UNITED STATES SUPREME COURT

JURISDICTION AND VENUE . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . PAGE 3

PARTIES . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . PAGE 3

INTRODUCTORY STATEMENT . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . PAGE 3

STATUTARY AUTHORITY . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . PAGE 12

CONCLUSION . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . PAGE 15

REQUEST FOR RELIEF. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . PAGE 15

JURISDICTION AND VENUE

Plaintiff is requesting the Court to issue – a Temporary Restraining Order – to postpone the 2004 presidential election by 30 days.

This court has Original Jurisdiction of this action under Article III of the U.S. Constitution. There is no other court that has the authority to postpone a federal election nationwide. This case is brought under the Fourteenth Amendment and 42 U.S.C. §1983.

Venue is proper because a substantial part of the events or omissions giving rise to the claims herein occurred in this country, and because Defendant resides in this country.

PARTIES

Plaintiff LYNN E. LANDES is a resident and registered voter of the City and County of Philadelphia and a citizen of the United States. She is one of the nation’s leading journalists in the field of voting systems and democracy issues.

Defendant THE UNITED STATES is the government that is responsible for the passage and enforcement of laws regulating federal elections and protecting the voting rights for all citizens. U.S. Attorney General Ashcroft is the party whose job it is to defend The United States in federal court.

INTRODUCTORY STATEMENT

1. This nation is in a constitutional crisis. On November 2^nd, there will be no material way to prove which candidate really won. There will be no material way to know if Americans or foreigners counted our votes. There will be no material way to know if many votes were counted at all.

2. The Plaintiff has the right to a free, fair, and transparent election, which includes the right to vote and to have votes counted properly. Plaintiff made a good faith attempt to go through traditional legal channels and filed two Complaints against the use of: 1) voting machines, and 2) absentee voting on July 2, 2004 in the United States District Court for the Eastern District of Pennsylvania. She marked the box to have her case expedited. However, the Court granted time extensions until October 7, 2004. Counsels for the defendants (City Commissioner Margaret Tartaglione, Secretary of the Commonwealth Pedro Cortes, and U.S. Attorney General John Ashcroft) filed motions to dismiss, the last motion was filed on October 7^thby counsel for Defendant Ashcroft. Plaintiff filed a temporary restraining order. She got a same-day hearing from Judge Kauffman who was handling the “absentee ballot” case, (he dismissed it outright). Plaintiff filed an appeal to Judge Kauffman’s denial, but the Court took several days to respond. Plaintiff has not had a hearing from Judge O’Neill on either the original Complaint or the TRO. It has become all too apparent that time has run out on this process.

3. Plaintiff asserts that it is her duty and obligation as a citizen of the United States to put before the Supreme Court this fundamental challenge to the use of voting systems that are effectively dismantling the foundations of our democratic republic.

4. Approximately 99.4% of all votes will be counted secretly using machines that are manufactured, sold, and serviced by a handful of corporations of both American and foreign ownership; while 30% of the voters will have already voted absentee or early, in a manner that also denies any effective public oversight.

5. Roughly 30% (29.35) of the voting population will vote on touchscreen or push button voting machines (DREs), according to Election Data Services. Most of these systems (except in Nevada) produce no paper ballots to count or recount.

6. Two companies, ES&S and Diebold, will count approximately 80% of the vote, using both DREs and computerized ballot scanners. The officers of these two companies have well known and documented ties to the Republican Party, as do most of the voting companies the Plaintiff has investigated. This obvious conflict of interest is not lost on many Democratic and Republican voters, alike.

7. The decision to delay an impending federal election is unprecedented. However, this election is completely devoid of any integrity or security. The administration of elections is a state right, but only if they do not violate federal laws. The use of voting machines, early, and absentee voting is a clear violation of the constitution and federal law.

8. The election is already in chaos as reports fill the front pages of newspapers across the country and around the world about problems with voting machines, absentee ballots, and early voting. However, the issue is not about perfect accuracy in the voting process, but instead, it’s about the right to a properly administered voting process under the U.S. Constitution and federal law.

9. Despite the Supreme Court’s decision in Bush v. Gore, which clearly stated that ‘standardless’ recount procedures are a violation of the Equal Protection Clause, many states, including Pennsylvania, have not taken steps to remedy the situation. Instead, they have made matters much worse. Some states and counties will be able to conduct recounts in the upcoming election, while others will not, because they’re using paperless touchscreen voting machines. But, that is not the only problem involving Equal Protection and voting systems.

10. There is no ‘effective’ public oversight in place to ensure even minimal enforcement of voting rights. There is no way to prove that those citizens who are qualified to vote are allowed to vote, and that their votes are marked, cast, and counted properly. As a watchdog for democracy, this journalist will have nothing to watch.

11. To require that citizens first prove vote fraud or system failure in order to obtain enforcement of voting rights, without affording them the opportunity to observe the process in the first place, is to put citizens in a Catch-22 scenario.

12. Elections officials are counseling voters to “trust” in a voting process that has been largely outsourced and privatized. Our government was not founded on faith and trust, but on checks and balances. The widespread practice of election officials employing private corporations to administer the election (via voting machines and the processing of absentee ballots) is an unlawful delegation of their authority and responsibility.

13. The promise, or threat, of the presidential candidates to put thousands of lawyers at the polls to monitor the voting process and protect our right to vote, will be an exercise in futility; for they will have nothing to watch other than the most obvious violations. There is no way to know if an absentee voter is coerced or if they sell their vote. There is no way to know if absentee ballots are not lost or deliberately destroyed. There is no way to know if voting machines are switching votes from one candidate to another.

14. Although Americans have been using voting machines and absentee ballots for over 100 years, the longevity of any custom or practice does not confer legitimacy, as this nation’s tragic 250-year history of slavery is evidence.

15. Pending a full hearing at a later date to be decided by the Court, Plaintiff is requesting that the Court consider these voting systems (machine, absentee, and early) to be, on their face, unconstitutional and a violation of Equal Protection under the 14^th Amendment. Plaintiff suggests remedies such as the Australian paper ballet method and the establishment of remote polling precincts for absentee voters (see below: #12 & #13). Plaintiff is requesting the Court to order a delay of 30 days so that states can make arrangements to establish sufficient numbers of local and remote polling precincts.

SUGGESTED REMEDIES, BACKGROUND INFORMATION, & DISCUSSION

16. Most of the world still subscribes to the Australian paper ballot, where voters come to a polling precinct on Election Day in order to mark their ballots private, cast them publicly, and then are able on their own, or through poll watchers and the press, to observe the counting of the ballots. Canada uses such as system. They count their paper ballots in approximately four hours. Canadians keep their precincts small (250-500 registered voters) so that the vote count is speedy. Voters who are blind can vote privately using a tactile paper ballot with audio assistance, as is done in some states in America and in countries around the world.

17. There are also remedies to accommodate absentee voters. For instance, remote polling precincts for absentee voters could be set up at places such as municipal buildings, college campuses, and military bases across the country, as well as at American embassies, consulates, overseas military bases, and onboard military ships. Instead of applying for an absentee ballot, voters would simply apply to their election boards for a permission slip to vote at a remote precinct. Election officials could be appointed and the press, the public, and poll watchers could be present to observe the process in the normal manner. The permission slips would have the contact information of the voter’s election board in order to call-in election results and information on where to mail the ballots. Ballots could already have printed on them offices for president and vice president. All other offices could be write-ins. This may not be a perfect system, but at least it would be Constitutional.

18. It is common knowledge that absentee voting is an open invitation to vote fraud. A September 25, 2003 report by the Congressional Research Service (CRS), stated, “While the percentage of votes cast by absentee or mail ballot has been increasing in recent elections, some observers have expressed concerns that the method is more vulnerable to certain kinds of fraud and coercion of voters than is balloting at the polling place… According to the National Conference of State Legislatures, at least states have some form of early voting. Some have criticized early voting as distorting the electoral process and being open to certain kinds of fraud and abuse.”

19. In an October 2001 GAO report, the authors stated, “… some officials promote reforms such as early voting to enhance the accessibility of the electoral process to the general public, while others claim such a move could open the door to voter fraud and thus may come at the price of the integrity of the election system.”

20. How Bush Took Florida: Mining the Overseas Absentee Vote, New York Times, July 15, 2001 is an in-depth report (over 9,000 words) that describes how the Bush campaign waged a legal and public relations offensive to pressure canvassing boards in Republican counties to accept overseas ballots for Bush that were illegal and should have been rejected, while at the same time pressing canvassing boards in Democratic counties to reject overseas ballots with identical flaws.

21. Banning voting machines is long overdue. In a July 4, 1989 article in the Los Angeles Times about electronic voting machines and vote fraud, Craig C. Donsanto, head of the U.S. Justice Department’s election crimes branch from 1970 to the present, said, “If you did it right, no one would ever know.” (EXHIBIT A) Not much has changed since that article was first published.

22. There is an extensive and disturbing history of voting machine irregularities and tremendous cause for concern. Two of the best records of these problems can be found in the report, Pandora’s Black Box, Did It Really Count Your Vote by Phillip M. O’Halloran, and in Chapter 2 of the book Black Box Voting, Ballot-Tampering in the 21 Century, by Bev Harris. (EXHIBITS B & C)

23. The Congressional Research Service (CRS) concluded in a November 4, 2003 report, “Given the worsening threat environment for information technology and the findings of several studies and analysis discussed in this report, at least some current DREs clearly exhibit security vulnerabilities….The potential threats and vulnerabilities associated with DREs (touchscreen and push button) are substantially greater that those associated with punchcard or optical scan readers, both because DREs are more complex and because they have no independent records of the votes cast.” It looks like we’ve jumped from the pot into the frying pan.

24. There has been considerable discussion and claims made as to the accuracy of voting machines. Although qualified voters have the right under federal law to have ballots “properly counted”, the accuracy of the count does not enjoy the same legal protection. Voting machines may or may not be more accurate than people or other voting machines. Those who make claims of accuracy or assurances of security for voting machines, have no evidence to substantiate those claims on Election Day since marking ballots is secret and voting machines are inherently unobservable.

25. Research data on residual votes (overvotes and undervotes) is limited in its scope and questionable in its importance, as it does not take into consideration the substantial vulnerability of voting machines to vote manipulation or technical failure. Nonetheless, Massachusetts Institute of Technology (MIT) political science professors, Dr. Stephen Ansolabehere and Dr. Charles Stewart III, in a September 25, 2002 study entitled, Voting Technology and Uncounted Votes in the United States, report, "The difference between the best performing and worst performing technologies is as much as 2 percent of ballots cast. Surprisingly, paper ballots—the oldest technology—show the best performance. Paper ballots that are either hand counted or optically scanned have the lowest average incidence of residual votes in presidential elections and, down the ballot, in Senate and gubernatorial elections. These technologies perform consistently better than lever machines and punch cards. Electronic voting machines (aka DREs) also show promise, though they have a statistically higher residual vote rate than hand-counted paper and optically scanned ballots."

26. There are no federal or state restrictions on who can count Americans’ votes. Any individual, corporation, or government, including felons and foreigners, can make, sell, and service voting machines in the United States. For example, Accenture (formerly Andersen Consulting) received a contract from the U.S. Department of Defense (DOD) to process the military and overseas civilian vote via the Internet for the 2004 election. Accenture has its corporate headquarters on the British territory of Bermuda and claims that more than half of its “partners” are non-U.S. citizens. Sequoia Voting Systems, the third largest voting machine company, is a subsidiary of British-based, De la Rue.

27. The business of counting votes in America is dominated by two corporations, Election Systems and Software (ES&S) and Diebold Election Systems. These two corporations are managed by the Urosevich brothers, Bob (CEO, Diebold) and Todd (vice president, ES&S). Author Bev Harris in her book, Black Box Voting, wrote, "...one of the founders of the original ES&S (software) system, Bob Urosevich, also oversaw development of the original software now used by Diebold Election Systems." The owners of both of these companies have close ties to the Republican Party.

28. Assurances of state elections officials that voting equipment has been independently tested and meets federal standards are meaningless. There are no real federal standards, just general guidelines. The entire certification process is administered by private organizations and corporations, many with strong ties to the Republican Party. “Executives and employees of one of the independent testing authorities (ITA), Ciber, Inc., favored the Republicans 57-1 over the past three election cycles, $101,900 to $1,800. The executives and principal owners of SysTest Labs, another ITA, appear to shun political giving. In the past three cycles employees at Wyle Laboratories, the third ITA, made a total of five contributions to five Republican recipients,” writes Ronnie Dugger in The Nation.

29. Some people believe that it is enough for the voting machine to produce a paper ballot for the voter to verify to be used in case of a close election. First and foremost, it is the voters right to personally mark their own ballot, creating direct evidence of their own intent without interference from technology. Second, voters have a right to have ballots counted the first time, not simply to have ballots sit in storage in case of a close election. And, lastly, if the rule is to conduct recounts only in a close election, then anyone contemplating vote fraud would make sure to steal enough votes to NOT trigger a recount; which looks like what may have happened in the 2002 election, where in 16 upset elections, 74% went to Republicans by margins well off of pre-election polling by Zogby International. Some of the most notable upsets occurred in Georgia, which used Diebold voting machines statewide. The following is an excerpt from a July 30, 2003 article by Thom Hartmann, “’USA Today reported on Nov. 3, 2002, "In Georgia, an Atlanta Journal-Constitution poll shows Democratic Sen. Max Cleland with a 49%-to-44% lead over Republican Rep. Saxby Chambliss.” Cox News Service, based in Atlanta, reported just after the election (Nov. 7) that, "Pollsters may have goofed" because "Republican Rep. Saxby Chambliss defeated incumbent Democratic Sen. Max Cleland by a margin of 53 to 46 percent. The Hotline, a political news service, recalled a series of polls Wednesday showing that Chambliss had been ahead in none of them… Just as amazing was the Georgia governor's race…. the Zogby polling organization reported on Nov. 7, "no polls predicted the upset victory in Georgia of Republican Sonny Perdue over incumbent Democratic Gov. Roy Barnes. Perdue won by a margin of 52 to 45 percent. The most recent Mason Dixon Poll had shown Barnes ahead 48 to 39 percent last month with a margin of error of plus or minus 4 points… Almost all of the votes in Georgia were recorded on the new touchscreen computerized voting machines, which produced no paper trail whatsoever.” (http://www.alternet.org/story/16474).

30. Many Americans are counting on the news media to raise the red flag on election irregularities. However, the late authors of the book, VoteScam: The Stealing of America, concluded that some of the major news networks, including the polling organizations that they hire for election night reporting, have been complicit in vote fraud. One of the first examples they site occurred in Florida in the 1970’s. In 1970, Channel 7 in Miami projected with 100% accuracy (a virtual impossibility) the final vote totals on Election Day. When asked where they got their exit poll data, both Channel 3 & Channel 7 claimed that the League of Women Voters sent it in from the precincts. But, the League's local president tearfully denied it, saying, "I don't want to get caught up in this thing." The broadcasters then told the Colliers that a private contractor used the data from a single voting machine to project the winners, but the contractor said he got the data from a University of Miami professor, who in turn denied this. In the end, the news broadcasters appeared to have got the polling numbers out of thin air.

31. This year the Associated Press (AP) announced that they would be again reporting the raw vote totals for the upcoming election. In recent interviews conducted by the Plaintiff, AP spokesmen, Jack Stokes and John Jones, refused to confirm or deny that the AP will receive direct feed from voting machines and central vote tabulating computers across the country on Election Night. If election results are uploaded to the AP (or to anywhere, for that matter), computer experts agree (and the examination of the online Diebold election software proved) that backdoors built into the computer program can allow votes to be manipulated during an election. It is interesting to note that Burl Osborne, chairman of the AP board of directors, is also publisher emeritus of The Dallas Morning News, a newspaper that endorsed George W. Bush in the last election. Kathleen Carroll, senior vice president and executive editor of AP, was a reporter at The Dallas Morning News before joining AP. Carroll is also on the Associated Press Managing Editors (APME)’s 7-member executive committee. The APME "works in partnership with AP to improve the wire service's performance," according to their website. APME vice president, Deanna Sands, is managing editor of the Omaha World Herald newspaper, a subsidiary of Omaha World Herald Company, owner of the nation's largest voting machine company, Election Systems and Software (ES&S), that will count approximately 50% of all votes in the upcoming election.

32. Experts say that both mechanical and electronic voting machines are easy to rig and can remain virtually undetected; which may partially explain why it is so hard to defeat incumbents in American elections. Whoever has the keys to the warehouse where lever voting machines are stored, has an open opportunity to rig the machines. However, with electronic voting machines there is an unlimited opportunity for a few people, particularly company insiders, to manipulate millions of votes. Computer scientists have long warned that there is no meaningful security to these systems.

33. The popularly accepted rationale for imposing voting machines on American voters is that ballot box stuffing was rampant at the turn of the last century. However, some noted historians dispute this. In his book, The Right To Vote, The Contested History of Democracy in the United States, Alexander Keyssar, of the Kennedy School of Government, Harvard University, writes, "...recent studies have found that claims of widespread corruption were grounded almost entirely in sweeping, highly emotional allegations backed by anecdotes and little systematic investigation or evidence. Paul Kleppner, among others, has concluded that what is most striking is not how many, but how few documented cases of electoral fraud can be found. Most elections appear to have been honestly conducted: ballot-box stuffing, bribery, and intimidation were the exception, not the rule."

STATUTORY AUTHORITY

34. A state’s discretion and flexibility in establishing the time, place and manner of electing its federal representatives has only one limitation; the state system cannot directly conflict with federal election laws on the subject. (McDonald v. Board of Election, 394 U.S. 802 (1969)). Plaintiff argues that the use of voting machines, early, and absentee voting deny effective public participation and meaningful oversight of the voting process. The roll of the poll watcher is reported in U.S. Constitution: Annotations p.18, § 4. Elections, Clause 1. Congressional Power to Regulate, Federal Legislation Protecting Electoral Process, “More recently, Congress has enacted, in 1957, 1960, 1964, 1965, 1968, 1970, 1975, 1980, and 1982, legislation to protect the right to vote in all elections, federal, state, and local, through the assignment of federal registrars and poll watchers, suspension of literacy and other tests, and the broad proscription of intimidation and reprisal, whether with or without state action.” Voting by machines, absentee, or early is inherently non-transparent and therefore prevents effective observation of the voting process and full enforcement of voting rights.

35. States that allow voting to begin ‘early’ or by ‘absentee’ are in violation of 2 U.S.C. §§ 1, 7 and 3 U.S.C. § 1, which establish the Tuesday after the first Monday in November as the day for the election of federal representatives, senators, and presidential electors throughout the United States. In addition, these methods of voting effectively prevent public oversight of the voting process.

36. Qualified citizens have the right to have their votes “counted properly.” (42 U.S.C. § 1973l c(1), Allen v. Board of Elections 393 U.S. 544, 1969) Voters, either by themselves or through their representatives, such as the press, poll watchers, and Federal observers, must be able to observe the voting process in order to know if their votes are “counted properly”. (42 U.S.C. §1973f)

37. Consideration or claims of speed, convenience, participation, or even accuracy do not supersede the citizens’ right to a properly administered election under the constitution and federal law. Writing for the majority in Tennessee v. Lane, No. 02-1667, Justice John Paul Stevens said, “Ordinary considerations of cost and convenience cannot justify a state’s failure to provide individuals with a meaningful right of access to the courts.”

38. Recounts: Implicit in the Constitution is the right to a recount of ‘intact’ ballots. Contested elections are addressed in 1 U.S.C. § 5 and in 26 Am Jur 2^nd § 444, “In an election contest the ballots themselves constitute the highest and best evidence of the will of the electors, provided they have been duly preserved and protected from unauthorized tampering, and recourse may be had to the ballots themselves in order to determine how the electors actually voted. However, one who relies on overcoming the prima facie correctness of the official canvass by a resort to ballots must first show that the ballots as presented to the court are intact and genuine.” Recounts are not possible using paperless DREs, lever, or Internet voting. Any paper produced only displays vote totals. These machines prevent the voter from creating a ballot at all (i.e., an official record of their votes), let alone an “intact” ballot.

39. The citizens’ right to vote is guaranteed under Article I, § 2 of the U.S. Constitution (Wesberry v. Sanders, 376 U.S. 1, 1964), the Fourteenth Amendment, and other Amendments and federal laws. The right to vote is given under the Constitution to all “qualified” citizens. (42 U.S.C. § 1971, Reynolds v. Sims 377 U.S. 533, 1964) A voting machine is not a “qualified citizen”, yet on Election Day, many voters must use a voting machine in order to vote. Although voters can make inputs to the voting machine, it is the machine, not the voter, which is supposed to physically mark, cast, and count the ballots.

40. “The terms 'vote' or 'voting' includes all action necessary to make a vote effective in any primary, special, or general election.” (42 U.S.C. § 1973l (c)(1) Voting machines interfere with the citizens’ ability to make their votes “effective” or to know if they, in fact, voted. With the DRE, as well as with other voting systems, voters may enter and leave the voting booth thinking that they ‘effectively’ voted, when they did not. The machine may not record their votes or the voter may unknowingly fail to cast a vote. In contrast, when a voter marks a paper ballot with a pen or pencil and puts it in a ballot box, the voter knows that he marked and cast his ballot. With absentee ballots, there is no way for the voter to know if their ballot was even counted or if it was lost or destroyed.

41. In Bush et. al v. Gore et. al (No. 00-949), the Supreme Court wrote, "A ‘legal vote,’ as determined by the (Florida) Supreme Court, is one in which there is a ‘clear indication of the intent of the voter’.” The Court accepted that definition as, "unobjectionable as an abstract proposition and a starting principle.” The use of voting machines prevents the voter from directly creating or casting a “legal vote” as a “clear indication” of their intent. Any result produced by a voting machine is direct evidence or a “clear indication” that the machine did something. However, it is circumstantial or not “clear” evidence of the intent of the voter. In addition, an absentee vote cannot be legal (i.e., “a clear indication of the intent of the voter”), in that there is no way to determine if the voter was not subject to coercion.

42. It is the government’s responsibility to provide a private place to cast a secret vote (i.e., the voting booth). If there is no protection from intimidation for the voter and their votes cannot be “effective.” In Empire Voting Machine Company v. Harry W. Carroll et al., 78 Wash. 83; 138 P. 306 (1914), the court said, “The object of all constitutional provisions and laws providing for a vote by ballot is primarily to procure secrecy.” The only way to ensure that ballots must be marked in secret is for elections officials to provide a place that offers secrecy. The polling booth is such as place; a home or office is not. The voting booth provides voters a secure place in which to mark their ballots secretly and privately. The polling precinct provides citizens a public place in which to cast their ballots and have them counted properly, in full view of fellow citizens, poll watchers, Federal observers, election officials and the press. In contrast, absentee voting offers substantial opportunities for vote fraud, voter intimidation, vote selling, and system failure, with minimal opportunities to detect irregularities.

43. The following quote is by a Department of Justice (DOJ) counsel in an amicus brief (April 23, 1997) for Nelson v. Miller No. 97-1155, in the U.S. Court of Appeals for the Sixth Circuit, “The Supreme Court has similarly recognized that the secret ballot serves compelling state interests. See Burson v. Freeman, 504 U.S. 191, 206 (1992); see also McIntyre v. Ohio Elections Comm'n, 115 S. Ct. 1511, 1517 (1995) (observing that the 'respected tradition of anonymity in the advocacy of political causes" is "perhaps best exemplified by the secret ballot, the hard-won right to vote one's conscience without fear of retaliation"); Buckley v. Valeo, 424 U.S. 1, 237 (1976) (Burger, C.J., concurring in part and dissenting in part) (" [S]ecrecy and privacy as to political preferences and convictions are fundamental in a free society.”

44. Plaintiff wholeheartedly agrees with this statement. Furthermore, in Burson v. Freeman, 504 U.S. 191, 206 (1992), the Supreme Court said, “In sum, an examination of the history of election regulation in this country reveals a persistent battle against two evils: voter intimidation and election fraud. After an unsuccessful experiment with an unofficial ballot system, all 50 States, together with numerous other Western democracies, settled on the same solution: a secret ballot secured in part by a restricted zone around the voting compartments. We find that this widespread and time-tested consensus demonstrates that some restricted zone is necessary in order to serve the States' compelling interests in preventing voter intimidation and election fraud.”

If this election is allowed to continue under present circumstances, the last flicker of our founders’ dream of a democratic republic will be extinguished for many Americans.

PLAINTIFF respectfully requests that this Court delay this Election Day by 30 days in order to allow states to make arrangements for an election administered by American election officials that includes effective public oversight and enforcement of voting rights at local and remote polling precincts, and excludes voting machines, early voting, and absentee ballots.