May 20, 2005
Petitioners' Trial Brief

Posted here is the 63-page Petitioners' Trial Brief in Borders v King County et al

Posted by Stefan Sharkansky at May 20, 2005 07:52 PM | Email This
Comments
1. And so it begins.

Posted by: Danny on May 20, 2005 08:06 PM
2. One worry relieved the are not relying on one issue, they are going after all the issues.

III. FACTS.
A. Illegal Votes Cast by Identifiable Voters.
1. Felon Voters.
2. Persons Who Voted More Than Once.
3. .Persons Who Voted in the Name of a Deceased Person.
4. Other Categories of Identifiable Illegal Voter.
B. Illegal Votes Cast by Persons Who Cannot Be Identified.
1. The Process of Voting, Counting and Reconciliation
a. Poll Site Voting.
b. Provisional Ballots.
c. Reconciliation.
d. bsentee Ballots
2. King County Alone Counted More Than a Thousand Votes in Excess of the Number of Persons Who Signed the Poll Books to Cast Their Votes at the Precinct Poll Sites.
3. King County Counted 875 Absentee Ballots in Excess of Persons Credited With Having Cast Absentee Ballots, and Knowingly Concealed This Information From the Secretary of State.

Posted by: JCM on May 20, 2005 08:34 PM
3. Correct me if I missed it, but has anybody heard whether the certification of the ballots was done under penalty of perjury?

I can't imagine, given the foundation of our representative government, that any official would be allowed to perform such a serious duty without having to sign under penalty of perjury.

And if so, why hasn't anything (at least I haven't heard anything) been said about felony prosecution?????

Posted by: Rascal on May 20, 2005 08:53 PM
4. Don't know about the perjury. However according to RCW 29A.84.711 falsefying the Mail Ballot report is a Class C Felony with fines and jail time. Prejury would just be icing on the cake.

Don't know why the McKenna, Maleng or McKay aren't all over this, that remains a mystery.

Posted by: JCM on May 20, 2005 09:09 PM
5. Rascal, I believe the answer to your question is yes. The witnesses were "sworn" before the testimony.

Posted by: Gil on May 20, 2005 09:23 PM
6. How come the two identified non citizens who voted were not included in the illegal list?

Posted by: C. Oh on May 20, 2005 09:48 PM
7. That's odd...I can't get it to load PDF?

Posted by: Deborah on May 20, 2005 10:21 PM
8. That's odd...I can't get it to load PDF?

Have patience. It's a big file.

Posted by: Stefan Sharkansky on May 20, 2005 10:26 PM
9. C Oh. I remember hearing something recently about that. Apparently the two parties (Rs & Ds) agreed not to include that. I think it was because the rules for contest don't specifically lay it out. They should , but that's just another reason to update election law.

Posted by: Michele on May 20, 2005 10:30 PM
10. Heh..Stefan...

I think I've burned out my AR on the Way and Fell depositions!

Posted by: Deborah on May 20, 2005 10:37 PM
11. I can't seem to open it either. Didn't have trouble with the depositions. How big is the file Stefan? We do have a cable connection but it's been unusually slow lately...

Posted by: cc on May 20, 2005 11:04 PM
12. More hints at the F* word.
From p. 23 of 63 line 13-22.

"Fourth, there is a pattern to the discrepancies in absentee crediting. Garth Fell, KC's assistant superintendent of elections for ballot processing and delivery (responsible for processing absentee ballots), testified that if there were any human errors in the absentee crediting process, they should be random. In King County, however, the precincts with the largest discrepancies show a pattern. The two precincts with the largest positive discrepancy (more absentee ballots counted than voters credited with casting ballots) are precincts in which Rossi won only 22% of the vote. The two precincts with the largest negative discrepancies (fewer absentee ballots counted than voters credited with casting ballots) are precintcs in which Rossi received the majority of votes. Fell could not explain any reason for the pattern."

Posted by: RonP on May 20, 2005 11:45 PM
13. Stefan,

Were the trial briefs in the same pdf format as the depositions? Or were they processed in an updated version of acrobat reader? It's only 65 pages....

I have tried everything and can't open it!

Posted by: Deborah on May 21, 2005 12:01 AM
14. It opens fine for me with Acrobat 6.0.2.
Try a right click and Open in New Window or right click and Save Target As...

Posted by: RonP on May 21, 2005 12:10 AM
15. OK RonP..
I'm going to try to save target as....
I have tried to open in New Window but it hung...
It's only about 3.5 mb..
Thanks!

Posted by: Deborah on May 21, 2005 12:37 AM
16. OK! That did it! (Save Target As)

RonP,
Thanks again!

Posted by: Deborah on May 21, 2005 12:53 AM
17. Oh my!!

I am impressed!

A resounding answer to the Dems *bold-face* lies and *in your face* tactics!

Rossi's group is categorically spelling out every charge in wonderful detail and the evidence that will sink the Democrats!

(Is that the sound of Paul Berendts I hear?..... squealing like a little girl in anguish?.........)

I love how they went in depth on the Dems *cherry picking* of Gregoire votes - with those *miscanvassed* Larry Phillips ballots! And how most of them shouldn't have been validated...

There is so much! (OK...I cheated after page 30 and skipped to the conclusion)....I'll reread it in the morning!

Posted by: Deborah on May 21, 2005 01:28 AM
18. The final paragraph on p. 1 of the brief provides all the information one needs to conclude, with a high degree of certainty, that fraud occurred:

"The change in the election result in the manual recount was largely attributable to changes in the results in King County, the largest and the most heavily Democratic county in the state. According to the results ofthe initial count in King County, Gregoire received 59% of the votes cast for either Gregoire or Rossi. In the machine recount, King County counted an additional 941 votes cast for the two candidates, of which King County counted 593, or 63%, for Gregoire. In the manual recount, King County counted another 537
additional ballots cast for the two candidates, of which King County counted 358, or 66.6%, for Gregoire. At each count, Gregoire s percentage of the newly discovered votes increased."

Based on the original count of a very large number of votes, the likelihood of a vote in King Co. being cast for Gregoire was 59% (ignoring those votes cast for someone other than Gregoire or Rossi). If new ballots were found to be for Gregoire at a significantly higher rate than 59%, that's evidence of pro-Gregoire fraud. In the first recount, 593 of 941 new ballots were for Gregoire. The probability of this many votes or more going for Gregoire, assuming that 59%, on average, would go to her, is only 0.65%. Per statistical convention, one may assume the existence of fraud if the probability is less than 5%--0.65% is far less than 5%.

In the second recount, 358 of 537 new ballots were for Gregoire. The probability of this many votes or more going for Gregoire, assuming that 59%, on average, would go for her, is a mere 0.0002%!

One can come to only two possible conclusions: either Gregoire experienced a genuine miracle, or the 'Rat Machine in King Co. pulled her through to victory by means of flagrant fraud.

Posted by: Bill on May 21, 2005 03:14 AM
19. The case cited beginning with line 9 on page 41 pretty much ends the last thread of hope for the argument Paul Berendt has been pedaling this week.

Posted by: Baynative on May 21, 2005 05:56 AM
20. p. 43 of 63, lines 11-14.

"If the number of illegal votes were 500,000, out of 2.9 million cast, there is no question how the Court would rule. And, if the number of questioned votes were 100, there is likewise no question how the Court would rule. In this case, Foulkes [previous case] permits and the circumstances demand that the Court annul the election, whether or not the Court is persuaded that absent the error Rossi would have prevailed in the election."

See you in November.

Posted by: RonP on May 21, 2005 06:43 AM
21. Micajah is now our resident "psychic".
Last night on a different thread @ 11:27PM, Micajah asked when the MSM would report on the fact the Fell implicated Huenekens in knowing about the false Mail Ballot Report #'S and
VOILA!!
Read Keith Ervins article in today's Seattle Times.
Ervins and Postman are going to get some kind of award for professional journalism. It's especially encourage since they face immense pressure to "see no evil and write no evil".
Outstanding.

Micajah--
When will the Dow, NASDAQ and S&P peak and what levels will they reach in the next year???

Posted by: Mr. Cynical on May 21, 2005 07:13 AM
22. Bill,

There is an alternate explanation that could invalidate those statistics. It could be argued that in the Rossi precincts the (more likely to be Republican) poll workers were more careful to follow the rules than in the democratic precincts (manned more likely by Democtratic poll workers) (we know that Republicans are more interested in following rules), meaning that democratic precincts were more likely to loose ballots not to be found until later.

My point here is that the origin of the ballots needs to be considered, along with the controls that were in place from where they were lost to where they were found.

I personally believe it is fraud, so don't attack me...I'm just warning you of the other side's argument. King County has been blaming everything on "errors" which are more likely to be committed, in my opinion, by someone less interested in following the letter of the law.

Posted by: VaCSProf on May 21, 2005 08:15 AM
23. save as target worked for me too! thanks RonP!

Posted by: cc on May 21, 2005 08:26 AM
24. Everything but the kitchen sink is included in the brief, even arguements they think they will lose or that Judge Bridges has already excluded. Probably for appeal purposes, but it makes for a much longer read.

Otherwise it looks as though they scoured through the archives of SP to get much of their case.

I wonder how they would have done this if Stefan had never moved here from CA.

Thank you Stefan for your invaluable work in making this case as clear as you have over the last 6 months.

Posted by: DeadWood on May 21, 2005 08:45 AM
25. Stefan,

Thank you for making these depositions and briefs available to us this weekend in time for this coming week's trial!!

Oh..And this weather is perfect for curling up with a long deposition and a hot cup of coffee!! Heh! Clancy will have to wait!

Posted by: Deborah on May 21, 2005 12:30 PM
26. Deborah--
I started reading the depositions with coffee...
and I finished drinking Jack Daniels!

Posted by: Mr. Cynical on May 21, 2005 06:11 PM
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