DOJ Donoghue FOIA Docs

A Simple Test for the extent of Vote Fraud with Absentee Ballots in the 2020 Presidential
Election: Georgia and Pennsylvania Data
John R. Lott, Jr., Ph.D.*
Revised
December 21, 2020
Summary
This study provides measures of vote fraud in the 2020 presidential election. It first compares
Fulton county’s precincts that are adjacent to similar precincts in neighboring counties that had
no allegations of fraud to isolate the impact of Fulton county’s vote-counting process (including
potential fraud). In measuring the difference in President Trump’s vote share of the absentee
ballots for these adjacent precincts, we account for the difference in his vote share of the in-
person voting and the difference in registered voters’ demographics. The best estimate shows
an unusual 7.81% drop in Trump’s percentage of the absentee ballots for Fulton County alone
of 11,350 votes, or over 80% of Biden’s vote lead in Georgia. The same approach is applied to
Allegheny County in Pennsylvania for both absentee and provisional ballots. The estimated
number of fraudulent votes from those two sources is about 55,270 votes.
Second, vote fraud can increase voter turnout rate. Increased fraud can take many forms:
higher rates of filling out absentee ballots for people who hadn’t voted, dead people voting,
ineligible people voting, or even payments to legally registered people for their votes. However,
the increase might not be as large as the fraud if votes for opposing candidates are either lost,
destroyed, or replaced with ballots filled out for the other candidate. The estimates here
indicate that there were 70,000 to 79,000 “excess” votes in Georgia and Pennsylvania. Adding
Arizona, Michigan, Nevada, and Wisconsin, the total increases to up to 289,000 excess votes.
*
This research purely reflects my own personal views. This research does not represent work done by or for the US
Department of Justice, and it has not been approved of by the DOJ.
Electronic copy available at: https://ssrn.com/abstract=3756988

Introduction
Courts have frequently rejected Republican challenges to the 2020 presidential vote because
they want evidence that a case involves enough fraud to alter the vote’s outcome in a particular
state. Republicans argue that since their observers couldn’t watch the vote count, they can’t
provide that evidence and have asked for discovery. Still, while the courts have agreed that
irregularities have occurred, they weren’t willing to grant discovery unless Republicans first
present enough evidence of fraud to overturn the election. Republicans thus faced a kind of
Catch 22.
This paper’s approach allows us to quantify how large a potential problem vote fraud and other
abnormalities might be in the 2020 election. The process is applicable to other states where
precinct-level data is available on voting by absentee and in-person voting.
Concerns over fraud with absentee ballots is not something limited to Republicans in the United
States. Indeed, many European countries have voting rules stricter to prevent fraud than what
we have in the United States.1 For example, 74% entirely ban absentee voting for citizens who
live in their country. Another 6% allow it, but have very restrictive rules, such as limiting it to
those in the military or are in a hospital, and they require evidence that those conditions are
met. Another 15% allow absentee ballots but require that one has to present a photo voter ID
to acquire it. Thirty-five percent of European countries completely ban absentee ballots for
even those living outside their country. The pattern is similar for developed countries.
Many of these countries have learned the hard way about what happens when mail-in ballots
aren’t secured. They have also discovered how hard it is to detect vote buying when both those
buying and selling the votes have an incentive to hide the exchange.
France banned mail-in voting in 1975 because of massive fraud in Corsica, where postal ballots
were stolen or bought and voters cast multiple votes. Mail-in ballots were used to cast the
votes of dead people.2
The United Kingdom, which allows postal voting, has had some notable mail-in ballot fraud
cases. Prior to recent photo ID requirements, six Labour Party councilors in Birmingham won
office after what the judge described as a “massive, systematic and organised" postal voting
1
John R. Lott, Jr., “Why do most countries ban mail-in ballots?: They have seen massive vote fraud problems,”
Crime Prevention Research Center, revised October 15, 2020
(https://papers.ssrn.com/sol3/papers.cfm?abstract_id=3666259).
2
Staff, “In Corsica, the tormented history of the vote by correspondence,” World Today News, June 15, 2020
(https://www.world-today-news.com/in-corsica-the-tormented-history-of-the-vote-by-correspondence/). Jean-
Louis Briquet, “EXPATRIATE CORSICANS AND THE VOTE AU VILLAGE: MECHANISMS OF CONTROL AND
EXPRESSIONS OF SENTIMENT (NINETEENTH–TWENTIETH CENTURIES),” Revue française de science politique
(English Edition) Vol. 66, No. 5 (2016), pp. 43-63; Staff, “Corsicans of France Are Feeling the Sting of Publicity Given
to Criminals,” New York Times, January 7, 1973 (https://www.nytimes.com/1973/01/07/archives/corsicans-of-
france-are-feeling-the-sting-of-publicity-given-to.html).

fraud campaign.3 The fraud was apparently carried out with the full knowledge and cooperation
of the local Labour party. There was "widespread theft" of postal votes (possibly around 40,000
ballots) in areas with large Muslim populations because Labour members were worried that the
Iraq war would spur these voters to oppose the incumbent government.
In 1991, Mexico’s 1991 election mandated voter photo-IDs and banned absentee ballots. The
then-governing Institutional Revolutionary Party (PRI) had long used fraud and intimidation
with mail-in ballots to win elections.4 Only in 2006 were absentee ballots again allowed, and
then only for those living abroad who requested them at least six months in advance.5
Some European countries allow proxy voting, but that is very strictly regulated to minimize
fraud. For example, proxy voting requires the verification of photo IDs and signed request
forms. In Poland, a power of attorney is necessary to have a proxy vote and then can only be
granted by the municipal mayor. In France, you must go in person to the municipality office
prior to the elections, provide proof of who you are, provide proof of reason for absence (for
example, letter from your employer or medical certificate), and then nominate a proxy. Proxy
voting is not only very limited, but it prevents the problem that absentee ballots are unsecured.
Proxy voting requires that the proxy vote in-person in a voting booth.
Unsecured absentee ballots create the potential that either fraudulent ballots will be
introduced or votes to be destroyed. Some safe guards can at least minimize these problems,
such as requiring matching signatures, but even this is not the same as requiring government
issued photo voter IDs. Nor does it prevent votes from being destroyed. In addition, one of the
controversies in this election was that states such as Georgia, Nevada, Pennsylvania, and
Wisconsin did not match signatures on the outer envelopes match the voters’ registration
records.6 Other states, particularly Pennsylvania, were accused of accepting absentee ballots
that didn’t even have the outer envelope where the voter’s signature would be or were missing
postmarks.7
3
Nick Britten and George Jones, “Judge lambasts postal ballot rules as Labour 6 convicted of poll fraud,” The
Telegraph (UK), April 2005 (https://www.telegraph.co.uk/news/uknews/1487144/Judge-lambasts-postal-ballot-
rules-as-Labour-6-convicted-of-poll-fraud.html).
4
John R. Lott, Jr., “Evidence of Voter Fraud and the Impact that Regulations to Reduce Fraud Have on Voter
Participation Rates,” SSRN, August 18, 2006 (https://papers.ssrn.com/sol3/papers.cfm?abstract_id=925611).
For example, as a result of fraud in their 1988 Presidential election, absentee ballots were not allowed in Mexico
until 2006 (see Associated Press, “Mexican Senate approves mail-in absentee ballots for Mexicans living abroad,”
AZcentral.com, April 28, 2005 (http://www.azcentral.com/specials/special03/articles/0428mexicovote-ON.html).
5
James C. McKinley, Jr., “Lawmakers in Mexico Approve Absentee Voting for Migrants,” New York Times, June 29,
2005 (https://www.nytimes.com/2005/06/29/world/americas/lawmakers-in-mexico-approve-absentee-voting-for-
migrants.html).
6
Peter Navarro, “The Immaculate Deception: Six Key Dimensions of Election Irregulaties,” December 15, 2020.
7
Ibid.

Vote fraud concerns are important in that they will not only alter election results, but they can
also discourage voter participation.8
The following sections provide precinct level estimates for Georgia and Pennsylvania and then
look at all the swing states by county to see if counties with fraud had higher turnout rates.
II. Georgia
In Georgia’s certified ballot count, former Vice President Joe Biden leads President Trump by
12,670 votes.9 Biden won Fulton County by a margin of 243,904 votes, and the absentee ballots
in the county by 86,309 votes.10
Part of the controversy with Fulton County’s absentee ballots arises from a burst pipe that
resulted in the removal of poll watchers. According to the Chair of the Georgia Republican
Party, David J. Shafer, “counting of ballots took place in secret after Republican Party observers
were dismissed because they were advised that the tabulation center was shutting down for
the night” (Letter dated November 10, 2020 from Doug Collins and David Shafer to Georgia
Secretary of State Brad Raffensperger, p. 3).
If election workers counted absentee ballots when Republican observers were not present, is
there statistical evidence of bias in the absentee ballot counting? While in-person voting took
place at the precinct level, absentee vote counting took place at one common facility at the
county level. If the type of fraud that Mr. Shafer worries about occurred, it would have only
affected the absentee ballots in Fulton County.
To examine that, I looked at precinct-level data for Fulton County and the four Republican
counties that border it and no fraud has been alleged: Carroll, Cherokee, Coweta, and Forsyth.11
The idea is a simple one: compare Trump’s share of absentee ballots in precincts adjacent to
each other on opposite sides of a county border. The comparison is made between precincts in
Fulton and these four other counties as well as between precincts in these four counties where
they are adjacent each other. Comparing a county were fraud is alleged to ones without alleged
fraud is simpler than comparing counties where there might be hard-to-specify varying degrees
of fraud.
8
John R. Lott, Jr., “Evidence of Voter Fraud and the Impact that Regulations to Reduce Fraud Have on Voter
Participation Rates,” Social Science Research Network, 2006
(https://papers.ssrn.com/sol3/papers.cfm?abstract_id=925611).
9
“US election 2020: Biden certified Georgia winner after hand recount,” BBC, November 20, 2020
(https://www.bbc.com/news/election-us-2020-55006188).
10
This was quite different from previous elections. For example, in 2012, while Obama received 64% of the total
vote in Fulton County, he barely received a majority of the absentee vote, taking 50.89% (data from Clark Bensen
at Polidata).
11
Corrected data was not available for Fayette County, but including this data resulted in no change in the level of
statistical significance for either Tables 1 or 2.

Precincts adjacent to each other on opposite sides of a county border should be relatively
similar demographically. In one case, Fulton County precinct ML02A matches up with four
different precincts in Cherokee County (Mountain Road 28, Avery 3, Union Hill 38 and a small
portion of Freehome 18).12 The goal is to compare the precincts of Fulton county that are most
similar to precincts nearby counties that had no allegations of fraud, in order to isolate the
impact of Fulton county’s vote-counting process (including potential fraud).
The analysis also accounts for the percent of in-person votes that went for Trump, because if
you have two adjacent precincts and they are similar in terms of their demographics and in-
person voting, one would expect them to also be roughly similar in terms of their absentee
ballots. While Democrats were pushing their voters to vote by absentee ballot, there is no
reason to expect that rate to differ between two precincts that are next to each other and are
similar in terms of their in-person voting support and their demographics.
I did this test using the data from both 2016 and 2020. There were no serious accusations of
fraud with respect to absentee ballots in 2016, so one should expect the absentee ballot
percent for Trump in precincts in Fulton county to behave no differently than the adjacent
precincts in Carroll, Cherokee, Coweta, and Forsyth.
The results in Table 1 show that in 2016, there was indeed essentially no difference (less than 1
percentage point) between Trump’s share of absentee ballots cast in Fulton and other
counties.13 Trump’s share of absentee ballots also matched up closely with his share of in-
person votes across the precincts, no matter which county they lay in.
12
The model is given as:
A = absentee ballots for Trump
TA = total absentee ballots for both candidates
P = in-person votes for Trump
TP = total in-person votes
a = A/TA
p = P/TP
Yi = (ai0 – ai1)
where the superscripts 0 and 1 indicate adjacent precincts in neighboring counties
Xi = (pi0 – pi1)
D = 1 if one of the adjacent precincts is in Fulton County (in that case Fulton County is superscript 0), D = 0
otherwise
Yi = ⍺ + ßXi + 𝛿 D*Xi + 𝑢I, and 𝑢 is the error term.
Null hypothesis: 𝛿 = 0.
Precinct pairs in which one is the Fulton County precinct are no different from other pairs.
Alternative hypothesis: 𝛿 < 0.
Precinct pairs in which one is the Fulton County precinct undercounts Trump’s absentee ballots.
The other counties are matched west to east and south to north. For a related discussion see Stephen G. Bronars
and John R. Lott, Jr., “Criminal Deterrence, Geographic Spillovers, and the Right to Carry Concealed Handguns,”
American Economic Review, May 1998, pp. 475-479.
13
The source for the 2016 precinct border lines was obtained here: http://rynerohla.com/index.html/election-
maps/2016-south-atlantic-republican-primaries-by-precinct/

However, redoing the same test for 2020 shows something quite different (see Table 2).
Trump’s percentage of absentee votes was now lower in Fulton county border precincts than in
the precincts just across the street in neighboring counties. Trump’s share was 7.19 percentage
points lower on the Fulton county side, and the difference was also statistically significant at
the 7% level for a two-tailed t-test.
This is not likely to have been caused by the general shift to absentee voting among Democrats,
because the study controlled for in-person voting. In layman’s terms, in precincts with alleged
fraud, Trump’s proportion of absentee votes was depressed – even when such precincts had
similar in-person Trump vote shares to their surrounding countries. The fact that the shift
happens only in absentee ballots, and when a country line is crossed, is suspicious.
In the first two tables, if the estimate for the “Difference in Trump’s percent of the two-
candidate in-person vote” between the two adjacent precincts equals 1, it means that the
differences in the percent of the in-person vote Trump received in the adjacent precincts would
perfectly track the difference in the absentee ballots. In the estimate for 2016, the coefficient
of 0.87 is not statistically different from 1. But for the 2020 data, Trump’s share of in-person
votes did not line up as closely with the differences in absentee ballots, as can be seen in the
reduced coefficient of the control variable for Trump’s share of in-person votes. Indeed, the
coefficient for 2020 (at .5738) is statistically significantly less than 1 at the 0.0000% level for a
two-tailed t-test.
This can also not be explained by the general shift in which Democrats were more likely to vote
absentee, because the precincts being compared are matched up by location (differing
primarily in terms of which side of the county line they lie on) and thus expected to be very
similar.
This study goes further and controls for demographic variables, to account for any differences
that might still exist. Georgia collects information on registered voters’ racial and gender
demographics by precinct. Table 3 accounts for the differences in the adjacent precincts by
replacing the change in the in-person difference in Trump’s share of the votes with detailed
demographic information. It provides information on the difference between the precincts in
the percent of the population that are black males, black females, Hispanic males, Hispanic
females, Asian males, and Asian females. Table 4 then not only includes those variables but
then also again the “Difference in Trump’s percent of the two-candidate in-person vote.” Thus,
this estimate uses three ways to account for differences in Trump’s share of the absentee ballot
vote: geographic closeness for relatively small areas, differences in Trump’s share of the in-
person vote, and differences in the demographics registered voters.
The results provide consistent estimates that Trump’s percentage of absentee votes was
consistently lower in Fulton county border precincts than in the precincts just across the street
in neighboring counties. The estimates for the Fulton County effect range from 5.8% to 17.3%
and again are all statistically significant. The variables for the race and gender demographics
are virtually never statistically significant, though that is not particularly surprising given how

highly correlated these variables are. That also makes it difficult to interpret individual
coefficients on the demographic variables. However, they are statistically significant as a group
(a joint F-test for the demographic variables shown in Tables 3 and 4 finds they have F-values of
4.53 and 4.23, respectively, which are both statistically significant at about the 1 percent level).
This indicates that the demographic values are worth including, and that table 4 is the preferred
model. But all models agree that Trump’s absentee ballot share was depressed in Fulton County
precincts.
Given that there were 145,267 absentee ballots cast for Trump and Biden in Fulton county,
even the lowest estimate of the unusual drop off in Trump’s share of the absentee ballots for
Fulton county of 5.84 percentage points equals approximately 8,280 votes, or 59% of Biden’s
margin of victory over Trump. There are concerns about vote counting in DeKalb county, but
there are no Republican counties adjacent to it for me to use in a test. However, with 128,007
absentee ballots cast for the two major-party candidates in DeKalb, a similar 5.84 percentage
point swing for Biden would account for another 7,482 votes. Together this margin in DeKalb
and Fulton would more than account for Biden’s winning vote share. Indeed, their total of
15,762 would be larger than Biden’s certified win.
If there were also fraud in terms of the in-person voting in Fulton County that worked to also
help Biden, the estimates presented here will underestimate the amount of fraud with the
absentee ballots. For example, in Georgia as well as Nevada, Pennsylvania, and Wisconsin there
were allegations that large numbers of in-person voters were not legally registered.14 In Fulton
County, Georgia, 2,423 voters were not listed on the State’s records as being registered and
2,560 felons who voted had not completed their sentence were registered.15
Using the average value for these various estimates (7.81%) shows that an unusual drop in
Trump’s share of the absentee ballots for Fulton County alone of 11,350 votes, or 90% of
Biden’s vote lead in Georgia.
III. Pennsylvania
In Pennsylvania’s initial ballot count, former Vice President Joe Biden leads President Trump by
81,361 votes. Biden won Allegheny and Philadelphia Counties by margins of 146,706 and
471,305 votes, and the absentee vote margins in the county were 206,505 and 310,553 votes.
There was also an usually large number of provisional votes in those counties, with Biden
leading by 1,489 and 9,045, respectively.
A number of concerns are raised about possible vote fraud in both counties. Republican poll
watchers have complained that they were too far away from the ballots to meaningfully
14
15
The Superior Court Of Fulton County State Of Georgia, Trump v. Raffensperger, December 4, 2020.
https://www.democracydocket.com/wp-content/uploads/sites/45/2020/12/Trump-v.-Raffensperger.pdf

observe the process.16 The president’s lawyers say that in Pittsburgh and Philadelphia, voters
with invalid mail-in/absentee ballots received a notification and were allowed to correct that
defect by using a provisional ballot on Election day, whereas election officials in Republican-
leaning counties followed election law more strictly and did not give similar notifications to
voters with invalid mail-in/absentee ballots.17 Complaints also arose from voters being required
to cast provisional votes because they were identified as having requested a mail-in ballot even
though the voter claimed that they had not done so.18 That raises concerns that someone else
other than the registered voter may have voted using that person’s absentee ballot.
While there are sworn affidavits attending to these problems, an open question has been
whether the level of problems was significant enough to alter the election outcome.
To examine that, I used the same approach with precinct-level data that I did for Georgia. I
collected data from adjacent precincts in Allegheny County and the four Republican counties
that border it: Beaver, Butler, Washington, and Westmoreland. The comparison is made
between Allegheny and these four other counties as well as between these four counties where
they are adjacent each other. However, unlike Georgia, I could only obtain the breakdown of
absentee and provisional voting for Allegheny County in 2020, so these estimates will look at
only the relationship in that year. While large scale fraud is alleged in Philadelphia County,
there are no Republican counties adjacent to it for me to use in a test.
The results in Table 5 show that in 2020, Trump’s percentage of absentee votes was lower in
Allegheny County border precincts than in the precincts just across the street in neighboring
counties. Trump’s share was 3.4 percentage points lower on the Allegheny County side, and the
difference was also statistically significant at the 8% level for a two-tailed t-test. This is about
half the size of the gap found in Georgia, but that still represents a net overrepresentation of
11,410 votes for Biden in Allegheny County. If that rate applies to Philadelphia County, that
would represent another 12,397 votes for Biden. If the Republican claims are correct about
Centre, Chester, Delaware, Montgomery, and Northampton Counties and that rate remains at
3.4 percentage points, their 622,443 absentee ballots between Biden and Trump would imply
another 20,909 votes. Combined, that indicates Biden got a total of 44,716 extra votes that are
attributable to the difference in county election methods.
16
Shan Li and Corinne Ramey, “What Are Election Observers? Role at Crux of Trump Lawsuits in Pennsylvania,”
Wall Street Journal, November 10, 2020 (https://www.wsj.com/articles/what-are-election-observers-the-role-at-
the-crux-of-trump-lawsuits-in-pennsylvania-11605053759). Daniel Payne, “Pennsylvania poll watcher: 'We literally
had no input and no ability to watch anything',” Just the News, November 9, 2020
(https://justthenews.com/politics-policy/elections/pennsylvania-poll-watcher-we-literally-had-no-input-and-no-
ability-watch).
17
Rudy Giuliani, “Trump Campaign News Conference on Legal Challenges,” C-SPAN, November 19, 2020
(https://www.c-span.org/video/?478246-1/trump-campaign-alleges-voter-fraud-states-plans-lawsuits).
18
Complaint filed in Trump v Boockvar et al in the United States District Court for the Middle District of
Pennsylvania (p. 48).

To the extent that one believes that there is fraud in in-person voting, the estimates here will
underestimate the amount of fraud in absentee ballots.19
Because of aforementioned concerns with provisional ballots being offered to solve problems
with absentee ballots in Allegheny and Philadelphia Counties, I also used the same test to we
have been using to examine them.
Table 6 is the same as Table 5, except it applies to provisional, rather than absentee, votes.
While the estimate is quite large, implying a 12.5 percentage point lower rate for Trump in the
adjacent precincts in Allegheny County, the result is not statistically significant. But there is a
simple reason for this. There are a lot fewer observations as 53 of the 87 observations have no
provisional ballots for Trump and, since one cannot divide by zero, those observations are not
defined.20
Another way to look at the problem that avoids the loss of these observations is to look at the
rate that provisional ballots were used in Allegheny versus the Republican counties. In that
case, there is a very clear difference. 1.5% of the votes in border precincts on the Allegheny side
involve provisional ballots, which is 3.2 times the 0.48% in the adjacent precincts in the
surrounding counties, and that difference is statistically significant at more than the 0.1% level
for a two-tailed t-test.21
Table 7 looks at the difference in the percent of Biden’s votes from provisional ballots in the
adjacent precincts after accounting for the same difference for Trump. The share of Biden’s
votes from provisional ballots is about 1.02 percentage points higher in Allegheny County than
in the adjacent precincts, that is about 4,400 more votes for Biden. If the same pattern
occurred in Philadelphia, that would be another 6,160 votes.
Again, as a control, I tried running this for Georgia. Given that the claim about warning voters to
correct defects in absentee by using a provisional ballot was not applicable to Georgia, one
would not expect a statistically significant result for that state. Indeed, those results indicate
that for Fulton County the effect was extremely tiny – just 1/20th of the size of the coefficient
for Allegheny County – and was statistically insignificant with a t-statistic of only 0.47.
19
Republicans argue that there is some reason for concern. Pennsylvania has had convictions as recently as this
year in Philadelphia where a Philadelphia Judge of Elections was charged with election fraud for allegedly stuffing
ballot boxes on behalf of Democratic candidates in three different races (Katie Meyer, “Philly judge of elections
pleads guilty to election fraud, accepting bribes,” WHYY NPR, May 21, 2020 (https://whyy.org/articles/philly-judge-
of-elections-pleads-guilty-to-election-fraud-accepting-bribes/).). The president’s lawyer, Rudy Giuliani, has also
claimed that people from New Jersey illegally voted in Philadelphia (Rick Sobey, “Rudy Giuliani claims Trump
campaign has found nationwide Democrat voter fraud conspiracy plot,” Boston Herald, November 19, 2020
(https://www.bostonherald.com/2020/11/19/rudy-giuliani-trump-campaign-has-found-nationwide-voter-fraud-
conspiracy-plot/)).
20
I also ran this regression using the Georgia data, but there were so few places with provisional ballots there were
only 12 observations and the Fulton County Effect variable was omitted from the regression.
21
The rate is slightly higher for the entire county: 1.98%.

Adding the results together, there are at least 55,270 extra ballots given to Biden. To the extent
that there is also some fraud in in-person voting, it is plausible that this total is roughly similar
to Biden’s margin in Pennsylvania.
Finally, I redid the results from Tables 5, 6, and 7A with data from Polidata on the racial
demographics of voting age populations in these precincts. While information on gender
wasn’t available, data from the 2010 Census was available on the difference between the
precincts in the percent of the voting age population that are black, Hispanic, and Asian. The
results are similar to what were shown before, though the estimate that corresponds to Table 5
is statistically significant at the 10 percent level for a one-tailed t-test.
IV. Voter Turnout Rate
One objection to the preceding results is that even though the preceding results accounted for
three types of differences between precincts (geography as they are across the street from
each other, the difference in the in the in-person vote share for Trump, and demographic
variables), there still might be some other difference associated with county lines that might
explain the difference in how absentee ballots were voted in 2020. It isn’t obvious what that
difference would be since the push for absentee ballots by Democrats appears to have been an
state level and national level effort. If you had two adjacent precincts next that are the same in
terms of support for Trump and demographics, it isn’t clear why Democrats wouldn’t try to get
absentee votes from both precincts. Still, even if such a factor might exist that is independent of
fraudulent activity, providing another qualitatively different test might help make that
alternative explanation less plausible.
Vote fraud can increase voter turnout rate. Increased fraud can take many forms: higher rates
of filling out absentee ballots for people who hadn’t voted, dead people voting, ineligible
people voting, or even increased payments to encourage legally registered people to vote. The
increase might not be as large as the fraud if votes for opposing candidates are either lost,
destroyed, or replaced with ballots filled out for the other candidate.
For example, a court case in Georgia Fulton County Superior Court by State Republican
Chairman David Shafer and President Donald Trump discovered hundreds of thousands of extra
votes: 40,279 people who had moved counties without re-registering; 4,926 voters who had
registered in another state after they registered in Georgia; 305,701 people who, according to
state records, applied for an absentee ballot past the deadline; 66,247 under 17 years of age,
2,560 felons, 8,718 who were registered after they were dead, and 2,423 who were not on the
state’s voter rolls.22
22
Donald J. Trump and David J. Shafer v Brad Raffensperger et al, Fulton County Superior Court, December 4, 2020
(https://cdn.donaldjtrump.com/public-files/press_assets/verified-petition-to-contest-georgia-election.pdf).

In Nevada, over 42,000 voted more than once.23 Jesse Banal, the lead counsel for the Trump
Campaign in testimony before the Senate Hearing on Election Security and Administration,
compiled this list by reviewing voter registration lists and finding the same name, address, and
birthdate for registered voters. In some cases, two registrants might have the same last name,
same birthdate, and same address, but one is “William” and the other “Bill.” Over 1,500 dead
people allegedly voted. Another 19,000 people who voted didn’t live in the state (this doesn’t
include military voters or students). Over 1,000 listed non-existent addresses.
Similarly, in Madison and Milwaukee, Wisconsin, 28,395 people allegedly voted without
identification. Republican lawyers claimed that 200,000 absentee ballots did not have the
proper signatures to be allowed to be counted.24 Payments to Native Americans to vote were
supposedly “orchestrated by the Biden campaign . . . [with] Visa gift cards, jewelry, and other
‘swag.’”25
Another reason for a higher turnout could be because of a much lower absentee rejection rate.
Ballotpedia notes that in the 2016 general election 6.42% of Georgia’s absentee ballots were
rejected, but that rate was only 0.60% in 2020 – that is a difference of about 76,971 votes.26
Other swing states also saw a drop, though they were much smaller than Georgia’s.
Pennsylvania’s went from 0.95% in 2016 to 0.28% in 2020 – a difference of 17,361 votes.27,28
23
Senate Hearing on Election Security and Administration, December 16, 2020 (https://www.c-
span.org/video/?507292-1/senate-hearing-election-security-administration).
24
Senate Hearing on Election Security and Administration, December 16, 2020 (https://www.c-
span.org/video/?507292-1/senate-hearing-election-security-administration).
25
Paul Bedard, “Pro-Biden effort offered Native Americans $25-$500 Visa gift cards and jewelry to vote,” Washington
Examiner, December 3, 2020 (https://www.washingtonexaminer.com/washington-secrets/pro-biden-effort-
offered-native-americans-25-500-visa-gift-cards-jewelry-to-vote).
26
“Election results, 2020: Analysis of rejected ballots,” Ballotpedia, December 23, 2020
(https://ballotpedia.org/Election results, 2020: Analysis of rejected ballots). The number of absentee ballots
cast (1,322,529) is from the Georgia Secretary of State’s website
(https://sos.ga.gov/index.php/elections/number_of_absentee_ballots_rejected_for_signature_issues_in_the_202
0_election_increased_350_from_2018).
27
The number of absentee ballots cast in Pennsylvania for Biden and Trump were obtained from Pennsylvania’s
Secretary of State
(https://www.electionreturns.pa.gov/General/SummaryResults?ElectionID=83&ElectionType=G&IsActive=1).
28
While it isn’t necessary for the results shown here, a higher turnout rate could also show up from the
manufacturing of false ballots. A possible example occurred in Atlanta, where, as noted, election officials ordered
ballot-counting stopped because of a water leak. (Frank Chung, “Slow leak’: Text messages cast doubt on Georgia
officials’ ‘burst pipe’ excuse for pause in counting,” News.com, November 12, 2020
(https://www.news.com.au/world/north-america/us-politics/slow-leak-text-messages-cast-doubt-on-georgia-
officials-burst-pipe-excuse-for-pause-in-counting/news-story/19176f5113512210517c82debe684392).) The
officials told observers that the vote-counting would start up again in the morning. Then once poll watchers,
observers, and the media left, the vote-counting continued with surveillance video caught large boxes of ballots
pulled out from underneath a draped table. (“Trump Campaign lawyers present video 'evidence' of ballot fraud,”
Senate Judiciary Subcommittee, December 4,2020. https://www.youtube.com/watch?v=LJ0xDWhWUxk) On the
other hand, Fulton County Elections Director Richard Barron, a Democrat, claims that no one was asked to leave
and that observers decided on their own to leave the building in Atlanta. (Staff, “Surveillance Tape Of Vote
Counting Breeding False Fraud Claims In Georgia,” Associated Press, December 4, 2020

Nevada’s dropped by 0.6 percentage points – 4,143 votes. The only other swing state that
Ballotpedia proves an estimate of rejected absentee ballots for was Michigan, and their rate
was essentially unchanged from 2016 to 2020, falling from 0.49% to 0.46%.
On the other hand, some aspects of vote fraud can reduce voter turnout. In Arizona, Republican
Plaintiffs in the United States District Court for the District of Arizona claim that up to 94,975
voters returned absentee ballots that were marked as unreturned.29 Peter Navarro’s election
report describes these lost or destroyed ballots as “consistent with allegations of Trump ballot
destruction.”30
To test whether counties in which fraud was alleged had higher turnout rates, I take the voter
turnout rates for the 2016 and 2020 general elections by county for the swing states: Arizona,
Florida, Georgia, Michigan, Nevada, North Carolina, Ohio, Pennsylvania, and Wisconsin. The
question was whether there was a larger increase in turnout rates for the counties in which
vote fraud was alleged relative to other counties. The counties claimed to have had vote fraud
are the ones already discussed for Georgia (Fulton and DeKalb) and Pennsylvania (Allegheny,
Centre, Chester, Delaware, Montgomery, Northampton, and Philadelphia). For Arizona (Apache,
Coconino, Maricopa, and Navajo),31 Michigan (Wayne), Nevada (Clark and Washoe),32 and
Wisconsin (Dane, Menominee, and Milwaukee)33.
To account for differences in county turnout rates, I account for that county’s turnout rate
when Trump ran in 2016 and how heavily Republican or Democrat the counties are based on
whether they voted for Trump or Biden. I classify those counties that Trump carried as
Republican counties and Biden’s ones as Democratic ones. Since the turnout change may differ
for Democratic and Republican counties, I separate the counties where Trump and Biden won
(https://www.huffpost.com/entry/video-georgia-election-false-
fraud_n_5fcac976c5b619bc4c330575?guccounter=1&guce_referrer=aHR0cHM6Ly9kdWNrZHVja2dvLmNvbS8&guc
e).) Similarly, Gabriel Sterling, Georgia’s voting system implementation manager, says that even if political
observers weren’t present, Georgia Secretary of State investigators were present. (Twitter post by
(https://twitter.com/GabrielSterling/status/1334825233610633217?s=20).)
29
See the United States District Court for the District of Arizona, Tyler Bowyer et al v.. Doug Ducey, December 2,
2020 . https://www.democracydocket.com/wp-content/uploads/sites/45/2020/12/Bower-Complaint-AZ.pdf
30
31
John Davidson, “In Nevada, A Corrupt Cash-For-Votes Scheme Is Hiding In Plain Sight,” The Federalist, November
18, 2020 (https://thefederalist.com/2020/11/18/in-nevada-a-corrupt-cash-for-votes-scheme-is-hiding-in-plain-
sight/),
(https://web.archive.org/web/20201109232825/https:/twitter.com/ITCAOnline/status/1319745575064162304),
Anna V. Smith, “How Indigenous voters swung the 2020 election,” High Country News, November 6, 2020
(https://www.hcn.org/articles/indigenous-affairs-how-indigenous-voters-swung-the-2020-election).
32
Paul Bedard, “Pro-Biden effort offered Native Americans $25-$500 Visa gift cards and jewelry to vote,”
Washington Examiner, December 3, 2020 (https://www.washingtonexaminer.com/washington-secrets/pro-biden-
effort-offered-native-americans-25-500-visa-gift-cards-jewelry-to-vote).
33
Scott Bauer, “Wisconsin issues recount order in 2 counties as Trump wanted,” Associated Press, November 19,
2020 (https://apnews.com/article/wisconsin-recount-2-counties-f408a7b43deb96e2ac7ff0b24a2f968a). See also
https://web.archive.org/web/20201111220325/https:/www.facebook.com/permalink.php?story_fbid=153929728
6270372&id=573103029556474.

with two separate variables. When Biden won a county, the values for the Republican variable
are zero. Similarly, when Trump won, the values for the Democratic variable are zero.
Elsewhere those variables equal Trump’s share of the vote minus Biden’s share. Since I have no
expectation of whether a change in turnout was linear with respect to how partisan the county
was, I also tried including the square of these measures of how partisan these counties were
(see Table 9).
I also used data from the U.S. Census Bureau's 2019 American Community Survey on median
household income as well as the percent of the population that is female, different racial
groups, by highest level of education, and the age groupings as provided by the Census.
The estimates in Table 10 start from the simplest specification to one with more controls, and
they imply that the counties where vote fraud is alleged had between 147,000 and 289,000
excess votes. In each case, the county fraud variable’s coefficient is statistically significant at
least at the 5 percent level for a one-tailed t-test.
The first specification shows that the more heavily Republican a county was, the larger the
increase in voter turnout rate over 2016. The opposite is true for more heavily Democratic
counties, but that effect is statistically insignificant. The F-test shows Democratic and
Republican counties behaved very differently in terms of voter turnout rates. The turnout rate
in 2016 by itself explains about half the variation in 2020 voter turnout.
The next estimate looks at both how Democratic or Republican counties are as well as those
values squared. Again, the voter turnout rate increased the most in the Republican counties
and didn’t change in the Democratic ones. While the coefficients for the Republican counties on
Trump’s win margin and that margin squared weren’t individually statistically significant, the F-
test shows that they are jointly statistically significant at better than the one percent level.
The following two specifications include the Census information for the counties. Still, they
show what should be pretty obvious: Census data on income, race, gender, age, and education
are highly correlated with measures of how partisan a county is. When I include the Census
data, the Republican partisanship measures are no longer statistically significant, even for the
joint F-test. Including all the additional factors explains virtually nothing more in the percent of
the variation in turnouts (the R-squares only increase by about one or two percentage points
and the difference in adjusted R-squares is even smaller).
The difference in the two specifications involves whether I include the percent of the
population that is Native American. Given that the vote-buying schemes were directly related
to Native Americans, both the percent of the population that is Native American and the county
fraud variable will be highly correlated. The county fraud variable in the fourth specification will
thus undercount the impact of vote fraud in that county. The third and fourth estimates imply
that there was between a 1.26 and 2.42 percent unexplained increase in voter turnout in
counties where fraud was alleged – the equivalent of 150,000 to 289,000 more votes.

In Table 11, I reran the regressions in Table 10 on just the two states that we examined in the
earlier sections of this – Georgia and Pennsylvania – as well as the control states swing state
(Florida, North Carolina, and Ohio), and the results were slightly larger and consistently
statistically significant at around the 5 percent level for a one-tailed t-test. The estimates on the
county fraud variable implied excess votes of between 1.37 and 1.53 percent, or about 70,000
to 79,000 votes. The total combined win margin for Biden in Georgia and Pennsylvania was
92,334. Again, my estimates are an underestimate of the fraud if votes for opposing candidates
are either lost, destroyed, or replaced with ballots filled out for the other candidate.

V. Conclusion
The precinct level estimates for Georgia and Pennsylvania indicate that vote fraud may account
for Biden’s win in both states. The voter turnout rate data also indicates that there are
significant excess votes in Arizona, Michigan, Nevada, and Wisconsin as well. While the
problems shown here are large, there are two reasons to believe that they are underestimates:
1) the estimates using precinct level data assume that there is no fraud occurring with in-
person voting and 2) the voter turnout estimates do not account for ballots for the opposing
candidate that are lost, destroyed, or replaced with ballots filled out for the other candidate

Table 1: 2016 Difference in Trump’s share of the Absentee Ballot Vote between adjacent
precincts at the border of Fulton, Carroll, Cherokee, Coweta, and Forsyth Counties
Control variables Coefficient Absolute t-statistic Level of statistical

significance for a two-
tailed t-test
Difference in Trump’s 0.8695 4.99 0.0000
percent of the two-
candidate in-person
vote between two
precincts
Fulton County Effect -0.008786 0.12 0.908
Intercept -0.014329 0.25 0.806

Number of F-statistic = 18.05 R-Squared = - 0.6322
Observations 24 Level of significance =
0.0000

tailed t-test
percent of the two-
candidate in-person
vote between two
precincts
Intercept 0.0632825 2.11 0.048

0.0000

Table 3: 2020 Difference in Trump’s share of the Absentee Ballot Vote after adjusting for
Racial and Gender Demographics of Registered voters

tailed t-test
Difference in the -1.9175 1.36 0.195

percent of voters who
are black males
Difference in the 1.31927 0.98 0.343
are black females

are Hispanic males

are Hispanic females

are Asian males
are Asian females
Intercept 0.10648 2.29 0.038

0.0008

Racial and Gender Demographics of Registered voters and the difference in the in-person
vote
Control variables Coefficient Absolute t- Level of statistical significance
statistic for a two-tailed t-test
percent of the two-
candidate in-person vote
between two precincts
Difference in the percent -0.94517 1.31 0.214

of voters who are black
males
Difference in the percent 1.1561 1.71 0.111
females

of voters who are Hispanic
males

females

of voters who are Asian
males
females
Intercept 0.0717792 3.00 0.010

Number of Observations F-statistic = 30.85 R-Squared
22 Level of significance = - 0.9500
= 0.0000

precincts at the border of Allegheny, Beaver, Butler, Washington, and Westmoreland
Counties
tailed t-test
percent of the two-
candidate in-person
vote in the adjacent
precincts
Allegheny County -0.0335925 1.75 0.084
Effect
Intercept 0.0374956 2.09 0.039
0.0000
Table 6: 2020 Difference in Trump’s share of the Provisional Ballots between adjacent
Counties
tailed t-test
percent of the two-
candidate in-person
vote in the adjacent
precincts
Effect
Intercept 0.088098 0.66 0.514
0.1036

Table 7: 2020 The Difference in the share of Biden’s votes from provisional ballots in
adjacent precincts
A) Examining Allegheny, Beaver, Butler, Washington, and Westmoreland Counties

tailed t-test
share of Trump’s
votes from
provisional ballots in
the adjacent precincts
Allegheny County 0.010184 2.27 0.026

Effect
Intercept -0.0032873 0.96 0.338
Number of F-statistic = 18.90 R-Squared = 0.3104
0.0000
B) Examining Fulton, Carroll, Cherokee, Coweta, Fayette, and Forsyth Counties
share of Trump’s
votes from
the adjacent precincts
Fulton County Effect 0.0003418 0.49 0.626
Intercept -0.0000357 0.06 0.950

0.0000

Table 8: Re-estimating Tables 5, 6, and 7A by including Census 2010 Precinct Demographic
data on Difference in the percent of the voting age population who are Black, Hispanic, and
Asian
Regression Coefficient Absolute Level of
Estimate on the t-statistic statistical
Allegheny significance for
County a two-tailed t-
Effect test
Table 5 -0.0288 1.53 0.131 Number of obs = 87
F-statistic = 8.17
Level of significance F-test = 0.0000
R-square = 0.3353
Table 6 -0.1555 1.13 0.266 Number of obs = 34
F-statistic = 2.46
R-square = 0.3048
Table 7A 0.010048 2.09 0.040 Number of obs = 87
F-statistic = 7.51
R-square = 0.3048

Table 9: Comparing Voter Turnout Rates in 2020 Swing States (Arizona, Florida, Georgia,
Michigan, Nevada, North Carolina, Ohio, Pennsylvania, and Wisconsin)
Variable Observations Mean Standard Deviation
Percent Voter Turnout 668 .7502149 .0704998
in 2020 Election
Percent Voter Turnout 668 .6979785 .0757554
in 2016 Election
Republican Counties 668 .18628 .21074
(Trump’s minus Biden’s
share of votes)
Republican Counties 668 .0790 .1228
share of votes squared)
Democrat Counties 668 -.1369 .200619
share of votes)
Democrats Counties 668 .05894 .10930
share of votes squared)
County where Fraud 668 .02844 .1664
alleged

Table 10: Did Counties Accused of Fraud have an unusual increase in Voter Turnout? (Arizona,
Florida, Georgia, Michigan, Nevada, North Carolina, Ohio, Pennsylvania, Wisconsin)
(absolute t-statistics and the level of significance for a two-tailed t-test are in parentheses)
Control variables (1) (2) (3) (4)
County where Fraud alleged .0124 .0123 .02423 .0126
(1.96, 0.050) (1.95, 0.052) (3.66, 0.000) (1.78, 0.076)
Republican Counties (Trump’s minus 0.0149 .0129 .00317 .0047
Biden’s share of votes) (2.39, 0.017) (0.62, 0.538) (0.15, 0.881) (0.23, 0.821)
Republican Counties (Trump’s minus .0097 .01004 .0099
Biden’s share of votes squared) (0.32, 0.746) (0.33, 0.741) (0.33, 0.740)
Joint F-test for Republican Counties F-test = 4.02 F-test = 0.74 F-test = 0.99
Democrat Counties (Trump’s minus 0.0152 -.0255 -.0130 -.0135
Biden’s share of votes) (0.23, 0.816) (1.03, 0.301) (0.54, 0.592) (0.56, 0.573)
Democrats Counties (Trump’s minus -.0493 -.03517 -.0340
Biden’s share of votes squared) (1.28, 0.202) (0.94, 0.350) (0.92, 0.359)
F-test for how turnout rates vary F-test = 8.18
differently between heavily
Democratic and Republican counties
Joint F-test for Democrat Counties F-test = 1.01 F-test = 0.99 F-test = 0.83
Percent Voter Turnout in 2016 .8653 .8661 .8090 .8060
Election (62.50, 0.00) (62.51, 0.00) (46.16, 0.00) (46.53, 0.00)
Median household income 2.34e-07 4.03e-07
(1.18, 0.238) (2.01, 0.044)
Percent Female .0549 .1044
(0.91, 0.364) (1.72, 0.087)
Percent Black -.0112 -.006256
(-1.12, 0.262) (0.63, 0.529)
Percent Hispanic or Latino -.03530 -.03268
(2.27, 0.023) (2.13, 0.034)
Percent Asian -.29899 -.25397
(2.94, 0.003) (2.52, 0.012)
Percent Native American .09038
(4.14, 0.000)
Percent Two or more races -.4854 -.543089
(4.46, 0.000) (5.01, 0.000)
Percent High School Graduate -.0775 -.0717
(1.98, 0.048) (1.85, 0.064)
Percent Some College or Associate -.06118 -.0706
(1.62, 0.105) (1.89, 0.059)
Percent Bachelor’s Degree .06025 .054079
(1.04, 0.301) (0.94, 0.347)

Percent Graduate or Professional -.10699 -.12516
(1.52, 0.129) (1.80, 0.072)
Joint F-test for Census Age Groups F-test = 3.72 F-test = 1.57
Constant .1433 .1416 .16232 .06437
(14.30, 0.00) (13.60, 0.00) (2.11, 0.035) (0.81, 0.418)
Number of Observations = 668 F-stat = F-stat = F-stat = F-stat =
983.11 656.27 128.44 128.53
R2 = 0.8557 R2 = 0.8563 R2 = 0.8767 R2 = 0.8800

Table 11: Focusing on Voter Turnout in Georgia and Pennsylvania. Using the specifications shown in
Table 10, though not all results are reported. (Florida, Georgia, North Carolina, Ohio, Pennsylvania)
(absolute t-statistics and the level of significance for a two-tailed t-test are in parentheses)
Control variables (1) (2) (3) (4)
County where Fraud alleged .01370 .01532 .01469 .01454
(1.53, 0.050) (1.71, 0.087) (1.63, 0.104) (1.61, 0.108)

From: Mastriano, Doug
To: [email protected]
Subject: Sen Mastriano (PA) letter on election irregularities in Pennsylvania
Date: Tuesday, December 29, 2020 11:28:55 AM
Attachments: donoghue elections investigate.pdf
Importance: High
Dear AG Donoghue,

As part of my constitutional responsibilities, I held an election hearing on November 25 pertaining to
the recent General Election. I am increasingly concerned by broad and extensive irregularities on
multiple levels in the Commonwealth that both undermined and undercut the outcome of the
presidential election.

Please do not hesitate to reach out to me with any questions.

Sincerely,
Sen Doug Mastriano
(b) (6)

December 28, 2020
Acting Deputy Attorney General Richard Donoghue

U.S. Department of Justice
950 Pennsylvania Avenue, NW
Washington, DC 20530-0001
RE: General Election Irregularities in Pennsylvania during the November 2020 cycle
Dear Honorable Donoghue:
Election fraud is real and prevalent in Pennsylvania. Yet, despite evidence, our Governor and Secretary
of State inexplicably refuse to investigate. Every legal vote must count. Our Republic cannot long endure
without free and fair elections where each person has one legal vote. However, allegations of fraudulent
activity, as well as violations of election law in 2020 have placed the nation's eyes upon this Commonwealth.
Several of the key findings are delineated below:
1. Senate Majority Policy Committee November hearing review on statistical anomalies, such as hundreds
of thousands of votes being dumped into a processing facility, with 570,000 Vice President Biden, and
only 3,200 for President Trump (https://policy.pasenategop.com/112520/).
Testimony provided at a Senate hearing from witnesses in Philadelphia, Northampton, Luzerne,

Montgomery, Allegheny and Delaware counties detailed instances of:
(a) Interference with poll watchers’ ability to perform functions as provided for in the state
election code, specifically regarding the submission, review and canvasing of mail-in ballots;
(b) Delayed opening or closing of polling locations on Election Day;
(c) Improper forfeiture and spoiling of mail-in ballots;
(d) Illegal ballot harvesting;
(e) Improper “curing” of insufficiently completed mail-in ballots;

Page 2 of 5
AG Donoghue
(f) Poll worker intimidation and harassment;
(g) Voter intimidation;
(h) Improper chain of custody of ballots and election materials;
(i) Submission of fraudulent ballots by an individual other than the named voter.
2. There is a massive VOTER DEFICIT in Pennsylvania. 205,122 more votes were counted than total
number of voters who voted: A comparison of official county election results to the total number of
voters who cast ballots November 3, 2020…as recorded by the Department of State…shows the
difference of 205,122 more votes cast than voters actually voting. (Rep Frank Ryan,
http://www.repfrankryan.com/News/18754/Latest-News/PA-Lawmakers-Numbers-Don%E2%80%99t-
Add-Up,-Certification-of-Presidential-Results-Premature-and-In-Error).
3. Unidentified Voters: When anyone registers to vote online or by paper, two options are provided for
gender: Male or Female. If left blank; gender defaults to “No” – leaving three types of voters: Male,
Female and “No.” However, there are four genders in state voter rolls: Male, Female, “No” and
Unidentified. It has been estimated that there are 121,000 “non-female/male voters” on state voter rolls,
and 90,000 voted in 2020. Initial assessments have concluded that at least 1/3 of these "U" voters are
fraudulent (Unidentified “U” Voters, Kathy Barnette for Congress); (Unidentified “U” Voters, Kathy
Barnette for Congress);
4. The mandate by Governor Wolf last year, requiring new voting machines for 2020 raised concerns from
county officials and state lawmakers. As a result, 14 counties are using Dominion voting machines. The
counties using Dominion voting equipment (1.3 million voters in Pennsylvania ): York, Erie,
Montgomery, Bedford, Armstrong, Carbon, Crawford, Clarion, Fayette, Luzerne, Fulton, Jefferson, Pike
and Warren." (“As Pennsylvania Counties Ring in the New year with New Voting Machines, Pressure
from Election Security Advocates Remains,” The PLS Reporter, 01/06/2020;
https://www.pennlive.com/politics/2018/12/county-commissioners-question-the-funding-the-timing-the-
need-for-replacing-voting-machines.html; Questions Abound Over New Voting Machines, Citizens’
Voice, 03/22/2019; https://whyy.org/articles/despite-gop-objections-wolf-moves-to-upgrade-voting-
machines-unilaterally/; As Wolf Administration Pushes to Replace All Voting Machines by 2020,
Lawmakers and County Officials Question Rush and Expense, PA Watchdog, 03/29/2019).
5. Statistical experts examined Pennsylvania voting records and reached conclusions indicating there are
“major statistical aberrations” in state voting records that are “unlikely to occur in a normal setting;”
eleven counties (Montgomery, Allegheny, Chester, Bucks, Delaware, Lancaster, Cumberland,
Northampton, Lehigh, Dauphin, York) showed “distinctive signs of voting abnormalities” for Vice
President Biden. These analyses “provide scientific evidence that the reported results are highly
unlikely to be an accurate reflection of how Pennsylvania citizens voted.” (Pennsylvania 2020 Voting
Analysis Report, 11/16/2020).
6. Gettysburg Senate Hearing - On November 25, Senator Doug Mastriano, together with Senator David
Argall, hosted the Senate Majority Policy Committee hearing in Gettysburg where hours of testimony
were presented, reviewed, and vetted regarding voting fraud and violations of voting law in
Pennsylvania. The hearing demonstrated that there is rampant election fraud in Pennsylvania that must
be investigated, remedied and rectified. The purpose of the hearing was to find out what happened in
Page 3 of 5
AG Donoghue
Pennsylvania in the aftermath of hearing allegations from thousands of people from across the
Commonwealth sharing stories of violations of election law and other infringements of voting law
related to the November 03, 2020 general election. We heard eyewitness testimony from citizens who
experienced their rights being violated. Additionally, during the hearing, expert witnesses testified to
statistical anomalies, where massive quantities of ballots arrived without a chain of custody. In one
such spike, close to 600k votes were dumped in a processing facility with 570k of these votes going
for Biden, and a paltry 3,200 for President Trump. Another witness testified that an election worker
was plugging flash drives into voting machines in a heavily democrat area, for no stated purpose.
Other irregularities included in the testimony presented at the hearing included:
(a) Mail-in ballots were not inspected by Republican representatives in portions of Philadelphia and
Allegheny County;
(b) Montgomery County was never provided with guidelines from State Department Secretary about
“curing” defective ballots;
(c) Timeline spikes depict more ballots being processed during specific periods than voting
machines are capable of tabulating;
(d) The Philadelphia Board of Elections processed hundreds of thousands of mail-in ballots with
zero civilian oversight.
(e) Ballots were separated from envelopes in numerous precincts; a recount is useless because the
votes cannot be verified;
(f) Observers were corralled behind fencing in Philadelphia, at least 10 feet away from processors;
similarly, in Allegheny County, observers were placed at least 15 feet away;
(g) Mail-in ballots were already opened in portions of Allegheny County; no one observed the
opening of these ballots;
(h) Illegal “pop-up” election sites developed, where voters would apply, receive a ballot and vote;
(i) Forensic evidence in Delaware County has disappeared;
(j) A poll watcher with appropriate certificates and clearances was denied access;
(k) There was no meaningful observation of ballots in Montgomery County, and no signature
verification, as well;
(l) A senior citizen voted for President Trump, but it was not displayed on receipt;
(m) Election workers illegally pre-canvased ballots in Northampton County; no meaningful canvas
observation was permitted;
Page 4 of 5
AG Donoghue
(n) several voters from across the state went to vote in person but when they arrived, they were told
“they already voted” and were turned away and could not actually vote or were able to fill out a
provisional ballot but was it really counted?
Despite the mounting evidence, our Governor and Secretary of State decline to investigate these serious
allegations.
The United States of America has spent millions of dollars and put her men and women in harm’s way
to oversee safer, more reliable and freer elections in Afghanistan, Iraq, Kosovo and Bosnia. Why is the very
state where the light of liberty was lit in 1776 is unable or unwilling to have elections as free and safe as war-
torn Afghanistan? Something is seriously wrong in this Commonwealth and unless this is corrected, our
republic cannot long endure.
The odyssey of PA finding itself in this position began in early 2020. Using the COVID-19 pandemic as
a pretense, the Wolf Administration, together with the Pennsylvania Supreme Court, threw voting law into
disarray.
The General Assembly (State House and State Senate) are constitutionally responsible for writing
election law, not Gov Wolf, Secretary of Secretary Boockvar or the PA Supreme Court. These altered the
original meaning of key provisions of Act 77. The state Supreme Court and Secretary Boockvar fundamentally
altered and unconstitutionally rewrote the original meaning of key provisions of Act 77.
Voting law, as passed by the General Assembly in 2019, was clear and specific:
● All mail-in ballots must be received by 8 p.m. on Election Day;
● Officials at polling locations must authenticate the signatures of voters;
● County Boards of Elections can conduct pre-canvasing of absentee and mail-in ballots after 8 a.m. on
Election Day;
● Defective absentee and mail-in ballots shall not be counted; and
● “Watchers” selected by candidates and political parties are permitted to observe the process of
canvasing absentee and mail-in ballots.
The corruption of our election began with Governor Wolf during the COVID crisis. Wolf urged mail in
voting upon people with a campaign to perpetuate the dangers of COVID. Likewise, he inferred that polling
stations would be closed or undermanned due to the risk of the virus.
But the coup de main was seven weeks before Election Day, where the PA Supreme Court unilaterally –
and in direct contravention of the wording of election law – extended the deadline for mailed ballots to be
received from Election Day, to three days later. Similarly, the court declared that ballots mailed without a
postmark must be counted. Additionally, the court mandated that mail-in ballots lacking a verified signature be
accepted.
Page 5 of 5
AG Donoghue
On the eve of Election Day, the State Department encouraged some counties – but not all – to notify
party and candidate representatives of mail-in voters, whose ballots contained disqualifying defects, thereby
enabling voters to cure said defects. This was unprecedented as it had never happened before in our
Commonwealth. Election law is very specific to the way defects of mail-in ballots are to be treated, and it
provides no authority for county officials to contact campaigns, or other political operatives, to affect the cure
of such defects.
Actions taken by the PA State Supreme Court and Secretary Boockvar in the 2020 general election were
so fraught with inconsistencies, improprieties and irregularities that the results for the office of President of the
United States cannot be determined in our state.
This election is an embarrassment to our nation. John Adams rightly said that, "Facts are stubborn
things," and armed with this, as Jesus stated, "We shall know the truth and the truth shall set us free." What
happened on November 3, 2020 must be immediately addressed using facts and the testimony of the good
people of our state.
Sincerely,
Senator Doug Mastriano

33rd Senate District
DM/kms
cc: Hon. United States Attorney William McSwain

U.S. Attorney's Office
504 W. Hamilton St., #3701
Allentown, PA 18101
Election Timeline for Butler County, Pennsylvania/November 12, 2020
In 2016, Butler County had a 72% voter support for Donald J. Trump in comparison
to Hilary Clinton at 28%. Pennsylvania ranks 25th for voter participation with 51
percent of the eligible population voting in the 2018 election. Butler County was a
stronghold for President Trump in the past as well as other Republican Candidates, I
believe, our County was specifically targeted by external forces such as Governor
Tom Wolf, Secretary of Commonwealth and State Election Director Kathy Boockvar,
Mark Zuckerberg/ Media/ Tech, as well as, Progress PA and Democrats statewide, to
name just a few. There is no doubt these entities used their positions to influence
the overall outcome of the Pennsylvania 2020 election. Often times this was done
under the Covid guise of safeguarding the health, safety, and accessibility of
Pennsylvania voters. As a Butler County Commissioner, I witnessed first hand these
ongoing efforts made by these entities to chip away preceding and post election
through a variety of tactics with the purpose of creating confusion, chaos, and
instilling fear…all implemented by design. Changes made “on the fly” to election
laws intentionally without our elected state legislature, left Pennsylvania counties
isolated and at the mercy of edicts by State officials with no recourse. Counties were
left to their own devices and fortitude to determine what was occurring and push
back as we did multiple times. What was even more tragic, these changes were most
often accomplished under the guise and cover of the Covid pandemic that was used
to influence the behavior of the public voter who fell for it hook, line, and sinker by
the mail in ballot system which encompassed early voting. One by one, our own
Pennsylvania Democratic State Officials stripped each of the previously established
safeguards and firewall requirements that protect the integrity of the voter system.
It was astonishing the extent and effort these aforementioned entities went to, to
influence and marginalize the 2020 vote in any way to the advantage of Presidential
Candidate Joe Biden. Progressive entities well understood it would not take much to
manipulate and alter the playing field in what was predetermined to be a race
separated by less than a 100,000 votes. Secretary Kathy Boockvar went as far as
requesting King Bench provisions to be used as a mechanism by the Pennsylvania
State Supreme Court, as State Officials were struggling to get Counties to comply
with over zealous state edicts and guidance in lieu of laws. Governor Wolf signed a
second renewal of his 90-day disaster for the Covid-19 pandemic that would extend
beyond the November 3, 2020 election. Naturally, as expected, Covid hype despite
evidence would begin to surge prior to and during the election with the intent to
keep senior citizens from venturing out to the polls. Democrats were whole-
heartedly supportive of mail-in balloting and they knew Republicans would prefer
to vote in person at the polls. Bad weather or a pandemic, could possibly persuade
some elderly or unhealthy individuals to stay at home? Hopefully, the Butler County
timeline will illuminate a much-needed light into the workings of these forces and
how they can influence our local, state, and national elections. The data, numbers,
and dubious actions compiled in the Butler County timeline demonstrate repeatedly
as to the Governor and his Election Administration’s great reluctance to follow
existing election law and processes, their lack of respect for the Constitution, and
the Governor’s own defiance to govern with the elected Pennsylvania General
Assembly who represent the voice of and by the people. The people of Pennsylvania
deserve to know to the extent and effort made by various entities to marginalize the
existing laws and processes governing our Commonwealth’s election system in an
effort to alter and/or influence a Presidential Election. After all, if our laws and
Constitution do not mean or stand for anything and we allow anyone, even a
Governor, to over ride laws, even under the conditions of a pandemic, then why
have a Constitution? Moving forward we must learn how we must work in each of
our own capacities, whether, we are a working man or an elected county
commissioner to stand up and protect not only our election system nationwide for
the greater good of democracy and our country as a whole. Our future generations
of voters and our country depend upon it.
Kimberly D. Geyer, Vice Chairman of the Butler County Commissioners
 Coming into office in 2016, Butler County, like many in PA, were in the
process of researching state certified vendors of election equipment and
investing into new voter equipment with a paper trail to replace existing
equipment which was a touch screen technology and no paper trail. In April
2018, the Department of State informed counties they must select the new
voting systems by the end of 2019 and voters must use the new system no
later than the April 2020 primary election. At least 52 counties, or 78
percent, have taken official action toward selecting a new voting system.
And 46 counties, or 68 percent, plan to use their new voting system in the
November 2019 election. Because Butler County had begun the process of
interviewing and acquiring new election equipment prior to the state
mandate by the Governor, we felt in a better-prepared position prior to our
fellow counties who, some, had only begun the process after the 2018
mandate.
 October 31, 2019 Governor Tom Wolf made voting more convenient by
signing PA Act 77 of 2019 into law. Without state legislature input, Governor
Wolf removed straight party ballot voting. Governor Wolf established the
ability for counties to set up temporary polling locations as early voting
stations.
Some of the provisions of PA Act 77 of 2019 are as follows: (prior to last

minute changes)
 No excuse mail-in voting

The law creates a new option to vote by mail without providing an excuse,
which is currently required for voters using absentee ballots. Pennsylvania
joins 31 other states and Washington, D.C. with mail-in voting that removes
barriers to elections.
 50-day mail-in voting period
All voters can request and submit their mail-in or absentee ballot up to 50
days before the election, which is the longest vote-by-mail period in the
country.
 Permanent mail-in and absentee ballot list
Voters can request to receive applications for mail-in or absentee ballots for
all primary, general and special elections held in a given year. Counties will
mail applications to voters on the list by the first Monday of each February.
Voters who return an application will receive ballots for each election
scheduled through the next February. Pennsylvania is the 12th state to
provide voters with the automatic option.
 15 more days to register to vote
The deadline to register to vote is extended to 15 days from 30 days before
an election. Cutting the current deadline by half enables more people to
participate in elections. The new more flexible and voter friendly deadlines
provide more time to register to vote than 24 other states.
 Creates Early Voting
Perhaps without full legislative awareness, Act 77 also creates early voting,
which many state legislators did not fully understand as it was not clear in
the act. This suddenly created long lines of voters in County election bureau
offices in the week(s) leading up to the election, further distracting and
hampering the ability to effectively execute actual mail ballot processing and
election preparations. (See attached article from Philadelphia 3.0 PAC)
 Extends mail-in and absentee submission deadlines
Voters can submit mail-in and absentee ballots until 8:00 p.m. on Election
Day. (Later extended to three days post Election Day). The current deadline
is 5:00 p.m. on the Friday before an election, which is the most restrictive in
the country. Pennsylvanians submitted 195,378 absentee ballots in 2018,
but 8,162 – more than four percent – missed the deadline and were rejected.
The national average is only two percent.
 The law also authorizes the governor to pursue a $90 million bond to
reimburse counties for 60 percent of their actual costs to replace voting
systems. The new systems have enhanced security to help guard against
hacking and produce an anonymous paper record so voters can verify their
ballot is correctly marked when casting it. Paper records also allow officials
to conduct the most accurate recounts and audits of election results.
 3/6/20 Covid-19 made its presence known in Butler County. Meanwhile, PA
Department of Health Secretary Rachel Levine was providing
Pennsylvanians daily-televised updates on the Covid pandemic and
statewide stay at home, school, and business closures began to be
implemented across regions of the PA Commonwealth.
 3/27/20 Governor Wolf signed Senate Bill 422, which rescheduled
Pennsylvania’s primary election from April 28 to June 2 due to the COVID-19
emergency.
 4/22/20 Governor closed Commonwealth with the exception of life-
sustaining businesses. Schools and childcare facilities closed. Stay at home
orders in place.
 4/22/20 Butler County election director resigns approximately one month
ahead of what was to be the May 2020 Presidential Primary before the State
extended it to June 2, 2020. This would be a pattern reoccurring statewide
due to frustration by State changes being made on the fly, and increased
workloads related to the mail–in ballot requirements. More than a 19 of PA’s
County Election Directors or Deputies resigned or left, that is one in every
3.5 counties. Butler County deputized two long time workers to split the
position until posting the job vacancy after the June 2nd Primary.
 4/28/20 Updated DOS (Dept. of State) guidance began occurring to all
counties in regards to preparation of elections (2020 Presidential Primary)
and HEIGHTENING Covid-19.
 5/1/20 DOS asked counties to participate in a technology program called
Albert Sensors to have counties connect into and to provide multi-state
information sharing and analytics. Butler County declined to participate as a
pilot county. Butler County had just invested in new technology
enhancements and did not want to that to interfere with our new internal
technologies and security. (This request will come around again by DOS in
the weeks leading to the Fall November election).
 5/5/20 Butler County represented by two Republican County
Commissioners (Osche & Geyer) filed petition for amicus brief for the
Friends of Danny Devito case v. Governor Tim Wolf and Rachel Levine,
Secretary of Health (respondents) for the statewide business closures and
the Constitutional violations represented by Attorney Thomas W. King III.
 5/7/20 (2:30p.m.) Butler County (Osche & Geyer) files lawsuit in federal
district court on behalf of Butler County, and joining counties, Greene,
Fayette, and Washington Counties v. Governor Tom Wolf and Rachel Levine,
Secretary of Health for violating the constitutional rights of businesses and
for the subjective process in determining business closures statewide.
 5/7/20 Governor Wolf extends Stay at Home order for Counties in the Red
to June 4th, two days AFTER the scheduled June 2nd primary further
confusing voters, discouraging in-person voting, and challenging Counties’
ability to recruit adequate numbers of poll workers.
 5/12/-5/14/20 Poll Worker Training Occurred over these days with four
sessions, two each morning and two each afternoon and one evening.
Consider the changes since that time prior to the June 2 Primary and all of
the changes that the DOS implemented between the Primary and November
3rd election. The constant barrage of DOS changes made it extremely
challenging for Judges of Elections and poll workers to keep abreast of
accurate information they needed to operate for election day. See attached
letter from a Judge of Election.
 5/2020 the two Republican county commissioners worked feverishly to
equip all 89 precincts with trained poll workers, PPE, and locate new sites
for those closed due to the Covid pandemic and the media narrative
instilling wide spread fear into former poll workers. It was extremely
challenging to get each and every poll open and staffed by those less fearful
and willing to work under these conditions. Many older poll workers could
not work due to compromised immune systems and it caused us to up our
game on recruiting and training new poll workers. i.e. Former precincts
located in churches and schools closed due to the Governor’s stay at home
orders was in conflict with us as elected officials trying to get the public to
understand that elections was a constitutional right and we had to open
facilities for voting.
 The State stated they would send PPE to all the counties for their polling
sites, such as hand sanitizer and masks. Despite that promise, Butler County
went ahead and ordered our own PPE and Plexiglas partitions for the polls
and it is a good thing we did, as the State’s masks and hand sanitizers arrived
the day before the election after we had delivered all the voting equipment to
the polls for the June 2nd Primary.
 Training for poll workers was extremely challenging as per trying to secure a
county site such as a school or facility that would allow us to hold training
during a Covid pandemic and Governor ordered statewide closures.
Thankfully, Butler School District and Cranberry Twp. Municipal Building
each provided us a physical space to hold poll worker and Judge of Elections
trainings. The next challenge was adhering to the Covid compliance while
trying to conduct and provide training with masking and people fearful due
to the nationwide and statewide narrative coming from the news sources. It
certainly created extensive work above and beyond for everyone involved.
 Mid-May, Counties received DOS guidance advising Counties may have drop
boxes and drop off locations. This last minute change was one that the Butler
County Republican Commissioners voted not to implement due to the lack of
security issues. May 31st and onward, Butler County had daily protests across
from the courthouse in Diamond Park and along Main Street by BLM.
 5/29/20 Counties received a court order by the DOS to require accessible
mail in ballots for ADA individuals and to make arrangements.
 5/29/20 Counties received DOS guidance on privacy envelopes. All of these
guidance’s issued by DOS, required all counties to adapt and create changes
with their operations and procedures. Another implication was the inability
to train our poll workers and Judges of Elections due to the late and daily
guidance changes in preparation for and leading up to the June 2nd election.
 5/29/20 DOS issued guidance no longer requiring voter identification for
ballots to be dropped off a drop off sites and drop box locations. Butler
County was requiring ID for ballots being dropped off at the Election Bureau.
 6/1/20 At 6pm Pittsburgh Media News Channels announced publicly that
Governor Wolf used executive order to extend the deadline for receiving mail
in ballots the night before the June 2nd Primary Election. I watched this
announcement in my own living room that evening when I returned home
from being at the county all day working. The Governor never bothered to
reach out to the counties about this during the workday. Governor Wolf also
announced the set up of additional drop boxes for only six of sixty-seven
counties statewide. This strategic move all added to the public’s existing
confusion 12 hours before the June 2, 2020 Presidential Election.
 6/1/20 Governor Wolf also announced on the 6pm television news that
ballots must be post marked by June 2nd, but received no later than June 9th
for some counties, but not all counties. Again, adding additional public
confusion and fear.
 6/3/20 Governor Wolf amended stay-at-home order
 6/5/20 Butler County was one of 12 counties to move to the yellow phase.
 6/10/20 PA General Assembly passed a concurrent resolution directing
Governor Wolf to issue a proclamation or executive order ending his
issuance of the March 6 Covid-19 Disaster Emergency which was renewed
June 3. Governor follows with statement that any concurrent resolution
needs to come to the Governor for approval or disapproval and that orders
will remain in place and that the legislature did nothing to end them.
 6/16/20 Governor Wolf edicts: School Safety & Security Committee and Etc.
 6/25/20 Governor Wolf and Secretary Levine sign 12 counties moving to the
green phase effective the following day.
 6/29/20 Governor Wolf announces that Lebanon County will move to the
green phase of reopening on July 3, putting all counties in green.
 6/29/20 Governor Wolf announces all businesses across PA can apply for
grants to offset lost revenue associated with Covid-19.
 7/1/20 Governor Wolf signs new order signed by Dr. Rachel Levine that
mandates mask wearing directive at all times effective immediately.
 7/`/20 Received state association communications regarding Trump
Campaign and RNC filed law suit pursuant to Governor and DOS Secretary.
 7/9/20 Governor Wolf signs an executive order protecting renters from
evictions or foreclosures in the event they have not received assistance.
 7/10/20 Governor Wolf signs an executive order authorizing state agencies
to conduct administrative proceedings and hearings remotely.
 7/16/20 Governor Tom Wolf releases federal CARES funding to PA Counties
with the exception of Lebanon County who had opened their county despite
the Covid associated closures moving from yellow to green on their own.
 7/16/20 Butler County hires a new Election Director with extensive
technical experience and local experience of working at the polls.
 7/17/20 Federal Court in Pittsburgh, Judge William Stickman IV hears Butler
County v. Governor Tom Wolf and Rachel Levine, Secretary of Health
 7/22/20 Declaratory Judgment Hearing in Federal Court, Pittsburgh by Judge
William Stickman
 7/31/20 DOS announces that the State will provide the entire
commonwealth’s counties with prepaid postage for their envelopes, so voters
would have no excuse for not mailing them. What they didn’t tell county
officials or the public, is typically, prepaid postage is not automatically
postmarked. The State would use federal CARES funding (Covid-19 Relief
Funds) to pay for postage. Postmarks matter to prove voters cast their vote
on time.
 8/14/20 Governor Tom Wolf finally concedes and releases federal CARES
funding to Lebanon County after with holding it for a month. There is a
timeline on these funds to be used before December 30, 2020.
 8/27/20 The DOS contacted counties about additional second round funding
being made available for election system equipment through the $90 million
bond amortization pursuant to Act 77 voting system reimbursements.
 8/31/20 Governor Wolf signed a second renewal of his 90-day disaster for
the Covid-19 pandemic that would extend beyond the November 3, 2020
election.
 9/2/20 DOS contacts all county commissioners announcing that the non-
profit Center for Tech and Civic Life has expanded its Covid response grant
program to offer all local election jurisdictions in the United States to apply
for grants to help ensure staffing, training and equipment for the November
2020 election. The expansion is thanks to a $250 million contribution from
Mark Zuckerberg and his wife, Pricilla Chan, who also made a $50 million
contribution to the Center for Election Innovation and Research, which will
offer additional grants to states. Butler County declined to accept these funds
to protect the integrity of their election system in Butler County from being
influenced by a private/public entity.
 Butler County Election Director informs us that Barbara Smotherman has
been assigned to Butler County as the state election liaison. Deputy
Smotherman is the Deputy Chief of Staff to DOS Secretary Kathy Boockvar.
 9/8/20 Governor Wolf puts out an edict that restaurants must have self-
certification documents in order to open September 21st at 50% occupancy.
 9/11/20 DOS issues guidance concerning examination of absentee and mail-
in ballot return envelopes as well as addressing signatures or lack of.
 9/14/20 Federal Judge William Stickman IV rules that Governor Wolfs
orders violated three clauses of the U.S. Constitution, the right of assembly,
due process, and equal protection clause. Butler County wins suit.
 9/14/20 PA State Supreme Court rules that signature verification on a ballot
Vs the one in the voter’s file no longer matters.
 9/15/20 Governor and Secretary Levine turn up the news narrative on Covid
and Butler County.
 9/16/20 PA Attorney General issues a stay on judicial decision on federal
decision striking down Governor Tom Wolf’s business closures.
 9/17/20 PA State Supreme Court rules ballots mailed back without secrecy
envelopes will not be counted in the general election. Known as “naked
ballots”.

 9/17/20 PA Supreme Court (Democratic Majority) issued the following:
Majority opinion in PA Democratic Party et al. v. Boockvar et al. holding as
follows:
o The Election Code permits county boards of election to accept
hand-delivered mail-in ballots at locations other than their office
addresses including drop-boxes
o Adopts a three-day extension of the absentee and mail-in ballot
received by deadline to allow for the tabulation of ballots mailed by
voters via USPS and postmarked by 8:00 pm on Election Day
o Holds that voters are not entitled to notice and an opportunity to
cure minor defects resulting from failure to comply with statutory
requirements for vote by mail (Yet the DOS made this request on
Election Day to Counties with naked ballots) See: 11/3/20
o Holds that a mail-in elector’s failure to enclose a ballot in a
secrecy envelope renders the ballot invalid
o Finds that the poll watcher residency requirement does not violate
the state or federal constitutions
 Order in Crossey et al v. Boockvar
o Dismisses the request to extend the received-by deadline for mail-
in ballots as moot based on the decision in PA Democratic Party
v. Boockvar
o Dismisses the request that prepaid postage be provided on mail-in
provide funding to county boards of election for postage on mail-in
ballots
o Denies the request that voters be permitted to obtain third-party
assistance in return of mail in ballots
o PA Supreme Court also ruled that the Green Party’s candidate for
president did not strictly follow procedures for getting on
November’s ballot and cannot appear on it, and the Department of
State has now certified the ballot*.
 *What is important for the public to understand that as of 9-17-20,

Counties were unable to print and prepare ballots prior to 9-17-20
due to the lack of a ruling on the Green Party candidate. The ballot
was not state certified until this legal decision occurred. Now, counties
in PA were racing to print their ballots and get them mailed out to all
those who requested mail in ballots which were in the thousands.
 9/24/2020 Commissioner Osche receives email from an overseas
voter in Switzerland who is a dual resident of Butler County who
claims she did not receive her email ballot. The election director
reported that he had communication from the state indicating this
was a “glitch” in the state system related to the secure email. She is a
member of a group called “PA Abroad” and claims suspicion as that
group believes that only Butler and Cumberland Counties did not send
the ballots. After being called out on her reports, she replies that she
did subsequently receive her ballot. And so begins the mass reports of
voters “not receiving” ballots.
 Butler County began to mail out their ballots to mail in requesters
beginning the week of September 28, 2020 and worked 7 days a week
to begin to mail out and simultaneously accept applications. Butler
County continually hired additional temporary staff and extended
hours of service to keep up with all the changes and timelines.
 10/1/20 Governor Wolf issued an executive order amending the
previous order Directing Mitigation Measures, which would go into
effect the following day and would continue to until rescinded or
amended in writing.
 10/8/20 Governor Wolf issues an executive order amending the
previous order related to Directing Mitigation Measures which would
go into effect the following day until rescinded or amended in writing.
 10/8/20 We became aware of a problem originating at the
Department of State in the SURE System, which is the state’s 15-20
year old data election’s system and software. Voters who are
monitoring the status of their ballot online are suddenly seeing it was
mailed out in early September (before the ballot was state certified).
Someone at the state level changed something in SURE early October
that populated the “Ballot Mailed On” date with the same date his or
her application was processed. A similar situation occurred in the
Primary. It’s happened across the state, and both the SURE helpdesk
and DOS are aware of it. This has generated a high volume of calls to
the County of folks monitoring their ballot process online.
 Butler County will come to learn from their Election Director that
there were several glitches with the SURE system preceding the
election.
 Butler County did an extensive mail drop to the U.S. Post Office of
approximately 10,000 ballots October 13, 2020, the day after
Columbus Day which was observed as a national holiday but in which
the elections department worked and another 7,000 mailed out later
that week.
 Week of 10/13/20 Democratic Commissioner hears from Governor’s
Southwest Regional Director about Albert Sensor Technology Pilot
and pushes for our County’s participation to which we again, decline.
 The week of October 19, 2020, the County began to get calls and
complaints by public not receiving their mail in ballot despite
requests made in September. The public was told that the ballots were
not state certified until 9/17 and printed and mailed out until the 28th.
 10/19/20 Election Director reports receiving the following memo
from PA SURE regarding a “system performance” issue where a
permanent mail voter approved for the primary did not have a
general election application or label in SURE. It was determined that
the permanent record was created after and not at the same time that
the record was processed which resulted in no general election
application being created for the voter, therefore the voter received
no mail-in ballot. Counties had no way to identify which voters this
affected.
 Week of 10/19/20, PA Department of Health Officials contact the
County Commissioners informing them they will be coming into
Butler County to set up multiple pop up Covid testing sites throughout
the county to begin Covid testing of up to 440 people at each site free
of charge. This process would begin in two days from the call and site
locations would not be disclosed until they arrived and set up.
Butler County Republican Commissioners pushed back and said NO as
our positivity rate was 3.2% the lowest in Western PA at that point in
time and with zero patients in our local Butler Health System Hospital.
State Dept. of Health staff were insistent and aggressively pushing and
informed us that within a day DOH was planning to release a report to
the public similar to the one they compiled for Centre County. This
report would call for enforcement measures on businesses and state
recommendations, as well as, recommend ways in which the State
wanted us as a County to spend our federal CARES funding. We
delayed DOH’s momentum by insisting that surrounding counties
given their Covid numbers would see greater benefit than Butler
County and are a better use of tax dollars. We had a follow up call on
October 26th and when the conversation initiated again, DOH was told
this was nothing more than a political attempt to come into Butler
County, drive up numbers via testing, and put out a report that
misleads our county with misinformation when our positivity rate is
only 3.2% in contrast to other counties, such as Westmoreland that
had three times our numbers. We communicated that they were
attempting to create more chaos in our county to suppress voter
turnout by instilling fear and misinformation. We clearly called them
out telling them this was political. We suggested they place their pop
up site on Slippery Rock University’s campus if they were so moved by
trying to help their students? Dept. of Health declined and wanted
testing sites implemented throughout the county in undisclosed sites.
We communicated the upcoming Election was the county priority at
that point in time given our extremely low Covid numbers based on
the DOH’s state dashboard of statewide data.
 10/22-23/20 Butler County fielded ten thousand calls over the course
of weeks leading up to the election from people saying they did not
receive their mail in ballot. Hired six additional people to set up a
county phone bank ASAP. Worked 18-hour days to call back each and
every voter to provide options so they could exercise their right to
vote. This included mailing new ballots and voiding the originals and
in some cases, over-nighting out of state applicants. We also had
sheriff deputies deliver ballots to disabled and to those shut in their
homes with no recourse. The majority came to the Election Bureau
and cast their vote in person via a new mail in ballot. Lines began to
form from that day on and we extended our evening hours to
accommodate those who worked beyond normal business hours and
had weekend hours available on Saturdays.
 10/26/20 DOS contacts Butler County Election Director of numerous
complaints made to DOS and delay of mail concerns specifically for
Butler and York County ballots mailed out two weeks ago. DOS, even
communicating that Governor Wolf and his wife’s ballots were
delayed in the York County mail system arriving a week apart from
one and other. 50 minutes later, Western PA USPS Manager Jason
Graney requests for our Election Director to call him to discuss
matter.
 10/26/20 Butler County Election Director reports to the Butler
County Commissioners that same day, Mr. Graney will investigate the
matter with the US Post Office.
 10/26/20 Continue to field calls from the public and work to enable
them to vote by presenting one of four options: going to polls, coming
to Election Bureau, mailing a new ballot and voiding the original, or
over-nighting out of state or to a college or hospital. In the latter days
of that same week leading up to the election, people were still calling
to say they had not received our new ballot or over-night ballot in the
mail. We checked to verify their mailing and confirm with callers, that
the new ballots were mailed. Confirmed that they were mailed or
over-nighted.
 Throughout this process, we are still receiving a high volume of
requests for mail ballots, many of which are duplicate requests due to
the high number of third party mailers voters are receiving at their
homes, which is making them, think that their request was not
processed. In addition, because of another glitch in the state’s SURE
system, people are not seeing their ballots being recorded in a timely
fashion. This is yet another issue that is consuming staff time and
slowing down the mail process.
 Butler County did not use a third party mailing company, as we
believe the chain of custody of these ballots is critical. We have a
check and balance system in place to be sure that all voters are
receiving the correct ballot for their district and/or precinct. We have
hired twenty additional temporary staff to assist.
 10/23/20 Commissioners meet with the Sheriff, District Attorney, and
Emergency Services Director to finalize security plan for the county at
the polling locations and review our safety plan.
 10/23/20 ACLU serves the County Elections with a cease and desist
order pertaining to our requiring ID when voters turn in ballots at the
Election Bureau located in the Government Center on Friday, the 23rd,
after work hours. They set a deadline for Monday for a response.
 10/23/20 PA Supreme Court rules that a voter’s absentee or mail in
ballot cannot be rejected based solely on a comparison of the
signature on the ballot with the voter’s signature on their registration
form. The ruling came as a result of a King’s Bench petition by Kathy
Boockvar Secretary of Commonwealth and Elections who used this as
a mechanism to get counties to comply as she was struggling with
challenges by counties as per guidance vs. law.
 10/23/20 PA Supreme Court ruled against President Trump and the
RNC challenging Secretary Boockvar’s interpretation of the election
code.
 10/26/20 Voter Intimidation Guidelines sent by Ali Doyle of
Southwest Deputy Director to Governor Wolf
 10/26/20 Ironically, we received hundreds of intimidating calls about
counting “all votes” beginning November 3rd in lieu of November 4th
that was inaccurately portrayed by Progress PA and Ben Forstate’s
inaccurate maps depicting Butler County as the only county in
Western PA not counting votes until the day after Election Day.
Several numbers coming from a call bank located in Pittsburgh and
Northeastern PA were pushing out text messages and social media
messages. People statewide were reacting to these messages and
harassing our office staff and two Republican Commissioners making
demands and threats. Progress PA had our names and phone numbers
posted on their Facebook page instructing people to call and pressure
the two Republican Commissioners, County Solicitor, and Office
Assistant by name and instructed them to “take no prisoners”. This is
a tactic of technology and there is no recourse for providing accurate
information, as that is not the goal. This tactic demonstrated to me
how technology and external entities could be used in influencing the
election’s system, adding to chaos and distraction. Despite that
difficult day, we “knew the game being played” and we stayed focus
on what really mattered.
 10/28/20 PA State Supreme Court rules that the time frame for
submitting ballots would be extended three days after the election as
long as there was a postmark, and if any ballots arrive post election
without a postmark, it should be assumed that ballot was cast on time.
So, why the rule of a postmark if not now necessary? Or even
followed? Please see 7/31/20
 10/28/20 DOS sends clarifications on Examinations of Absentee and
Mail-In Envelopes and ID Verification for Ballot Requests
 10/28/20 DOS sends guidance on Voter ID Not Required for
Verification for ballots handed into polling sites and drop boxes
 10/28/20 DOS sends voter ID requirements
 10/30/20 DOS sends PA Election Day Communication
 10/31/20 Secretary Boockvar sends out Important Election Day
Reminders
 11/1/20 DOS sends guidance on canvassing and segregating ballots
received post election day.
 11/2/20 Butler County held an afternoon poll worker training.
 11/2/20 DOS requesting mock elections to test election results
import process. Again, Butler County declined. Another tactic.
 11/3/20 On Election Day, DOS issues guidance on voters in
quarantine related to Covid.
 11/3/20 On Election Day, mid day, DOS contacts Election Director and
County Solicitor asks if the commissioners want those who submitted
naked ballots (ballots with no secrecy envelope) to be provided to
each political party, so those parties can contact individuals to redo
ballot, so it can be counted? Pennsylvania is the first and only state to
disqualify ballots received without a required secrecy envelope giving
voters no recourse to fix the mistake. Some PA counties allowed this
and others did not. It was not consistent statewide.
 11/3/20 On Election Day, Butler County’s 850 ES&S High-Speed
Scanner breaks and cannot be repaired by a state certified technician.
It is brand new, $100,00 machine has only been used once for the June
2nd Primary Election.
 11/3/20 On Election Day, We field multiple calls throughout the day
requesting tallies and turn out from the State. We provide DOS no
information other than to tell them our scanner is down. Our county
election team works all day into the night to address scanning without
the bigger scanner by using smaller scanning devices.
 11/3/20 On Election Day, many of our polling locations are running
out of ballots, as many people showed up surrendering their mail in
ballot and wanting to vote. The costs associated with the mail-in
debacle have to be exorbitant due to the fact we are printing each
person with an additional ballot who does this? Pennsylvania
taxpayers should be furious and demanding better.
 11/4/20 The day after the election we begin to field multiple calls
from people demanding their ballots to be counted that are received
after 8pm on Election Day threatening to call the ACLU & Authorities.
 11/4/20 We announce on the 6pm news stations that Butler County is
going to segregate ballots coming in after 8pm on Election Day on a
daily basis and we are not going to open them, and keep them safe and
secure until we receive further guidance from the DOS, to which we
were promised ahead of time we would receive, but, had not.
 11/5/20 DOS reissues guidance on ballot segregation requiring ID
verification
 11/5/20 Based on the news interviews of 11/4/20, people again
begin demanding “all ballots to be counted” and for them to be
integrated into the official tabulations. Again, we press back. Many of
whom I spoke from, were not even from Butler County. Callers were
simply reacting to text messages pushed out by anomonyous call
centers and social media postings.
 11/5/20 Commonwealth Court Order petitions requiring segregation
of all provisional ballots cast on Election Day by voters who also
submitted a timely mail-in or absentee ballot. These court ordered
segregated ballots would be subject to review and validation.
 11/6/20 Justice Alito issues Order that any ballots received after 8pm
on Election Day in PA be segregated and secured and if counted,
counted separately. There is a petition before SCOYTUS. Alito orders
opposing side to reply by 2pm Saturday, November 7.
 Third Party entities and major political parties such as the Center for
Voter Information purchased older, county voter rolls and mailed out
mass distribution via the USPS thousands of unsolicited ballot
applications to households and individuals. These mass mailings went
to deceased voters, to former homeowners of a current homeowner,
and to unregistered voters, to name a few scenarios. In some
instances in Butler County, individuals filled out up to 15 different
voter applications requesting a mail ballot per person. Each one of
these 15 requests for a mail in ballot has to be processed through
checks and balances for verification and to prevent duplication, as if it
is the only and original request. These third party mailing entities also
are generating hundreds of additional phone calls and taking time
away from those applications needing to be processed. Adding insult
to injury, often times, these third party entities utilize the County’s
Bureau of Election’s return address as printed on the envelope in lieu
of their own. This is misleading to the recipient who is led to believe
that our county is mass distributing these mailers out? Taxpayers are
led to believe we are using tax dollars to mail these mailers out, they
are calling to verify that they are already registered as a voter and
have been for years? This tactic is costing our taxpayers enormous tax
dollars through time, effort, and manpower and distracting counties
away from the focus of addressing applications in a timely and
efficient manner. These same mailers have added to the confusion and
anxiety of every voter wanting to do the right thing and that is,
exercise their right to vote. This is a real problem that needs to be
addressed.
 Finally, the US Postal Service needs to be addressed for the delay of

processing and delivering mail in a timely and efficient manner. Butler
County voters experienced many delays in receiving and returning
ballots that took up to three to four weeks one way. This created
thousands of phone calls. We have many accounts of ballots being
mailed at the Butler Post Office across the street from the Bureau of
Elections housed in Government Center that took 3-4 weeks and
sometimes not at all to be returned to the Election Department. When
inquired about, we were told they were considered “lost” in the mail
system.
 This timeline is not inclusive of all the Governor’s Orders pertaining to
the Red-Green, and Yellow Phases and Business Closures.
Evidence seems to point to a deliberate attempt to create confusion for voters and
local election officials including local Judges of Elections, and to delay ballot delivery
to voters through SURE system issues, social media campaigns that encouraged voters
to flood election bureaus with phone calls and emails, and early voting in election
offices, all which hindered getting mail ballots to voters and forcing our office to
cancel many initial mail ballots and issue new ballots. I can’t say what happened in
other Counties, but it appears Butler County may have been specifically and
deliberately targeted by the state in this effort.
The Counties lack of control over mail ballots once they leave our chain of custody is
problematic as we have no way of truly knowing what happens with that ballot before
it comes back to the bureau. While there has always been absentee balloting, perhaps
the early voting process provides a better solution than no-excuse mail since it is done
in-person. Voting by mail, while intended to increase access, unfortunately creates an
opportunity for those in power to manipulate and take advantage of vulnerable
populations since we truly cannot ensure that it takes place without influence or
intimidation. Empowering all to seek the truth about elections and candidates and to
exercise their right to vote in-person as much as possible should be our message to
“disenfranchised” voters. It means that they get to feed their own vote into the
scanner and essentially watch it be tallied, vs. relying on someone else to scan your
ballot into the system or losing chain of custody of your own ballot. Pennsylvania has
a lot of explaining to do and even more work to do to protect future elections from this
embarrassing debacle.
Leslie Osche
Chairman, Board of Commissioners
Butler County, PA
A Simple Test for the extent of Vote Fraud with Absentee Ballots in the 2020 Presidential
Election: Georgia and Pennsylvania Data
Revised
November 20, 2020
Summary
This study compares the precincts of Fulton county that are adjacent to similar precincts in
neighboring counties that had no allegations of fraud, in order to isolate the impact of Fulton
county’s vote-counting process (including potential fraud). In measuring the difference in
President Trump’s vote share of the absentee ballots for these adjacent precincts, we account
for the difference in his vote share of the in-person voting and also the difference in
demographics of registered voters. The best estimate shows an unusual 7.81% drop in Trump’s
share of the absentee ballots for Fulton County alone of 11,350 votes, or over 80% of Biden’s
vote lead in Georgia. The same approach is applied to Allegheny County in Pennsylvania for
both absentee and provisional ballots. The estimated number of fraudulent votes from those
two sources is about 65,000 votes.
I. Georgia
In Georgia’s certified ballot count, former Vice President Joe Biden leads President Trump by
12,670 votes.1 Biden won Fulton County by a margin of 243,904 votes, and the absentee ballots
in the county by 86,309 votes.
Part of the controversy with Fulton County’s absentee ballots arises from a burst pipe that
resulted in the removal of poll watchers. According to the Chair of the Georgia Republican
Party, David J. Shafer, “counting of ballots took place in secret after Republican Party observers
were dismissed because they were advised that the tabulation center was shutting down for
the night” (Letter dated November 10, 2020 from Doug Collins and David Shafter to Georgia
Secretary of State Brad Raffensperger, p. 3).
If election workers counted absentee ballots when Republican observers were not present, is
there statistical evidence of bias in the absentee ballots counting? While in-person voting took
place at the precinct level, absentee vote counting took place at one common facility at the
county level. If the type of fraud that Mr. Shafer worries about occurred, it would have only
affected the absentee ballots in Fulton County.
To examine that, I looked at precinct-level data for Fulton County and the four Republican
counties that border it and no fraud has been alledged: Carroll, Cherokee, Coweta, and Forsyth.
The idea is a simple one: compare Trump’s share of absentee ballots in precincts adjacent to
each other on opposite sides of a county border. The comparison is made between precincts in
Fulton and these four other counties as well as between precincts in these four counties where
they are adjacent each other. Comparing a county were fraud is alleged to ones without fraud is
simpler than comparing counties where there might be varying degrees of fraud.
Precincts adjacent to each other on opposite sides of a county border should be relatively
similar demographically. In one case, Fulton County precinct ML02A matches up with four
different precincts in Cherokee County (Mountain Road 28, Avery 3, Union Hill 38 and a small
portion of Freehome 18). The goal is to compare the precincts of Fulton county that are most
similar to precincts nearby counties that had no allegations of fraud, in order to isolate the
impact of Fulton county’s vote-counting process (including potential fraud).
The analysis also accounts for the percent of in-person votes that went for Trump, because if
you have two adjacent precincts and they are similar in terms of their in person voting, one
would expect them to also be similar in terms of their absentee ballots.
I did this test using the data from both 2016 and 2020. There were no serious accusations of
fraud with respect to absentee ballots in 2016, so one should expect the absentee ballot
1
“US election 2020: Biden certified Georgia winner after hand recount,” BBC, November 20, 2020
(https://www.bbc.com/news/election-us-2020-55006188).
percent for Trump in precincts in Fulton county to behave no differently than the adjacent
precincts in Carroll, Cherokee, Coweta, and Forsyth.
The results in Table 1 show that in 2016, there was indeed essentially no difference (less than 1
percentage point) between Trump’s share of absentee ballots cast in Fulton and other
counties.2 Trump’s share of absentee ballots also matched up closely with his share of in-person
votes across the precincts, no matter which county they lay in.
However, redoing the same test for 2020 shows something quite different (see Table 2).
Trump’s percentage of absentee votes was now lower in Fulton county border precincts than in
the precincts just across the street in neighboring counties. Trump’s share was 7.19 percentage
points lower on the Fulton county side, and the difference was also statistically significant at
the 7% level for a two-tailed t-test.
This is not likely to have been caused by the general shift to absentee voting among Democrats,
because the study controlled for in-person voting. In layman’s terms, Fulton precincts that had
similar in-person Trump vote shares (compared to precincts in neighboring counties) showed
depressed Trump absentee vote shares.
In the table below, If the estimate for the “Difference in Trump’s percent of the two-candidate
in-person vote” between the two adjacent precincts equals 1, it means that the differences in
the percent of the in-person vote Trump received in the adjacent precincts would perfectly
track the difference in the absentee ballots. In the estimate for 2016, the coefficient of 0.87 is
not statistically different from 1. Importantly, for the 2020 data, Trump’s share of in-person
votes did not line up as closely with the differences in absentee ballots, as can be seen in the
reduced coefficient of the control variable for Trump’s share of in-person votes. Indeed, the
coefficient for 2020 is statistically significantly less than 1 at the 0.0000% level for a two-tailed
t-test.
Although neighboring precincts are expected to be fairly similar to each other by virtue of
location and the difference in in-person votes should pick up other remaining differences, this
study goes further and controls for demographic variables, to account for any differences that
might still exist. Georgia collects information on registered voters’ racial and gender
demographics by precinct in 2020 to further account for differences in precincts. Table 3
accounts for the differences in the adjacent precincts by replacing the change in the in-person
difference in Trump’s share of the votes with detailed demographic information. They provide
information on the difference between the precincts in the percent of the population that are
black males, black females, Hispanic males, Hispanic females, Asian males, and Asian females.
Table 4 then not only includes those variables but then also again the “Difference in Trump’s
percent of the two-candidate in-person vote.” Thus, this estimate uses three ways to account
for differences in Trump’s share of the absentee ballot vote: geographic closeness for relatively
2
The source for the 2016 precinct border lines was obtained here: http://rynerohla.com/index.html/election-
maps/2016-south-atlantic-republican-primaries-by-precinct/
small areas, differences in Trump’s share of the in-person vote, and differences in the
demographics registered voters.
The results provide consistent estimates that Trump’s percentage of absentee votes was
consistently lower in Fulton county border precincts than in the precincts just across the street
in neighboring counties. The estimates for the Fulton County effect range from 5.8% to 17.3%
and again are all statistically significant. The variables for the race and gender demographics
are virtually never statistically significant, though that is not particularly surprising given how
highly correlated these variables are. That also makes it difficult to interpret individual
coefficients on the demographic variables. However, they are statistically significant as a group
(a joint F-test for the demographic variables shown in Tables 3 and 4 finds they have F-values of
4.53 and 4.23, respectively, which are both statistically significant at about the 1 percent level).
This indicates that the demographic values are worth including, and that table 4 is the preferred
model. But all models agree that Trump’s absentee ballot share was depressed in Fulton County
precincts.
Given that there were 145,267 absentee ballots cast for Trump and Biden in Fulton county,
even the lowest estimate of the unusual drop off in Trump’s share of the absentee ballots for
Fulton county of 5.84 percentage points equals approximately 8,280 votes, or 59% of Biden’s
margin of victory over Trump. There are concerns about vote counting in DeKalb county, but
there are no Republican counties adjacent to it for me to use in a test. However, with 128,007
absentee ballots cast for the two major-party candidates in DeKalb, a similar 5.84 percentage
point swing for Biden would account for another 7,482 votes. Together this margin in DeKalb
and Fulton would more than account for Biden’s winning vote share. Indeed, their total of
15,762 would be larger than Biden’s certified win.
If there were also fraud in terms of the in-person voting in Fulton County that worked to also
help Biden, the estimates presented here will underestimate the amount of fraud with the
absentee ballots.
Using the average value for these various estimates (7.81%) shows that an unusual drop in
Trump’s share of the absentee ballots for Fulton County alone of 11,350 votes, or 90% of
Biden’s vote lead in Georgia. These adjacent precincts show a large drop in Trump’s percent of
the absentee ballots in Fulton County after comparing precincts that are on opposite sides of a
street and accounting for the percentage of the in-person vote that Trump received in those
precincts and even race and gender demographics.
II. Pennsylvania
In Pennsylvania’s initial ballot count, former Vice President Joe Biden leads President Trump by
81,361 votes. Biden won Allegheny and Philadelphia Counties by margins of 146,706 and
471,305 votes, and the absentee vote margins in the county were 206,505 and 310,553 votes.
There was also an usually large number of provisional votes in those counties, with Biden
leading by 1,489 and 9,045, respectively.
A number of concerns are raised about possible vote fraud in both counties. Republican poll
watchers have complained that they were too far away from the ballots to meaningfully
observe the process.3 The president’s lawyers say that in Pittsburgh and Philadelphia voters
with invalid mail-in/absentee ballots received a notification and were allowed to correct that
defect by using a provisional ballot on Election day, whereas election officials in Republican-
leaning counties followed election law more strictly and did not give similar notifications to
voters with invalid mail-in/absentee ballots.4 Complaints also arose from voters being required
to cast provisional votes because they were identified as having requested a mail-in ballot even
though the voter claimed that they had not done so.5 That raises concerns that someone else
other than the registered voter may have voted that person’s absentee ballot.
While there are sworn affidavits attending to these problems, an open question has been
whether the level of problems was significant enough to alter the election outcome.
To examine that, I used the same approach with precinct-level data that I did for Georgia. I
collected data from adjacent precincts in Allegheny County and the four Republican counties
that border it: Beaver, Butler, Washington, and Westmoreland. The comparison is made
between Allegheny and these four other counties as well as between these four counties where
they are adjacent each other. However, unlike Georgia, I could only obtain the breakdown of
absentee and provisional voting for Allegheny County in 2020, so these estimates will look at
only the relationship in that year. While large scale fraud is alleged in Philadelphia County,
there are no Republican counties adjacent to it for me to use in a test.
The results in Table 5 show that in 2020, Trump’s percentage of absentee votes was lower in
Allegheny County border precincts than in the precincts just across the street in neighboring
counties. Trump’s share was 4.2 percentage points lower on the Allegheny County side, and the
difference was also statistically significant at the 4.4% level for a two-tailed t-test. This is about
half the size of the gap found in Georgia, but that still represents a net overrepresentation of
14,141 votes for Biden in Allegheny County. If that rate applies to Philadelphia County, that
would represent another 15,363 votes for Biden. If the Republican claims are correct about
Centre, Chester, Delaware, Montgomery, and Northampton Counties and that rate remains at
4.2 percentage points, their 622,443 absentee ballots between Biden and Trump would imply
3
Shan Li and Corinne Ramey, “What Are Election Observers? Role at Crux of Trump Lawsuits in Pennsylvania,” Wall
Street Journal, November 10, 2020 (https://www.wsj.com/articles/what-are-election-observers-the-role-at-the-
crux-of-trump-lawsuits-in-pennsylvania-11605053759). Daniel Payne, “Pennsylvania poll watcher: 'We literally had
no input and no ability to watch anything',” Just the News, November 9, 2020 (https://justthenews.com/politics-
policy/elections/pennsylvania-poll-watcher-we-literally-had-no-input-and-no-ability-watch).
4
Rudy Giuliani, “Trump Campaign News Conference on Legal Challenges,” C-SPAN, November 19, 2020
(https://www.c-span.org/video/?478246-1/trump-campaign-alleges-voter-fraud-states-plans-lawsuits).
5
Complaint filed in Trump v Boockvar et al in the United States District Court for the Middle District of
Pennsylvania (p. 48).
another 25,914 votes. Combined, that indicates Biden got a total of 55,418 extra votes that are
attributable to the difference in county election methods.
To the extent that one believes that there is fraud in in-person voting, the estimates here will
underestimate the amount of fraud in absentee ballots.6
Because of aforementioned concerns with provisional ballots being offered to solve problems
with absentee ballots in Allegheny and Philadelphia Counties, I also used the same test to we
have been using to examine them.
Table 6 is the same as Table 5, except it applies to provisional, rather than absentee, votes.
While the estimate is quite large, implying a 12.5 percentage point lower rate for Trump in the
adjacent precincts in Allegheny County, the result is not statistically significant. But there is a
simple reason for this. There are a lot fewer observations as 50 of the 84 observations have no
provisional ballots for Trump and, since one cannot divide by zero, those observations are not
defined.7
Another way to look at the problem that avoids the loss of these observations is to look at the
rate that provisional ballots were used in Allegheny versus the Republican counties. In that
case, there is a very clear difference. 1.5% of the votes in Allegheny’s border precincts involve
provisional ballots, which is 3.2 times the 0.48% in the adjacent precincts in the surrounding
counties, and that difference is statistically significant at more than the 0.1% level for a two-
tailed t-test.8
Finally, Table 7 looks at the difference in the percent of Biden’s votes from provisional in the
adjacent precincts even after accounting for the same difference for Trump. The share of
Biden’s votes from provisional ballots is about 0.96 percentage points higher in Allegheny
County than in the adjacent precincts. Again, as a control, I tried running this for Georgia. Given
that the claim about warning voters to correct defects in absentee by using a provisional ballot
was not applicable to Georgia, one would not expect a statistically significant result for that
state. Indeed, those results indicate that for Fulton County the effect was extremely tiny – just
1/20th of the size of the coefficient for Allegheny County – and was statistically insignificant
6
Republicans argue that there is some reason for concern. Pennsylvania has had convictions as recently as this
year in Philadelphia where a Philadelphia Judge of Elections was charged with election fraud for allegedly stuffing
ballot boxes on behalf of Democratic candidates in three different races (Katie Meyer, “Philly judge of elections
pleads guilty to election fraud, accepting bribes,” WHYY NPR, May 21, 2020 (https://whyy.org/articles/philly-judge-
of-elections-pleads-guilty-to-election-fraud-accepting-bribes/).). The president’s lawyer, Rudy Giuliani, has also
claimed that people from New Jersey illegally voted in Philadelphia (Rick Sobey, “Rudy Giuliani claims Trump
campaign has found nationwide Democrat voter fraud conspiracy plot,” Boston Herald, November 19, 2020
(https://www.bostonherald.com/2020/11/19/rudy-giuliani-trump-campaign-has-found-nationwide-voter-fraud-
conspiracy-plot/)).
7
I also ran this regression using the Georgia data, but there were so few places with provisional ballots there were
only 12 observations and the Fulton County Effect variable was omitted from the regression.
8
The rate is slightly higher for the entire county: 1.98%.
with a t-statistic of only 0.47.
Adding the results together, there are at least 65,400 extra ballots given to Biden. To the extent
that there is also some fraud in in-person voting, it is plausible that this total is roughly similar
to Bidens margin in Pennsylvania.
Conclusion
The benefit of this approach is that it allows us to quantify how large is potential problem vote
fraud and other abnormalities might be in the 2020 election, and it is applicable to other states
where precinct-level data is available.

tailed t-test
percent of the two-
candidate in-person
vote between two
precincts
Intercept -0.014329 0.25 0.806

0.0000

tailed t-test
percent of the two-
candidate in-person
vote between two
precincts
Intercept 0.0632825 2.11 0.048

0.0000
Racial and Gender Demographics of Registered voters

tailed t-test

are black males
are black females

are Hispanic males

are Hispanic females

are Asian males
are Asian females
Intercept 0.10648 2.29 0.038

0.0008
Racial and Gender Demographics of Registered voters and the difference in the in-person
vote
Control variables Coefficient Absolute t- Level of statistical significance
statistic for a two-tailed t-test
percent of the two-
candidate in-person vote
between two precincts

males
females

males

females

males
females
Intercept 0.0717792 3.00 0.010

Number of Observations F-statistic = 30.85 R-Squared
22 Level of significance = - 0.9500
= 0.0000
Counties
tailed t-test
percent of the two-
candidate in-person
vote between two
precincts
Effect
Intercept 0.0447211 2.37 0.020
0.0000
Table 6: 2020 Difference in Trump’s share of the Provisional Ballots between adjacent
Counties
tailed t-test
percent of the two-
candidate in-person
vote between two
precincts
Effect
Intercept 0.088098 0.66 0.514
0.1036
Table 7: 2020 The Difference in the share of Biden’s votes from provisional ballots in
adjacent precincts
A) Examining Allegheny, Beaver, Butler, Washington, and Westmoreland Counties

tailed t-test
share of Trump’s
votes from
the two adjacent
precincts
Effect
Intercept -0.0009996 0.27 0.790
0.0020
B) Examining Fulton, Carroll, Cherokee, Coweta, and Forsyth Counties
share of Trump’s
votes from
the two adjacent
precincts
Effect
Intercept 7.26e-06 0.01 0.994

0.0000
From: Trutanich, Nicholas (USANV)
To: Donoghue, Richard (ODAG)
Subject: RE: NV GOP Letter
Date: Friday, November 6, 2020 12:38:01 PM
Attachments: Gloria 110520.pdf
Barr 110520.pdf
nv moved raw file.csv
image003.png
Rich,

Attached are two letters from Shana Weir (addressed to the Attorney General and Clark County’s
lawyer, Mary-Anne Miller, respectively), as well as the spreadsheet that accompanied the letter to
the AG . Please let me know if anything else would be helpful. Thanks very much.

Best,
Nick
Nicholas A. Trutanich
U.S. Attorney for the District of Nevada

501 Las Vegas Blvd S, Ste 1100 | Las Vegas, NV 89101

From: Donoghue, Richard (ODAG) <(b) (6)
Sent: Friday, November 6, 2020 8:57 AM
To: Trutanich, Nicholas (USANV) (b) (6)
Subject: NV GOP Letter

Nick,

I hope all is well and that you are surviving the chaos.

Can you send me whatever the NV GOP submitted as “criminal referral” relating to the purported
voter fraud? Obviously, we see the reporting but I haven’t seen the actual document.

Thanks,

Rich

Richard P. Donoghue
Principal Associate Deputy Attorney General
Office of the Deputy Attorney General
(b) (6)

November 5, 2020
Via Email
Mary-Anne Miller, Esquire

500 S. Grand Central Parkway
Las Vegas, NV 89106
(b) (6)
Re: Mail Ballots Received from Thousands of Ineligible Voters
Dear Ms. Miller
This firm, in conjunction with Harvey & Binnall, PLLC represents Donald J. Trump for
President, Inc. As you know we have been concerned for months about improper ballots being
cast in the 2020 general election. Yet, Joseph Gloria has yet to take any reasonably basic and
fundamental steps to ensure that mail ballots are free from fraud and abuse. His inaction has had
and continues to have material adverse consequences on our election security; we have
confirmed that thousands of votes have been cast improperly. Indeed, we have initially identified
3,062 voters who moved from Nevada before the election but still cast ballots in this election.
We have verified this by cross-referencing the list of general election voters with publicly
available change of address records. For instance, demographic experts agree that the National
Change of Address database only captures about one-third of relocations. Consequently, this
number will likely grow by 6,000 voters, at a minimum. As you know, voter fraud is a serious
crime, under federal and state law and these fraudulent ballots call into question the legitimacy
and integrity of the entire Nevada general election. This is a direct result of Mr. Gloria’s lax
procedures for authenticating voter identity and his negligent maintenance of voter rolls.
Had Mr. Gloria’s office used proper and generally accepted procedures to authenticate
these ballots and clean the voter rolls on the front end, then these illegal votes would never have
permeated into the voter pool, diluting the votes of honest Nevadans. That is why it is imperative
that he take immediate action to clean the voter rolls and purge them of all ineligible voters,
including those that have moved from Nevada and those that have died. Moreover, he should
immediately cease authenticating and separating mail ballots until the rolls are cured and take all
possible measures to cull improper ballots from the 2020 general election voter pool.
We have enclosed the change of address information for the voters we have already
identified. Please take care to ensure that this data is not improperly disseminated. also promptly
respond by explaining what steps Mr. Gloria will take to ensure that no further ballots from
ineligible voters will be tabulated. The time critical nature of this request is self-evident.
Sincerely,
Weir Law Group, LLC
/s/ Shana D. Weir
Shana D. Weir
Jesse R. Binnall
cc: Hon. William Barr

Hon. Christopher Wray
Hon. Nicholas A. Trutanich

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What concerns does the study aim to address?

What concerns does the study aim to address?

What methodology does the study use to measure potential fraud?

What methodology does the study use to measure potential fraud?

A Simple Test for the extent of Vote Fraud with Absentee Ballots in the 2020 Presidential

Election: Georgia and Pennsylvania Data

John R. Lott, Jr., Ph.D.*

Electronic copy available at: https://ssrn.com/abstract=3756988

Electronic copy available at: https://ssrn.com/abstract=3756988

Electronic copy available at: https://ssrn.com/abstract=3756988

Electronic copy available at: https://ssrn.com/abstract=3756988

Electronic copy available at: https://ssrn.com/abstract=3756988

Electronic copy available at: https://ssrn.com/abstract=3756988

Electronic copy available at: https://ssrn.com/abstract=3756988

Electronic copy available at: https://ssrn.com/abstract=3756988

Electronic copy available at: https://ssrn.com/abstract=3756988

Electronic copy available at: https://ssrn.com/abstract=3756988

Electronic copy available at: https://ssrn.com/abstract=3756988

Electronic copy available at: https://ssrn.com/abstract=3756988

Electronic copy available at: https://ssrn.com/abstract=3756988

Electronic copy available at: https://ssrn.com/abstract=3756988

Electronic copy available at: https://ssrn.com/abstract=3756988

Control variables Coefficient Absolute t-statistic Level of statistical

Intercept -0.014329 0.25 0.806

Control variables Coefficient Absolute t-statistic Level of statistical

Intercept 0.0632825 2.11 0.048

Electronic copy available at: https://ssrn.com/abstract=3756988

Control variables Coefficient Absolute t-statistic Level of statistical

Difference in the -1.9175 1.36 0.195

Difference in the -1.4117 0.53 0.602

Difference in the 2.0844 1.32 0.208

Difference in the -0.4588 0.27 0.791

Intercept 0.10648 2.29 0.038

Electronic copy available at: https://ssrn.com/abstract=3756988

Difference in the percent -0.94517 1.31 0.214

Difference in the percent -0.55649 0.42 0.683

Difference in the percent 2.09435 2.64 0.020

Difference in the percent -0.2352 0.28 0.787

Intercept 0.0717792 3.00 0.010

Electronic copy available at: https://ssrn.com/abstract=3756988

Electronic copy available at: https://ssrn.com/abstract=3756988

A) Examining Allegheny, Beaver, Butler, Washington, and Westmoreland Counties

Allegheny County 0.010184 2.27 0.026

Intercept -0.0000357 0.06 0.950

Number of F-statistic = 23.60 R-Squared = - 0.7130

Electronic copy available at: https://ssrn.com/abstract=3756988

Electronic copy available at: https://ssrn.com/abstract=3756988

Electronic copy available at: https://ssrn.com/abstract=3756988

Electronic copy available at: https://ssrn.com/abstract=3756988

Electronic copy available at: https://ssrn.com/abstract=3756988

Electronic copy available at: https://ssrn.com/abstract=3756988

Acting Deputy Attorney General Richard Donoghue

Dear Honorable Donoghue:

Several of the key findings are delineated below:

Testimony provided at a Senate hearing from witnesses in Philadelphia, Northampton, Luzerne,

(b) Delayed opening or closing of polling locations on Election Day;

(c) Improper forfeiture and spoiling of mail-in ballots;

(d) Illegal ballot harvesting;

(e) Improper “curing” of insufficiently completed mail-in ballots;