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17 48 hours in advance. Then the votes are counted on election day. 51. By removing the ballots for examination prior to seven o’clock a.m. on election day, Secretary Boockvar created a system whereby local officials could review ballots without the proper announcements, observation, and security. This entire scheme, which was only followed in Democrat majority counties, was blatantly illegal in that it permitted the illegal removal of ballots from their locked containers prematurely. 52. Statewide election officials and local election officials in Philadelphia and Allegheny Counties, aware of the historical Democrat advantage in those counties, violated Pennsylvania’s election code and adopted the differential standards favoring voters in Philadelphia and Allegheny Counties with the intent to favor former Vice President Biden. See Verified Complaint (Doc. No. 1), Donald J. Trump for President, Inc. v. Boockvar, 4:20-cv-02078-MWB (M.D. Pa. Nov. 18, 2020) at 3-6, 9, 11, 100-143. 53. Absentee and mail-in ballots in Pennsylvania were thus evaluated under an illegal standard regarding signature verification. It is now impossible to determine which ballots were properly cast and which ballots were not. 54. The changed process allowing the curing of absentee and mail-in ballots in Allegheny and Philadelphia counties is a separate basis resulting in an unknown number of ballots being treated in an unconstitutional manner inconsistent with Pennsylvania statute. Id. 55. In addition, a great number of ballots were received after the statutory deadline and yet
18 were counted by virtue of the fact that Pennsylvania did not segregate all ballots received after 8:00 pm on November 3, 2020. Boockvar’s claim that only about 10,000 ballots were received after this deadline has no way of being proven since Pennsylvania broke its promise to the Court to segregate ballots and comingled perhaps tens, or even hundreds of thousands, of illegal late ballots. 56. On December 4, 2020, fifteen members of the Pennsylvania House of Representatives led by Rep. Francis X. Ryan issued a report to Congressman Scott Perry (the “Ryan Report,” App. 139a-144a) stating that “[t]he general election of 2020 in Pennsylvania was fraught with inconsistencies, documented irregularities and improprieties associated with mail-in balloting, pre-canvassing, and canvassing that the reliability of the mail-in votes in the Commonwealth of Pennsylvania is impossible to rely upon.” 57. The Ryan Report’s findings are startling, including: • Ballots with NO MAILED date. That total is 9,005. • Ballots Returned on or BEFORE the Mailed Date. That total is 58,221. • Ballots Returned one day after Mailed Date. That total is 51,200. Id. 143a. 58. These nonsensical numbers alone total 118,426 ballots and exceed Mr. Biden’s margin of 81,660 votes over President Trump. But these discrepancies pale in comparison to the discrepancies in Pennsylvania’s reported data concerning the
Page 1 and 2: No. ______, Original In the Supreme
Page 3 and 4: No. ______, Original In the Supreme
Page 5 and 6: legislatures to appoint Presidentia
Page 7 and 8: i TABLE OF CONTENTS Pages Bill of C
Page 9 and 10: 2 or no chain of custody 1 and, at
Page 11 and 12: 4 5. Each of Defendant States acted
Page 13 and 14: 6 8. Nor was this Court immune from
Page 15 and 16: 8 President and the Vice President
Page 17 and 18: 10 PARTIES 22. Plaintiff is the Sta
Page 19 and 20: 12 FACTS 34. The use of absentee an
Page 21 and 22: 14 protect the integrity of the bal
Page 23: 16 49. Pennsylvania’s election la
Page 27 and 28: 20 much larger volume of mail-in ba
Page 29 and 30: 22 express mandatory procedures set
Page 31 and 32: 24 78. The number of votes affected
Page 33 and 34: 26 signatures do not agree sufficie
Page 35 and 36: 28 95. The TCF was the only facilit
Page 37 and 38: 30 percent increase over 2016, were
Page 39 and 40: 32 Stat. 7.15(2m) provides, “[i]n
Page 41 and 42: 34 may be misled to exercise their
Page 43 and 44: 36 that USPS employees were backdat
Page 45 and 46: 38 vote principle in Defendant Stat
Page 47 and 48: 40 C. Enjoin Defendant States’ us
Page 49 and 50: i No. ______, Original In the Supre
Page 51 and 52: iii II. This case presents constitu
Page 53 and 54: v Dunn v. Blumstein, 405 U.S. 330 (
Page 55 and 56: vii Republican Party of Pa. v. Booc
Page 57 and 58: ix THE FEDERALIST NO. 57 (C. Rossit
Page 59 and 60: 2 is the glue that binds our citize
Page 61 and 62: 4 Constitutional Background The rig
Page 63 and 64: 6 are processed and tabulated witho
Page 65 and 66: 8 (emphasis added). This Court not
Page 67 and 68: 10 electors,” meaning that state
Page 69 and 70: 12 1. Plaintiff State suffers an in
Page 71 and 72: 14 In addition to standing for thei
Page 73 and 74: 16 accorded to each vote and the eq
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18 appointment of presidential elec
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20 We hold that this challenge to a
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22 is conferred upon the legislatur
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24 A. The 2020 election suffered fr
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26 J. CONST. L. 1, 31 (2010) (colle
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28 confusion and consequent incenti
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30 Court explained at length in Bus
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32 U.S. 527, 537-41 (1981), overrul
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34 III. REVIEW IS NOT DISCRETIONARY
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No. 20A , Original In the Supreme C
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expedition of this original action
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• On August 7, 2020, the League o
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of Pennsylvania is impossible to re
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2016 rejection rate was more than s
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without Defendant States’ elector
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Republic. With ordinary briefing, D
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prospective intervenors file or see
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CERTIFICATE OF SERVICE The undersig
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No. ______, Original In the Supreme
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ii 7. This action does not raise a
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iv Dunn v. Blumstein, 405 U.S. 330
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vi Roman Catholic Diocese of Brookl
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No. ______, Original In the Supreme
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3 voting. The Defendant States floo
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5 a manner as the legislature of su
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(1) a reasonable probability that f
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A. This Court has jurisdiction over
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11 Plaintiff State’s Electoral Cl
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13 judicial enforcement according t
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15 breaking vote in the Senate. Thr
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17 c. The requested relief would re
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19 reconsideration under lawful mea
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21 5. This action is not moot and w
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23 States become evident until days
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25 justification for a violation of
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27 “Legislature thereof.” U.S.
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29 For example, if a state court en
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31 This form of executive nullifica
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33 unconstitutional and unilateral
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35 election results that includes v
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