georgia law. 

35. Raffensperger further claimed that Ms. Pick’s presentation “showed a 

slice of video that had removed the clear evidence that Fulton County election 

workers had protected the ballots and the process as required by law.” Raffensperger 

later again referred to the video as a “chopped-up video.” Book, p. 139 (emphasis 

added). 

36. In later public statements, Raffensperger described the video shown by 

Ms. Pick as “doctored” and “false.” 

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37. Raffensperger’s statements are false and were intended to discredit and 

defame Ms. Pick. While Raffensperger attributes many of his comments regarding 

the State Farm Video to the president’s personal lawyer, Rudy Guiliani, Ms. Pick was 

the only witness to present the video to the panel. Rudy Giuliani did not. (Ms. Pick 

was not affiliated with or working for Rudy Guiliani, and they did not communicate 

or coordinate their respective December 3, 2020, testimonies). Upon information and 

belief, Giuliani was President Trump’s personal counsel and not part of the firm with 

which Ms. Pick had been volunteering or part of the legal team litigating the Georgia 

election contest. Raffensperger’s disparaging comments about the “deceptive,” 

“chopped-up,” “doctored” video presentation which “removed...clear evidence” “so 

that it appeared to show the opposite of reality” could only be referring to Ms. Pick. 

38. The Book further made statements that Raffensperger’s office and his 

surrogates had to “punch down lies” to correct Ms. Pick’s description of “official boxes” 

containing ballots as “suitcases” or “secret suitcases.” Book pg. 138, 144, 146. It 

further suggested that someone who would use such a term lives “in a world outside 

of reason and reality.” These characterizations were false and defamatory, as 

Raffensperger was aware the term “suitcases” was used by Fulton County election 

workers and his own election monitors. 

39. The defamatory statements are “of and concerning” the Plaintiff. Ms. 

Pick was the only person who presented the State Farm Arena video, despite 

Raffensperger’s repeated knowingly false statements that it was Rudy Giuliani. The 

publicly available hearing video and transcript clearly show Ms. Pick was the only 

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one presenting the video. Raffensperger had knowledge of the truth or showed 

reckless disregard for the truth regarding his characterizations of the State Farm 

Arena video at the December 3, 2020, hearing. Further, after hearing Raffensperger’s 

claims that the December 3, 2020, video was an attempt to lie to the legislature, 

persons acquainted with Ms. Pick independently informed her they believed 

Raffensperger’s statements defamed Ms. Pick. Finally, Ms. Pick’s image was seen in 

videos and photos of her December 3, 2020, testimony that went viral with millions 

(perhaps tens of millions) of views worldwide, on national network television 

broadcasts, and in newspapers and online news outlets. 

40. The video Ms. Pick showed on December 3 was raw, uncut footage. It 

was not edited at all, let alone “deceptively edited,” ‘doctored,” or “sliced and diced.” 

Ms. Pick truthfully and honestly explained to the Committee that she and the firm 

had literally not had sufficient time to review all the video. She also offered 

Committee members the opportunity to view more of the footage during her 

testimony, and they declined her offer. Further, the Committee upon information and 

belief, had access to the video in its entirety after the presentation. 

41. The law firm took the entire, unedited video to the State Capitol for the 

presentation to the Georgia Legislature. The film shown and the manner of its 

presentation was and is a matter of public record. Ms. Pick’s testimony to the Georgia 

Legislature was a matter of public record. As of October 2022, the Georgia Legislature 

has a link to Ms. Pick’s video presentation available on its website. Upon information 

and belief, Raffensperger viewed the video of the hearing, and therefore had actual 

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knowledge his statements about the video were false. In the alternative, it shows a 

reckless disregard for the truth for him to claim the presenter of the video was lying 

to the legislature without actually having viewed the testimony described. 

42. Raffensperger’s defamatory statements were calculated to, and did, 

harm Ms. Pick’s reputation, lowered her in the estimation of the community, and will 

deter third persons from associating or dealing with her. 

43. Raffensperger has thus far refused to retract or correct the defamatory 

statements, despite knowing of their falsity. 

44. Raffensperger wrote the Book in his personal capacity, to aid in his 

reelection efforts and, upon information and belief, has personally profited from the 

Book’s sales. 

Damages 

45. Raffensperger’s defamatory statements caused Ms. Pick actual 

damages. 

46. As a result of Raffensperger’s defamatory statements, Ms. Pick has 

suffered reputational damages in her personal and private life. She is a licensed but 

non-practicing attorney and podcaster, and her professional success depends on a 

reputation for truthfulness and honesty. 

47. Before Raffensperger’s defamatory statements, Ms. Pick enjoyed a good 

reputation in her community and had even been approached for high-level 

governmental and other influential positions. Because of Raffensperger’s defamatory 

statements, her reputation for truthfulness and honesty has been irreparably 

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damaged, and she likely is no longer a viable candidate for political or professional 

appointments. 

48. Raffensperger’s defamatory claims regarding Ms. Pick have also 

repeatedly been parroted in the news media at the highest level concerning one of the 

biggest media events in American history. Google searches of her name return pages 

of results repeating the Book’s defamatory allegations. Regardless of if Raffensperger 

acts to retract, repudiate, or correct his defamatory statements, there is no way to 

correct every repetition of his false claims. Further, he cannot undo the life sentence 

of reputational damage sustained from false statements made on live television 

broadcasts and other media appearances. 

49. Raffensperger’s defamatory claims have been so destructive that Ms. 

Pick is now being investigated by the Fulton County District Attorney’s office for 

knowledge of various alleged crimes in connection with the November 3, 2020, 

election, including, on information and belief, having made false statements to the 

legislature. On information and belief, the District Attorney’s allegations are based 

upon or closely mirror the false and defamatory claims made in Raffensperger’s Book. 

Raffensperger knows this because it has been widely reported. Also, the Atlanta 

Journal Constitution reported in their coverage of the Fulton County Special Purpose 

Grand Jury that Raffensperger said the video was “doctored.” Despite the knowingly 

false statements being widely attributed to him in the press, upon information and 

belief, he has made no efforts to correct them, instead letting an innocent be 

threatened with prosecution for his lies. 

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50. An attempt to subpoena Ms. Pick to testify in Georgia, and Ms. Pick’s 

successful legal action at the Texas Court of Criminal Appeals to protect against that 

unwarranted legal process, resulted in additional negative press coverage and harm 

to Ms. Pick’s reputation. Upon information and belief, the allegations underlying the 

Fulton County subpoena can be traced to Raffensperger’s false accusations. Upon 

information and belief, the only evidence of any alleged wrongdoing by Ms. Pick is 

the manufactured claim originated by Brad Raffensperger. 

51. If Raffensperger repeated his Book’s false accusations to the District 

Attorney, it demonstrates a pattern of acting in ways that are deceptive or not 

forthcoming with government officials on the public record. 

52. Raffensperger was chastised by federal Judge Amy Totenberg for giving 

“far fetched,” and “flatly not credible” evidence to a federal court that “contradict[ed] 

the fulsome expert opinion and evidence.” Curling v. Raffensperger, Case 1:17-cv02989-AT, Document 579, p. 70. 

https://www.courtlistener.com/docket/6139924/curling-v-raffensperger/ 

53. Similarly, Raffensperger appears to have lied to the Georgia legislature 

on at least three occasions about the contents of the State Farm Video specifically, 

and Ms. Pick’s presentation is what proved it. 

54. In the Dec. 3, 2020, hearing before the Georgia Senate Subcommittee, 

Senator Elena Parent states on the record that the Secretary of State’s office told the 

Subcommittee only an hour before Ms. Pick’s testimony that the Secretary of State 

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had a state monitor present on election night at State Farm Arena the “whole time” 

or “entire time.” The video proved this false. 

55. A week later at a Georgia House hearing, State Rep. Scot Turner stated 

that Raffensperger sent two writings to the legislature that falsely claimed—in bold 

face print no less—that an election monitor was present at State Farm Arena while 

all counting took place. Rep. Turner held up a November 12, 2020, hard copy letter 

repeating the false claim signed by Raffensperger, and also referenced a November 

19, 2020, email from Raffensperger making a substantially similar claim. According 

to the hearing transcript and video of this December 10, 2020, hearing, the 

Representative believed Raffensperger’s prior representations until he saw the video 

presented by Ms. Pick which proved that the state monitor was not present when 

counting resumed at State Farm Arena on election night. Rep. Turner investigated 

further and found that the state monitor admitted this in a FactCheck.org article 

dated Dec. 4, 2020. This video testimony by Rep. Turner is linked in the Georgia 

Legislature website and is found at 6:17:30 on 

https://www.youtube.com/watch?app=desktop&v=9EfgETUKfsI&feature=youtu.be

In the words of Rep. Turner, “The changing nature of the information that we have 

been getting as legislators from the Secretary of State’s office has been most 

disappointing...The video comes out...debunking the claims in the video from 

[Raffensberger’s] Senate testimony,...They changed the story without even 

acknowledging they changed the story. That damages credibility. We have to be 

better than that...this is the best part. The Deputy Secretary of State told 

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FactCheck.org that the monitor was not required to be there at all times, but she 

instructed him to return, after hearing from the new outlets that the county was going 

to cease counting for the night. This means that the Secretary of State’s office knew 

the entire time that there was not an observer in the room when ballot scanning was 

happening and they sent two memos to us saying that there was. The story doesn’t 

add up. Somebody isn’t telling the truth.” That “somebody” not telling the truth was 

Raffensperger. 

56. Later, the Chief Operating Officer of the Georgia Secretary of State’s 

office, Gabriel Sterling, also contradicted the Secretary of State when he admitted 

publicly that the State Monitor had not been present for a considerable period of time 

while counting was taking place. But for Ms. Pick’s testimony, it is entirely possible 

that Raffensperger’s lies to the legislature and others would never have been found 

out. 

57. Ms. Pick has suffered embarrassment, stress, humiliation, and mental 

anguish because of Raffensperger’s defamatory statements. This mental anguish has 

resulted in sleeplessness, anxiety, and has significantly affected Ms. Pick’s enjoyment 

of life. Ms. Pick has sought counseling. The time since Raffensperger published his 

Book has been the most emotionally challenging of Ms. Pick’s life. 

58. Ms. Pick has also suffered physical injury and pain because of 

Raffensperger’s defamatory campaign. The stress caused by Raffensperger’s 

defamation exacerbated her pre-existing medical conditions including her heart 

arrythmia—for which she has already undergone two heart procedures—and a 

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condition that causes damage to her voice and her ability to speak. She lost ten 

pounds due to stress, chronic mental and physical fatigue, and exhaustion. 

59. Ms. Pick has lost months of her life addressing legal issues precipitated 

by Raffensperger’s defamation campaign and has accrued enormous sums in legal 

fees defending against subpoenas that have, upon information and belief, been 

precipitated and perpetuated by Raffensperger’s false claims. Ms. Pick has expended 

and will continue to expend an enormous amount of time and money repairing her 

reputation, including working with reputation management professionals, attorneys 

to request retractions, and whatever else is needed to restore her good name. 

However, she knows that, no matter how much time and money she spends, she 

cannot unring the bell on the defamatory accusations that Raffensperger thrust into 

the national public debate. 

Count 1—Defamation 

60. Ms. Pick incorporates the preceding paragraphs as if set forth herein 

verbatim. 

61. Raffensperger published false statements in his November 2, 2021, Book 

claiming Ms. Pick presented deceptively edited video to the Georgia legislature. In 

fact, Ms. Pick played raw, uncut, unaltered video, the file of which spanned more than 

twenty hours in full. Ms. Pick did not edit the video at all. 

62. Raffensperger also falsely accused Ms. Pick of lying that the Fulton 

County election officials stored ballots in “suitcases,” when that was the exact 

terminology for ballot transfer bags used by Raffensperger’s own state election 

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monitor in his November 13, 2020, report to the Georgia State Board of Elections. It 

was also the term poll worker Bridget Thorne used to refer to the ballot transport 

bags in her November 2020 affidavit made in connection with a lawsuit against 

Raffensperger. Ms. Pick’s testimony December 3, 2020, testimony came after both of 

these affiants statements were already matters of public record. 

63. Raffensperger’s statements were of and concerning Ms. Pick as Ms. Pick 

was the only individual to show the video at the December 3, 2020, hearing. Claims 

that someone presented a deceptively edited video from State Farm Arena could refer 

to no one other than Ms. Pick. 

64. Raffensperger made his statements with actual malice, full knowledge 

that his statements were false or with reckless disregard for the truth or falsity of his 

statements. Raffensperger has repeatedly and publicly claimed that he or his agents 

watched the State Farm Video and the December 3, 2020, testimony before the 

Committee. He knew his statements suggesting the State Farm Video was 

deceptively edited were false when he made them. By virtue of the affidavit signed 

by a veteran poll worker and served on him in December 2020 in the Trump v. 

Raffensperger election contest, he also was aware that the term “suitcase” was a term 

utilized by Fulton County election administrators and the State’s own election 

monitor to describe where Fulton County stored their ballots. 

65. Ms. Pick pleads actual malice as to all of the defamatory statements 

identified above—both those in the Book and after the Book’s publication. 

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Raffensperger’s statements were substantially false and gave a defamatory 

impression by omitting material facts or juxtaposing facts in a misleading way. 

66. Any reasonable person reading the cited statements would construe 

them to be defamatory. 

67. The “gist” of Raffensperger’s statements is that Ms. Pick presented a 

“deceptively sliced and edited” video “so that it appeared to show the exact opposite 

of reality” to mislead the Georgia legislature. Among his many defamatory 

statements, he more specifically alleges that the deception included “showing a slice 

of video that had removed the clear evidence that Fulton County election workers had 

protected the ballot and the process as required by law.” He also publishes and 

republishes statements that she lied about ballots being stored in “suitcases.” All of 

these statements were made with knowledge of the statements’ falsity or reckless 

disregard for the truth or falsity of the statements. 

68. Raffensperger’s claims that Ms. Pick’s video presentation was deceptive 

and false could not have a non-defamatory meaning. Neither could Raffensperger’s 

claims that Ms. Pick lied by calling the ballot containers “suitcases” be anything but 

defamatory. 

69. Raffenspberger’s defamatory statements were defamatory per se 

because they reflect on Ms. Pick’s fitness to conduct her business and trade and 

therefore injured her in her office, profession, and occupation. As discussed above, 

Ms. Pick produces an educational podcast focused and is, in effect, an opinion 

journalist. Accusing a journalist of presenting a “deceptively” “sliced-and-diced” or 

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“chopped-up” video in a deliberate attempt to mislead a government body to attempt 

to undermine an election goes to the heart of journalistic integrity and is harmful to 

her in her profession and community. In addition, Ms. Pick is a licensed, nonpracticing attorney. 

70. Raffensperger’s statements were also defamatory per se because they 

accused Ms. Pick of committing a crime—false statement to the legislature—for 

which she is now being investigated, upon information and belief, because of 

Raffensperger’s repeated defamatory falsehoods. 

71. Ms. Pick has suffered damage as a result including, but not limited to, 

in her personal and professional community, in the press, on social media, and in the 

courts. 

PRAYER FOR RELIEF

Plaintiff respectfully prays for judgment as follows: 

A. For judgment in her favor against Bradley Jay Raffensperger; 

B. For general, specific, and compensatory damages in excess of $75,000; 

C. For punitive and exemplary damages; 

D. For pre and post judgment interest; 

E. For taxable court costs; 

F. For an apology and retraction; and 

G. All other relief deemed appropriate. 

Respectfully submitted, 

DHILLON LAW GROUP, INC. 

Case 7:22-cv-00112-O Document 1 Filed 10/31/22 Page 24 of 25 PageID 24
Date: October 31, 2022 /s/ Matthew Sarelson 

Matthew Seth Sarelson, Esq. 

msarelson@dhillonlaw.com

Karin M. Sweigart, Esq. (pro hac vice forthcoming) 

ksweigart@dhillonlaw.com

Christopher Halbohn, Esq. 

chalbohn@dhillonlaw.com

Dhillon Law Group Inc. 

1601 Forum Place, Suite 403 

West Palm Beach, FL 33401 

T 305.773.1952 

Counsel for Plaintiff

William G. Whitehill 

SBOT # 21356550 

bwhitehill@condontobin.com

Condon Tobin Sladek Thornton Nerenberg, PLLC 

8080 Park Lane, Suite 700 

Dallas, Texas 75231 

T 214.265.3862 | F 214.691.6311 

Local Counsel for Plaintiff 

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