Geoffrey Riggs: Park City, Utah 310-562-8373

Geoffrey Riggs
Park City, Utah

riggsco@gmail.com
310-562-8373
MEMORANDUM
BY EMAIL TO ALL PARTIES
TO: Sidney Powell

CC: Juli Haller, Carissa Keshel
FROM: Geoffrey Riggs
DATE: February 15, 2021
RE: A Scheme to Secure a Biden Victory in the 2020 Presidential Election in Pennsylvania
with Fraudulent Mail-In Ballots
Introduction:
This document describes a scheme to introduce fraudulent mail-in ballots (“MIBs”) in
Pennsylvania in sufficient numbers to guarantee victory for Joe Biden. The scheme is consistent with
evidence in several forms related to the election in Pennsylvania. It also correlates positively with data
about the election published by the Pennsylvania Department of State (“DOS”) and with models I
developed to track the results of the election and certain key variables that influence those results.
While the scheme described here could easily have accounted for Biden’s victory on its own,
evidence indicates that other forms of unlawful interference with the Pennsylvania election may have
also contributed, including tampering with election processing software and a number of irregularities in
counting operations. However, all indications thus far are that neither courts nor state legislatures have
been able, or are willing to, order state and local election officials in Pennsylvania to investigate
irregularities or perform audits of the sort needed to detect fraud and other unlawful interference with
the election.
Investigative and Analytical Process:
The findings and conclusions expressed in this memorandum evolved out of a lengthy process
that began shortly after November 3, 2020 and continues to this day, including:
 Review and analysis of all available data on the election itself, primarily focused on datasets and
various reports published or made available by the Pennsylvania DOS but also including data
from other sources including media reports. Datasets were then broken down and rebuilt to
generate data specifically relevant to possible fraud and or interference with the election.
 Comprehensive legal and procedural analysis of Pennsylvania’s laws, rules, procedures and
documents related to application, approval and submission for voting of MIBs in the election.
From the Desk of Geoffrey Riggs
February 15, 2021
Memorandum re: Fraudulent Ballot Scheme in Pennsylvania
Page 2
 Creation of several computational and predictive models emulating processing of election-

related data in various forms, some of which are being forwarded with this memo for purposes
of illustrating and/or validating some of the opinions and conclusions expressed.
 Review of news reports pre- and post-election relevant to findings made and conclusions
reached.
Supporting Documents:
The following documents accompanying this memorandum as aids to understanding and/or
verifying the processes by which certain findings and conclusions were reached for the analysis involved:
 ExhibitA_MathematiciansView.xlsx -- an Excel workbook containing a simplified vote processing
model showing that Biden’s victory could not have been the result of any legitimate expression
of voter choice.
 ExhibitB_Election_Fraud_Model.xlsx -- an Excel workbook containing a slightly more complex
model showing exactly how the scheme described in this memorandum voting would have
operated to ensure Biden’s victory.
 ExhibitC_FraudBreakdown.xlsx – an Excel workbook containing a more granular analysis
showing breakdown of the scheme by County.
 ExhibitD_Sequential_Vote_Count_Simulator.xlsx -- an Excel workbook containing a sequential
election processing model that was used to validate operation of the scheme and other
anomalies occurring during the processing of MIBs in Pennsylvania. This model was itself
validated by correctly accounting for over 150 intermediate election returns reported November
3 and November 12, 2020.
 ExhibitE_PADOS_mailInapplication.pdf -- hard copy application form for mail-in ballot in
Pennsylvania.
 ExhibitF_FINAL-PP-AMISTAD.pptx – PowerPoint presentation of investigation by Amistad Project
of Mark Zuckerberg funding of election operations in key counties and city jurisdictions of swing
states.
Key Findings:
The remainder of this memorandum is organized around three critical findings:
1. The results of the MIB vote that allowed Biden to overtake the lead amassed by President
Trump from in person, election day voting and to emerge as the winner of the election could not
have been achieved as a result of any recognized election metric or phenomenon, or any
legitimate expression of voter preference.
2. The rules, procedures and documents established by the state of Pennsylvania for obtaining and
voting with MIBs were deeply flawed, making it possible for properly equipped, financed and
February 15, 2021
Page 3
motivated individual or group of individuals to obtain fraudulent MIBs, in numbers large enough
to affect the outcome of the election, by exploiting critical gaps in the rules, procedures and
documents governing application for and approval of MIB requests.
3. By running different types and configurations of fraudulent MIBs through election processing
models based on the number and party affiliation of MIBs submitted for voting in Pennsylvania, I
was able to identify one specific scheme that essentially duplicated the results Biden achieved in
Pennsylvania from the inventory of MIBs logged in by the DOS. The scheme consisted of
obtaining approximately 200,000 MIBs in the names of registered Republican Pennsylvania
voters, using the same application process that legitimate voters used while taking advantage of
the flaws in the application process that made it possible for someone unrelated to a registered
voter, who had never had any personal contact with the voter, to obtain an MIB in that voter’s
name and have it delivered to the address of his/her choice. These MIBs would have been
properly accounted for by the DOS, and would have been included in the datasets that DOS
made available to the public. These MIBs literally made the impossible possible, meaning that
they made it possible for Biden to overcome Trump’s election day lead in a way that could not
be predicted or even reasonably calculated based on the party affiliation breakdown of the MIBs
submitted for voting by dramatically changing the votes represented by those MIBs – lowering
the vote count for Trump underlying the Republican MIBs, and raising the count for Biden
underlying the Democratic MIBs, each by 200,000 votes, creating a spread of 400,000 between
the candidates, more than enough to assure Biden of victory.
Finding # 1-- Biden’s Comeback and Victory Were Impossible:
A critical juncture occurred in my work on the election when I was able to determine, and for all
practical purposes, prove that Biden’s comeback and his eventual victory in Pennsylvania could not have
been the result of any currently recognized election metric or other election-related phenomenon
operating within any acceptable range of what is considered normal. From a mathematical perspective,
the numbers involved –the results of in person, election day voting, the size of Trump’s lead before
accounting for any MIB votes, the overall number of MIBs submitted for voting and the breakdown of
MIBs by party affiliation of the submitting voter – simply did not allow for the results that occurred
except under extraordinary and virtually impossible circumstances.
The math supporting this finding is relatively simple. According to the returns published in the
days following Nov. 3, Trump had amassed a 2,278,746 to 1,404,223 = 1,324,523 vote lead in election
day returns, with 2,528,405 MIBs to be counted. 1 The simplistic and factually incomplete media
analyses reported on November 4 and thereafter generally went something like this: Biden had already
won 78% of the early MIBs counted. Given the advantage Democrats held over Republicans in MIBs
submitted for voting, Biden had a good chance of maintaining that 78% to 22% margin in the MIBs that
1
- These election-day returns would change over time, but not in sufficient amount to change the analysis presented here. In
addition, the number quoted for MIBs of 2,528,405 reflects deduction of 24,690 votes that word eventually be cast for third-
party candidates from the initial DOS reports of 2,665,095 MIBs.
February 15, 2021
Page 4
remained to be counted. A 78% overall share of 2,528,405 MIBS would give Biden a 1,972,156 to
556,249 = 1,415,907 margin in MIBs, more than enough to overcome Trump’s election day lead, and
therefore more than enough to justify projecting a Biden victory. 2
In addition to sharing this underlying false logic, these predictions also shared a number of key
errors and omissions. While it was true that the early counts of MIBs favored Biden over Trump in
approximately the cited 78% to 22% margin, none of the reporters sought to apply any critical analysis
to these early MIB returns -- the political demographics of the districts and/or counties from which they
had come, or, more generally, the inadvisability of predicting the outcome of an election with more than
50% of the vote yet to be counted. Neither did any of them bother to cite the actual numeric or
percentage advantage Democrats had over Republicans in MIBs submitted (this advantage generally
being cited as major support for their projections), which was substantial but significantly less than 78%
to 22%.3 Neither did any of them mention the large block of 262,446 (allowing for deduction of the
24,690 votes that would eventually be cast for third-party candidates) independent and unaffiliated
voters who had submitted MIBs, which no matter how favorable they might have gone for Biden would
certainly never have gone 78% to 22% for him. And finally, neither did any of these reporters
demonstrate knowledge of any of the well known election metrics that could reasonably be used to
predict candidate votes from party affiliated MIBs, e.g. crossover voting rates and projected split of
independent voter MIBs between Biden and Trump. And good for these reporters that they left all of
these items out, because every single one would have exposed their predictions of a Biden comeback as
sheer fantasy.
As I have mentioned, the mathematics of predicting the outcome of this known block of MIBs
submitted for voting is not rocket science. At the time these reporters were making their predictions, it
required nothing more than the willingness to do a little research to come up with reasonable estimates
of the relevant election metrics and a junior high school level competence in mathematics to apply these
metrics to the known data about the MIBs submitted for voting, which was freely available from the
DOS. The following discussion references ExhibitA_MathematiciansView.xlsx.
The first order of business was to take note of the lead Trump had amassed from In-Person
voting:
Candidat
e Votes
2,728,74
Trump 6
2
- Different analyses started at different points in the MIB count. A popular starting point was early morning on November 4, at
which point Trump still held a lead of approximately 700,000 votes with 1,400,000 MIBs remained to be counted. As shown in
ExhibitA_MathematiciansView.xlsx, Scenarios E and F, the choice of starting point does not improve Biden's chances. In fact,
the results of the analysis showing the impossibility of his victory are the same. Compare Scenarios B and C of Exhibit A with
Scenarios E and F.
3
- The actual numeric advantage was 1,665,504 to 600,455 MIBs, or 73.5% to 26.5% -- an advantage which if held by Biden
through the full count of MIBs would land him considerably short of completing his miraculous comeback – 3,329,201 t0
3,069,727 = 259,474 votes short to be exact.
February 15, 2021
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1,404,22
Biden 3
1,324,52
Margin 3
Second, here is what was known about the inventory of MIBs submitted for voting, before any
of the votes had actually been counted:
Mail-In Ballots
By Party Affiliation
Dem 1,665,504
Rep 600,455
rd 4
3 Pty 24,690
Other 262,446
2,553,095
There is a simple formula for calculating how many votes out of the MIB group Biden would
need to catch Trump:
X = (A+B)/2
Where X = required number of votes, A = total number of MIBs remaining to be counted and B =
Trump’s lead at the time the calculation is made. The formula is derived by solving the following two
equations, where X, A and B are as above, and Y = the number of votes Trump would receive from the
total MIBs remaining:
X+Y=A X–Y=B
So in this case, Biden needed (2,528,405 5 + 1,324,523)/2 = 1,926,464 MIB votes to tie Trump.
So, where exactly was Biden expected to get these 1,926,464 votes out of this block of 2,528,405 MIBs?
In addition to accounting for the party breakdown of the MIBs submitted for voting, an informed
answer to that question would also factor in three key variables that would affect how party-affiliated
MIBs translate into actual votes cast for the candidates. Those variables are the respective crossover
rates for Republican and Democratic Party voters and the likely split of independent or unaffiliated
voters between Biden and Trump. Although definitive values for these variables were not available by
November 4, numerous pre-election polls gave fairly accurate indications of what could be expected in
this election. For purposes of my postelection analysis presented here, I utilized values determined by
exit polls conducted by Edison Research, arguably the most authoritative pulling and analytical
4
- The 24690 MIBs classified as 3rd Pty are the number actually voted, which I have segregated from the “Other” category since
they have no bearing on votes that would be cast for Biden or Trump other than to reduce the overall number available to
either of them.
5
- This number represents the total MIBs submitted net of the 24,690 that would be voted for 3 rd party candidates.
February 15, 2021
Page 6
organization specializing in exit polls. All of this basic information together with explanatory data is
covered in the first panel of Exhibit A.
Again, the math involved is quite simple. For any given number of Republican or Democratic
party MIBs, the actual vote for each candidate can be calculated as follows:
Votes Cast for P1 Candidate = P1MIBs minus (P1MIBs multiplied by P1XOR) plus (P2MIBs
multiplied by P2XOR) plus (OMIBs multiplied by P1SO), where:
P1MIBs = total MIBs submitted by P1 voters
P1XOR = crossover rate for P1 voters
P2MIBs = total MIBs submitted by P2 voters
P2XOR = crossover rate for P2 voters
OMIBs = total MIBs submitted by independent, third-party or unaffiliated voters
P1SO = P1 Candidate’s projected share of OMIBs
The additional seven panels presented to the rights of the opening panel in Exhibit A show the
likely results of MIB voting Pennsylvania based on the party breakdown of MIBs submitted for voting
and the Edison Research values for the key variables. They are briefly summarized here:
Scenario A – shows the result, calculated at the “hypothetical” 6 end of in person voting, before
any MIBs have been counted, assuming values for key variables set at the levels identified by Edison
research, i.e. 7% crossover rate for Democratic voters, 8% crossover rate for Republican voters, and
Biden capturing approximately 55% of the independent or other voters. Under this Scenario, Biden falls
short of receiving the required 1,926,464 votes to tie Trump by 185,164 votes, a deficit that translates
into a margin of victory for Trump equal to twice the shortfall (since the shortfall effectively reduces
Biden’s vote total by the indicated amount and increases Trump’s total by the same amount). Under
this Scenario, Trump wins the election in Pennsylvania by 370,327 votes. For purposes of comparison,
the actual returns most closely corresponding to this results in terms of total votes cast (meaning before
additional late arriving or late counted votes are added in) are displayed in the furthest right column,
showing that Biden mysteriously managed to achieve the impossible. This actual result can be viewed in
proper context in ExhibitD_Sequential_Vote_Count_Simulator.xlsx, Column DI. Exhibit D is an election
processing model created specifically for the purpose of analyzing the Pennsylvania election, and
incorporates over 150 individual reported returns for the election, beginning with the earliest returns in
the evening of November 3, after the polls closed, and extending until end of the day, November 11.
Scenario B – acknowledging that polls of all kinds can be and often are subject to error, this
Scenario assumes that all three key variables are adjusted 20% to favor Biden, meaning that the
6
- The timeframe of this Scenario, as well as Scenarios B and C, is referred to as "hypothetical" because the two operative
events – the end of in person vote counting operations and in the beginning of MIB counting operations – did not occur in such
a cleanly defined manner, but actually overlapped significantly. However, assuming that they did occur in this manner does not
invalidate the analysis. Rather it presents it in perhaps the clearest and most definitive format.
February 15, 2021
Page 7
Democratic Party crossover rate gets reduced by 20%, the Republican Party crossover rate gets
increased by 20% and Biden’s projected share of Independent or Other votes is increased by 20%. These
adjustments notwithstanding, Biden would still have fallen short of receiving the required number of
votes, in this case by 123,370 votes. The result would’ve been a Trump victory of 246,740 votes.
Scenario C – taking these adjustments to the extreme, this Scenario assumes that all three key
variables are adjusted 50% to favor Biden, resulting in a lowering of the Democratic Party crossover rate
to 3.5%, raising the Republican Party crossover rate to 12%, and raising Biden’s projected share of
Independent or Other votes to a preposterous 82.5%. Even with these radical adjustments, Biden still
falls short of receiving the required number votes by 30,680 votes, resulting in a Trump victory of 61,360
votes.
Scenario D – this Scenario shows the percentage adjustment to key variables that would have
been required for Biden’s comeback and victory to occur. All three variables would need to be adjusted
66% in Biden’s favor, reducing the Democratic party crossover rate to 2.38%, raising the Republican
Party crossover rate to 13.28%, and raising Biden’s projected share of Independent or Other votes to an
even more absurd 91.3%.
Scenario E – to demonstrate that the analysis does not appreciably change depending on the
time in MIB vote counting operations when the analysis is performed, this Scenario runs the same
analysis as of 1:33 AM on November 4, when the initial results of MIB vote counting, and the
corresponding number of MIBs remaining to be counted, were at levels cited by a number of the
reporters projecting the Biden victory. The reports to which I refer generally noted that Biden had
received approximately 78% of initial MIB votes counted with approximately 1,400,000 MIBs remaining
to be counted, at a time when Trump’s lead stood at approximately 700,000 votes. Scenario E presents
more exact numbers based on actual returns, which can be viewed in Column R of Exhibit D.
Unfortunately for Biden and his fans among the media reporters, this Scenario, based on the key
variable values calculated by Edison research shows the exact same result as the analysis performed as
of the hypothetical end of In Person voting displayed in Scenario A.
Scenario F – in the interest of consistency and thoroughness, this Scenario runs the same
analysis as of 1:33 AM on November 4, with all key variables adjusted 20% to favor Biden, and produces
the same result as the analysis performed as of the hypothetical end of In Person voting displayed in
Scenario B.
Scenario G – to answer the obvious question raised by all of this analysis – given that Biden’s
comeback and victory were mathematically “impossible”, how can we explain the fact that he did
achieve this comeback and victory? Scenario G presents the results with introduction of 220,000
fraudulent MIBs, submitted in the names of Republican voters who did not vote, containing votes for
Biden. ThisScenario is explained further in the section on Finding #3 below.
Contrary to the predictions of several media organizations as well as statement from the Biden
campaign and from Biden himself, it was clear based on size of Trump’s lead and the number and party
February 15, 2021
Page 8
distribution of outstanding mail-in ballots that a Biden comeback was mathematically improbable to the
point of being impossible. Given that the explanation for Biden achieving this impossible result had to
reside somewhere in the processes for obtaining, submitting and or counting MIBs, the next stage of my
inquiry began with a thorough examination and legal analysis of the rules and procedures governing the
application for submission of his ballots. This led to the second critical finding.
Finding # 2 – Laws, Rules and Procedures for Mail-In Ballots in Pennsylvania Invited Fraud on a
Massive Scale by Omitting or Effectively Disarming Available Security Measures
The system for MIBs currently in place in Pennsylvania makes it possible for any individual to
apply for and receive an MIB in the name of a registered voter, without ever appearing before anyone,
face to face, without ever producing an identity document or a copy of such a document, and without
having any personal knowledge or connection with the voter whose right to vote he or she is stealing.
The thief has only to fill out the application form with the correct information on the registered voter –
name, address, date of birth, etc. Save for the single exception of one item of information needed to
validate the voter’s identity (discussed in more detail below), all of this information is fully in the Full
Voter Export file, a complete file of information on registered voters kept by the Pennsylvania
Department of State (DOS) and available to any member of the general public who can pay the $20 fee
for the file. The fraud can be scaled up to almost any level desired, by automating the transfer of
information from the Full Voter Export filed into the application form for MIBs, and automating similar
processes to address return envelopes, etc. Completing ballots and other data entry associated with
returning the completed ballots to state election authorities could be similarly automated. The effort
would require good planning and organization, and a fair amount of unskilled labor, but it could
definitely be successfully accomplished. The principal challenges associated with such a scheme would
be logistical rather than legal.
Gaps in the Application Process
Pennsylvania provides several options for a registered voter to obtain a mail-in ballot – in
person, online and by mail. I would expect someone implementing the scheme to use the mail. In
person would be avoided for obvious reasons. Online would not be out of the question but would leave
a digital trail that would have to be obscured. The mail option has a lot of advantages.
Using a hard copy application form, the implementers could mass-produce applications by
software configured to pull data from the Pennsylvania Full Voter Export file (or alternatively could use a
digital version of the form to be filled out and then printed). The Full Voter Export file also contains
numerous data items that would be of use in screening the list for voters with desirable attributes, one
of which would be a track record for not voting very often were very recently (although if the snafu over
duplicate applications described on page ** of this memo was actually caused by this scheme, it would
indicate that the implementers did not put much effort into screening their candidates for theft of
identity and right to vote).
February 15, 2021
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Another advantage of using the mail option was one of the more glaring security gaps in the
mail-in ballot application process. As can be seen on the form, a copy of which I am enclosing with this
email (“PA DOS_mailinapplication”), and the instructions, a voter is able to designate a different mailing
address for delivery of his or her mail-in ballot (section 4 of the application). Simply by requiring that the
ballot be sent to the residence address listed on the voters registration file, Pennsylvania could have
effectively shut the door on scheme such as this. In this case, the thieves would have set up multiple
mail drops to receive the fraudulently obtained ballots.
The last item the implementers would need to address would be the State of Pennsylvania’s
proof of identity measure. As noted in section 5 of the application, the applicant can prove his or her
identity by providing either a PA driver’s license or identity card number or the last four digits of the
applicant’s Social Security number – not the actual cards or even a copy of such cards, just the number.
Personally, I laugh when I’m asked to provide the last four digits of my Social Security number as proof
of identity, knowing that there must be a thousand people would know that number. At any rate, I
doubt whether anyone with connections in the Pennsylvania State or federal bureaucracies would have
any trouble obtaining a list of the last four digits of Social Security numbers for as many registered
voters that they needed, or all of them for that matter. See the discussion below on page **concerning
to organizations that easily could have been involved in such a scheme, both of which had full access to
the computer records on registered voters maintained by the state of Pennsylvania. These records
would have included the numbers required for proof of identity in the mail-in ballot application as well
as digital copies of signatures.
In the event providing a driver’s license or ID number for the last four digits of Social Security
number is too much of a burden for a registered voter, the mail-in ballot application allows for alternate
forms of identification to suffice, including student IDs from any Pennsylvania institution of higher
learning or any Pennsylvania care facility (meaning any facility that provides health-related care and
services). It goes without saying that one need not be a US citizen to obtain any of these forms of
identification, a problem with greater relevance to the process of registering to vote than application for
or obtaining of mail-in ballots, but one that nonetheless provides another indication of how far
Pennsylvania (and numerous other states) have gone in abandoning their obligation to protect the right
to vote in an effort to inflate voter rolls at any cost. 7
Checking signatures has been one security measure that states have attempted to use to
validate MIBs. Although as a practical matter, a part-time election processing employee with a few
hours of training cannot be expected to competently match signatures, there are reasonably effective
7
- Although measures such as these intended to enable all persons, including noncitizens, to vote in our elections are promoted
primarily by Democratic party politicians and other liberal activists, Republican politicians do bear some of the responsibility, in
particular in states like Pennsylvania where the legislature is controlled by Republicans. For too long, Republican politicians
have allowed themselves to be bullied by their Democratic counterparts into approving, or not opposing, overly liberal laws
and regulations governing voting, immigration, residency and other related matters, intimidated by claims that any law or
regulation imposing requirements on a person’s right to vote is an attempt to suppress that person’s vote. The Republican’s
failure to stand up for what they supposedly believe in carried through to their ultimate failure to support the President in his
efforts to expose fraud in this election.
February 15, 2021
Page 10
software systems for signature matching that can be calibrated to different tolerances to strike the best
balance between optimal screening and avoiding false rejections. However, for multiple reasons,
signature matching was never a factor in Pennsylvania. Prior to the election, Secretary Broockvar filed
an application for declaratory relief with the Pennsylvania Supreme Court, requesting confirmation that
Pennsylvania law did not require signature verification in either the application process or submission of
MIBs for voting, an application which the ever compliant PA Supreme Court granted and then took the
additional step of prohibiting rejection of MIBs for signature mismatching.
Had not the Supreme Court removed the last possible security or voter identity measure in the
process, the application form itself provided an additional escape route for applicants and MIB voters
not wanting to provide a signature. Such applicants and voters merely had to indicate by making a mark
(presumably an X or some other 19th century signature substitute) that for some reason they were not
able to provide a signature and then have a witness (who literally could be any person on or off the
planet) provide their signature that the applicant or MIB voter providing the X was in fact the applicant
or MIB voter.
Once the application for an MIB was approved and the MIB sent out to the applicant, approval
of the ballot returned to the state or local election board was effectively guaranteed so long as there
were the book
All things considered, one can reasonably conclude that not only did Pennsylvania fail to provide
meaningful fraud prevention measures as part of their MIB application and voting process, for all
practical purposes, they invited fraud. By doing so they prospectively suppressed the vote of every
legitimate voter in the state of Pennsylvania. Having determined that it was indeed possible in fact
relatively easy to obtain a fraudulent MIB by impersonating and stealing the identity of a registered
Pennsylvania voter, the next phase of my investigation involved exploring ways that a properly
motivated and financed party could obtain large numbers of fraudulent MIBs, ideally in a manner that
would pass all screening procedures in the application and ballot validation processes and allow the
implementers of such a scheme to obtain MIBs that in every meaningful way would be indistinguishable
from legitimate, legally obtained MIBs.
Finding #3: A Scheme to Obtain Approximately 200,000 MIBs in the Names of Registered Republican
Voters and Submit These Fraudulent MIBs To Enter Votes For Biden Made Biden’s Impossible
Comeback and Victory in Pennsylvania Possible.
In the interest of providing a more complete explanation for what occurred in Pennsylvania, I
believe there are actually several answers to the question of how Biden managed to achieve the
impossible result in the Pennsylvania 2020 general election, all of which may have played some role in
creating this result. Without question, manipulation and/or alteration of the computer software
systems used to process election results could have played a role, whether initiated or effectuated
remotely or on-site by local election officials. Under ordinary circumstances in which security against
unauthorized tampering was considered a priority, e.g. in the case of any private enterprise that valued
February 15, 2021
Page 11
the integrity of their internal computer record-keeping and processing systems, guarding against and/or
determining whether tampering had occurred would be matters well within the capability of personnel
who designed, operated, and validated the systems in question. However, as we learned in the
aftermath of the November 3 election, these matters were far from a priority in Pennsylvania and other
states. Regulations intended to prevent tampering were routinely ignored; requests for records review
or auditing after the election to determine if tampering had occurred were likewise rejected; assurances
from local and state officials that no tampering could possibly have occurred were accepted as proven
fact. And in the few instances where some steps were taken after the fact to facilitate meaningful audit
and review of computer processes and records, those requesting such audit and review consistently
came up empty-handed, due to resistance or refusals to comply by local officials or mysterious absence
of logs and other records. Meaningful regulations to prevent such tampering should have included (and
in the future should include) routine impoundment of all computer systems for forensic auditing upon
completion of the vote counting processes.
Likewise, any number of unlawful tactics used by local election officials could have contributed
to the fraudulent result, including backdating MIBs submitted after established deadlines, double
counting ballots to inflate Biden’s vote count, random introduction of photocopied ballots voting for
Biden, etc. Although in a climate where security and integrity of the voting process was considered a
priority, detecting such ad hoc unlawful tactics would be a simple matter, in the climate existing in
Pennsylvania, a climate largely established and encouraged by a bureaucracy controlled by democratic
party appointees, suppression of the Trump vote and inflation of the Biden vote were considered proper
and admirable objectives. As for the courts, they have shown themselves across the board to be utterly
unprepared to effectively deal with fraud and other unlawful interference with elections, refusing to
recognize the need for court ordered investigation and expedited procedures necessary to provide
answers within prohibitively short time frames, while at the same time seemingly requiring that
plaintiffs who present proof rather than evidence as the threshold requirement to survive motions to
dismiss.
I began the search in earnest to find the answer to the ultimate question victory with two
constraints in mind: (1) the scheme would have to be scalable to large numbers, which I estimated to be
in the hundreds of thousands of votes, in order to guarantee a Biden victory; and (2) it would have to be
consistent with the DOS data compiled on MIBs, a requirement I believe will be necessary to survive any
postelection validation process intended to reconcile MIBs submitted for voting with the actual vote
count.8 Amidst all the evident irregularities and unlawful tactics, the scheme described in this section
stood out as the only tactic that could specifically account for Biden’s impossible comeback and victory
8
- Although the scheme described herein would in fact have survived any postelection reconciliation process, given the fact that
no such process appears to have been contemplated or undertaken by Pennsylvania election officials leads me to conclude at
this point that this requirement was not essential. This is an important point since it lessens the importance that fraudulent
ballots be obtained through the same processes established for legitimate balance (and therefore included in the data compiled
by the DOS). In other words, some portion or perhaps even all of the fraudulent ballots could have been simply dumped into
the vote counting operations at various times after November 3, without concern for whether the vote numbers would match
DOS MIB statistics.
February 15, 2021
Page 12
all by itself, with no assistance or amplification by other tactics of any kind. Furthermore, this scheme
matched up with known facts about the election in Pennsylvania on so many different levels that I was
reminded of a passage from one of my favorite novels, in which one of the main characters comments
to another character who has somehow appeared in multiple situations at the most inopportune times,
ostensibly by coincidence: “They have a saying in my business: ‘Once is happenstance. Twice is
coincidence. The third time it’s enemy action.’ ” See discussion below on facts supporting the existence
and implementation of the scheme. So closely did the scheme match publicly available data on MIBs
applied for, obtained and submitted for voting and publicly reported events surrounding the election
that for me, the design of the scheme did not require a great deal of imagination or speculation on my
part; in many ways, the scheme revealed itself.
The Scheme
The scheme itself was quite simple. As mentioned above, the principal challenges were
logistical rather than legal or conceptual. It involved applying for and obtaining a large number, in the
hundreds of thousands, of MIBs in the names of duly registered Pennsylvania voters, exploiting the gaps
in the application process (gaps that would have been just as obvious to potential wrongdoers, and
perhaps more so, than they were to me), and then simply marking the ballots to vote for Biden and
submitting them right alongside the multiple millions of legitimate MIBs being submitted for voting.
While it seemed obvious that introduction of a large number of fraudulent ballots all voting for
Biden would swing the election his way, remain to be determined how this could be accomplished in a
manner that would be consistent with the data recorded by the DOS on MIBs submitted for voting – in
other words, in a manner that would allow votes cast to be reconciled with MIBs submitted for voting.
Assuming that the fraudulent ballots were applied for and approved through normal channels and
therefore were already accounted for in the DOS data, where among the 2,528,405 MIBs submitted for
voting could they be hidden? 200,000 fraudulent MIBs (200,000 being a working number I chose to run
these test scenarios) contained within the 1,665,504 MIBs submitted by registered Democrats would do
little to change the ultimate result.9
Considering a scenario where 200,000 fraudulent MIBs might’ve been hidden among the
independent or other MIBs submitted for voting would have a greater impact on the final result, but
likely not enough to guarantee a victory for Biden. 10
9
- The net impact of fraudulent MIBs within the block of Democratic party MIBs would only be to insulate the fraudulent MIB
component of that block from Democratic Party crossover voting. To illustrate more clearly, consider if 200,000 of the
1,665,504 Democratic Party MIBs were actually fraudulent MIBs all voting for Biden (meaning that only 1,465,504 Democratic
party MIBs were actually legitimate) the only net increase over situation where all 1,655,504 MIBs were legitimate would be 7%
of the 200,000 fraudulent MIBs, or 14,000 votes. Hardly enough to make a major difference in the contest.
10
- To consider the impact of this approach, we must first envision the result without any fraudulent MIBs in the independent or
other group – i.e. we would have had 1,665,504 Democratic Party MIBs, 600,455 Republican party MIBs, and only 62,466
independent or other MIBs. Consider that crossover voting would deduct 68,549 potential Biden votes from the Democratic
Party MIBs (7% of the Democratic Party MIBs offset by 8% of the Republican Party MIBs), and his estimated split of the
independent or other voting block would add 55% of 62,466 or 34,356 votes, giving Biden a total of 1,621,311 votes before
introduction of any fraudulent MIBs, 200,000 fraudulent MIBs would still leave him over 100,000 votes short of victory. In
addition, submitting hundreds of thousands of fraudulent MIBs in the independent or other category might raise concerns
February 15, 2021
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The third possibility to consider was a scenario in which 200,000 fraudulent MIBs would be
obtained in the names of Republican voters, and then submitted with votes for Biden. The identity theft
of registered Republican voters was unique to this scenario and important to its success for a couple of
reasons: (1) it would effectively conceal the fraudulent MIBs in arguably the last place anyone would
look; (2) it would be the least likely to arouse suspicion for incongruity with pre-election estimates of
voter participation, since the pre-election expectation was for extremely low Republican use of MIBs;
and (3) most importantly, it would require far less numbers of fraudulent MIBs to achieve the desired
result within the reported numbers of party affiliated MIBs (since it would both lower the number of
expected votes for Trump and raise the actual number of votes for Biden by the same amount, resulting
in a net spread of two X the number of fraudulent MIBs introduced into the system.
In addition, introduction of between 180,000 and 250,000 fraudulent MIBs voting for Biden, but
submitted in the names of registered Republican voters matched the known facts about the election,
including the party affiliated numbers of MIBs submitted for voting and the actual votes cast for the
candidates, to an incredibly accurate degree.
In terms of the numbers, Scenario G of ExhibitA_MathematiciansView.xlsx shows the effect of
220,000 of these fraudulent MIBs on the result of the election. Note that the introduction of these
fraudulent MIBs in this precise manner, without any other factor entering into the equation, accurately
produces not only the ultimate result in terms of votes for each candidate, but almost the exact, and
highly anomalous, result of the MIB votes, with Biden receiving more than 200,000 more votes than
would have been projected without the fraudulent MIBs and Trump receiving the same number less
votes (please refer to Scenario A of Exhibit A). There is simply no other explanation for these results.
For those readers who remain unconvinced, ExhibitB_Election_Fraud_Model.xlsx presents a
more detailed account of the same information.
For those readers of this memorandum who still remain unconvinced,
ExhibitC_FraudBreakdown.xlsx presents an even more detailed account of this information broken down
by individual County. This exhibit is important because it demonstrates not only that the strategy
explains the overall results, but that it also explains the highly publicized results by County.
Understanding the content of Exhibit C requires a little explanation and a certain amount of attention
from the reader:
 Columns B – E display MIBs submitted for voting as of November 3, 2020, broken down by
County, according to the DOS and individual County records.
 Columns F - I display MIBs as actually voted, according to early returns, similarly broken down
by County, in this case slightly adjusted to reconcile with MIBs submitted for voting. 11
among outside observers as to how so many other independent voters were choosing to vote by MIB (since the implementers
of the scheme would not know in advance how many independent or other voters would be voting by MIB. Finally, the strategy
would leave unanswered question of how Trump ended up with hundreds of thousands of votes less than would be predictable
from the Republican party MIBs, crossover voting and is projected share of independent or other MIBs. This saves okay
11
- I use these early numbers for MIBs submitted for voting and MIBs actually voted because they make reconciling the
February 15, 2021
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 Columns J – N display intermediate calculations necessary to translate MIBs submitted for

voting into MIBs actually voted, based on the results of Edison Research exit polls conducted in
Pennsylvania following the 2020 General Election.
 Columns O – T display the projected votes cast based on columns J - N, assuming all MIBs
submitted were legal, i.e. none were fraudulent, compared to actual votes cast. In each case
the third column for each candidate, Column Q for Biden and Column T for Trump, displays the
difference between the projected and actual results. The reason I have gone to the trouble of
plotting this out by County is that the differences between projected results and actual results
conform closely to postelection analyses that attributed Biden’s victory to anomalous voting
trends in certain counties, in particular the seven counties displayed in the first seven rows of
this model, which by no coincidence are the counties including and surrounding Philadelphia.
 Column U displays my estimate of how fraudulent MIBs would have been distributed among
the counties in such a way as to produce the actual results and thereby to explain the
differences between the projected results and actual. The numbers of fraudulent MIBs
estimated, and displayed in column U, while admittedly speculative on my part, are consistent
with a strategy to introduce these fraudulent MIBs in a manner that would be spread out
among Pennsylvania counties in general, and also concentrated in those counties over which
Democratic Party election officials exercised the most direct and absolute control, thereby
minimizing the chances of any vote counting or other election processing scrutiny that might
interfere with the scheme. I have chosen 220,000 as the number of fraudulent MIBs used in
this model is a reasonable compromise and the number of fraudulent, Biden-voting, MIBs
submitted in the names of registered Republican voters.
 Columns X - AC display adjusted MIB and total vote statistics for Trump with the estimated
fraudulent MIBs removed, ultimately reflecting a net number of Republican Party MIBs
submitted for voting of 380,455.
 Columns AD – AJ display adjusted MIB and total vote statistics for Biden under three scenarios
– projected MIB vote result without the fraudulent MIBs in column AH, projected MIB vote
result with the fraudulent MIBs in column AI, and, and last but not least, in column AJ the
actual MIB vote, which is close enough to the projected MIB result with the fraudulent MIBs to
be considered identical.
 Columns AL – AQ display summaries of these various scenarios:
numbers possible, and therefore also make tracking errors in any formulas or computations included in this and other models
similarly possible. Using later numbers would not change the nature or magnitude of the results. The reason I have not used
later numbers is primarily because these numbers cannot be reconciled according to the latest information from the DOS.
According to that information, actual MIB votes cast add up to tens of thousands more votes than are accounted for by MIBs
submitted for voting. While I assume that the DOS can reconcile these numbers satisfactorily, and hope that they intend to do
so at some time in the future, the decision and/or policy makers at the DOS apparently believe there is no time urgency in doing
so, even though this relatively simple exercise would go a long way towards either convincing skeptics that the results of the
election are legitimate or identifying to DOS and others problem areas that need to be investigated.
February 15, 2021
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o Projected Result, No Fraud, All MIBs Legal;
o Actual Result;
o Projected Result, Fraudulent MIBs Removed;
o Projected Result, Fraudulent MIBs Added.
In conclusion, let me re-acknowledge that my estimate of the numbers of fraudulent MIBs

involved in the scheme, along with my hypothesis of the scheme’s very existence, are speculative –
guesses and more simple, understandable terms. Nonetheless, they are most certainly guesses of the
educated variety, not wild.
Merely because it was possible to obtain large numbers of fraudulent MIBs didn’t necessarily
mean that such a thing was accomplished or, if so, how it would have been accomplished. Possible
strategies were evaluated according to the following criteria: (1) scalability – to accomplish the stated
goal, i.e. to guarantee a win for Biden, a strategy would have to be scalable to obtain at least several
hundred thousand fraudulent MIBs; (2) stealth -- accomplishing the stated goal in a manner that would
effectively conceal the infusion of fraudulent MIBs and, of course, minimize the risk of exposure to those
persons implementing such a strategy; and (3) statistical and demographic consistency with known data
on MIBs, including data customarily recorded and reported by the DOS (although ultimately, this third
constraint may have been somewhat unnecessary given the absence of any effort by county or state
election officials to reconcile MIB data as a routine procedure to ensure that the final vote count
included all legal MIBs and no illegal ones). An important factor in evaluating different approaches to
introducing fraudulent mail-in ballots into the vote counting process was whether a given approach
could be reconciled with existing DOS data on mail-in ballots. Indeed, the scheme described here
definitely could be so reconciled, since the fraudulent ballots would have been obtained in advance
through the existing application process (and would therefore be properly accounted for in DOS data).
However, from the responses by Pennsylvania election officials to questions about voting irregularities,
it appears that even such a common sense process as reconciling mail-in the votes cast against mail-in
ballots received from voters is not considered a priority. Nor does it seem likely, even if such a
reconciliation were conducted and a discrepancy identified, that election officials would expend much
effort trying to track down the source of the problem. Consequently, it appears that even a poorly
organized, last-minute scheme to dump large numbers of mail-in ballots for Biden into the system ,
arranged by or with the cooperation of local officials, could have played a role. If such ballots were
simply counterfeit versions of the PA official ballot, they would be without an supporting paper trail, and
so would not be reconcilable with DOS data. However, given the reluctance of Pennsylvania election
officials from the highest state down to the lowest local level to investigate any allegation of impropriety
in the voting or vote counting processes, and the apparent view of the courts in dealing with claims of
fraud or other unlawful interference (i.e. that the standard for surviving a motion to dismiss is
possession of all evidence in hand to prove by clear and convincing evidence that fraud occurred, in
advance, and on the other side of the coin, that verbal assurance from election officials that there was
February 15, 2021
Page 16
no fraud involved in any part of the process was sufficient to disprove any allegation), I don’t anticipate
that any definitive reconciliation will ever be conducted. 12
implementation of the Scheme
Gaps in the processes set up for MIBs were so obvious, occurring in precisely the points in the
process where issues of security and identity should be solved, that the design of the scheme essentially
revealed itself, leaving me dismayed at Pennsylvania State political leadership on both sides of the aisle
who had passed such nonsense, with a special place reserved for those whose only response to criticism
of the system is to smear the source as a conspiracy theorist or promoter of disinformation. The
Pennsylvania rules and procedures for obtaining and voting MIBs made it possible for any individual or
group of individuals to apply for and receive MIBs in the names of Pennsylvania registered voters,
without ever appearing before any state or local election official, face to face, without ever producing an
identity document or a copy of such a document, and without having any personal knowledge or
connection with the voters whose rights were being stolen, apart from routine identifying information –
name, address, party affiliation, voting history, birthdate, registration date, etc. – which the
Pennsylvania legislature and through them the DOS was accommodating enough to make available to
anyone with $20 and an Internet connection.
When appropriately scaled up, there is almost no limit to the number of fraudulent MIBs that
could be obtained and then submitted for voting for. At scale, the scheme could be planned and
implemented by a professional team, taking full advantage of technology and most time relevant
information to fine-tune the scheme to produce victories of predefined margins and demographic
12
- Although legal analysis of the problem is beyond the scope of this memorandum, a few points are worth mentioning. First
and foremost, as referenced in the text, the standards applied by courts are simply inapplicable and unrealistic for claims of
election fraud or other unlawful interference. A truly reasonable standard should begin with a rebuttable presumption that and
election has been free and fair, subject to the burden shifting to election officials to prove that election was in fact free and fair
upon presentation of credible evidence, sufficient to meet a probable cause standard, that it was not. These election officials
are our servants, and it is their solemn obligation to ensure that our elections are free and fair. Another point worth
mentioning, applying specifically to Pennsylvania, and the responsibility for which should have rested with the Republican-
controlled legislature, was that the rules and procedures set up for mail-in ballots were so ridiculously lax that proving fraud of
the sort described in this memorandum is extremely difficult. In order to do so, one would have to go back to the application
process and all documentation related to it (including everything in the registered voters file maintained by the DOS) and
crosscheck every possible identity validation criteria, including specifically signatures (which of course the Pennsylvania
Secretary of State successfully fought tooth and nail before the courts to the point where checking signatures was affirmatively
prohibited by the Supreme Court). And of course, this strategy for determining whether applications were legitimate or
fraudulent would depend on whether local officials complied with their legal obligation to retain all records, which under the
circumstances I strongly suspect we would discover huge gaps, to which election officials (who basically are free to be as
incompetent as they choose) would simply throw up their hands and claimant had no idea what happened, which would of
course be the end of any investigation. There is an alternative strategy for determining whether or not certain applications for
MIBs were fraudulent, which would be to run a survey on all (in this case) Republican applicants who are accounted for in DOS
records as voting to determine those who as a factual matter did not vote. Once determined, the resulting MIB obtained would
by definition be fraudulent. However, there would still be the matter of proving, presumably by clear and convincing evidence,
that the resulting ballot was submitted for Biden, a fact obvious by the outcome and by any reasonable analysis of the MIB
numbers submitted by party and then voted, but still open to dispute without being able to match the application
documentation with the actual voted ballot, which is impossible due to measures intended to preserve the anonymity of voters.
All in all, the whole process is designed in a way that makes proving fraud in MIBs exceedingly difficult, perhaps even impossible
without intervening legislation. new due to
February 15, 2021
Page 17
characteristics, or it could be wielded as a blunt instrument by persons with other interests or priorities.
If it turns out that evidentiary issues described on page 4 this memo (e.g. evidence of the rejection of
hundreds of thousands of applications for MIBs as duplicates; evidence of interstate transport of
hundreds of thousands of MIBs into Pennsylvania that then mysteriously vanished along with the United
States Postal Service vehicle used to bring them in) were the result of such a scheme, I would be inclined
to classify the scheme is used in this election in the blunt instrument category, since there is very little
evidence that election officials on the state, county or local level with the least bit interested in
preventing fraud or other unlawful interference with the election. To the contrary, common sense
interpretation of circumstantial evidence indicates a desire on the part of many of these officials to
facilitate fraud or other unlawful interference with the election.
Pennsylvania law and regulations promulgated thereunder mom provided several options for a
registered voter to vote by MIB. MIBs could be obtained in person, online or by mail -- mail being the
preferred method for persons implementing this scheme for obvious reasons. In person would make
proof of identity a more difficult proposition and would require individual bodies to show up for each
fraudulent MIB obtained. While somewhat more desirable from an implementers viewpoint, online
application would leave a digital trail, more precisely hundreds of thousands of digital trails, that could
potentially be traced to points of origin. Application by mail, on the other hand, had lots of advantages.
Using a hard copy application form, or by reproducing in reprinting the form, the implementers
could mass-produce applications by software configured to pull data from the Pennsylvania Full Voter
Export file. As an aside, given the general outlook of election authorities in Pennsylvania, valuing
convenience and speed over security (and more bluntly, valuing victory for Biden/defeat for Trump over
election integrity), I doubt whether anyone would be alerted by the fact that many forms seem to have
been generated by computer or, if alerted, would be motivated to do anything about it.
Another advantage of using the mail option was one of the more glaring security gaps in the
mail-in ballot application process. As can be seen on the application form, a copy of which accompanies
this memorandum as ExhibitE_PADOS_mailInapplication.pdf, and the related instructions, a voter was
able to designate a different mailing address for delivery of his or her mail-in ballot (section 4 of the
application). Simply by requiring that the ballot be sent to the residence address listed on the voters
registration file, Pennsylvania could have effectively shut the door on this scheme, or made its
implementation significantly more difficult. In this case, the conspirators could simply program
alternate mailing addresses into their computer program, thereby including it in the mass-producing
process, and effect delivery without the registered voter in question ever having any idea that his
identity and right to vote had been stolen.
The last items to address are the weak and inadequate measure by which state of Pennsylvania
provided that these applications be validated and the identity of the applicant proven. Section 5 of the
application allows the applicant to validate his identity by providing his or her Pennsylvania driver’s
license or state ID number, or failing that, the last four digits of their social, or failing that, gives other
borderline ludicrous alternative options -- including an ID from a Pennsylvania institution of higher
February 15, 2021
Page 18
learning (I did not bother to follow-up to determine exactly what constitutes an institution of higher
learning in Pennsylvania; however, my guess is that broad interpretation is applied to all three operative
words – institution, higher and learning). That said, the laxity of the first three criteria opens the door
more than wide enough for any enterprising implementer of the scheme to pass muster. Although
Pennsylvania, as does most other states, technically does not make ID numbers or Social Security
numbers available to just anyone, a reasonably competent private investigator can obtain can obtain
these numbers for relatively limited numbers of citizens, whether registered to vote or not, given the
intensely political nature of this election in particular, the known willingness of the Democratic Party to
go to any length defeat Trump, and the fact that Democrats controlled the Pennsylvania governorship,
the Secretary of State’s office, and election boards in all critical swing counties, I believe it is safe to
assume that the implementers could obtain whatever qualifying ID numbers they desired. It is also
worth pointing out that to meet the criteria for any of the identity proof options, is not necessary or was
not necessary to present the original document or card, or even a photocopy in the case of ID numbers
and Social Security numbers, or the original document or card in the case of college IDs and other similar
alternative “proofs.”
Removing the Final Barrier to This and Similar Fraudulent Schemes
Most states have instituted signature matching in one form or another as a means of identity
proof for MIBs. Disregarding the impracticality and operational difficulty of burdening minimally
trained temporary employees with the obligation to match signatures, and the known methods of
circumventing automated mechanisms for signature matching (e.g. broadening the degree of conformity
of one signature to another an signature software matching systems to the point where virtually no
signatures are kicked out as non--matching), the state of Pennsylvania make sure that signature
matching would not stand in the way of approving either application for MIBs or MIBs submitted for
voting by omitting mention of signatures as identity proof criteria in MIB enabling legislation, an
omission that was then interpreted by the PA Supreme Court as expressly prohibiting rejection by
signature mismatch. Commenting upon the “wisdom” of the court’s decision, Senior election officials
noted that since proof of identity was completed at the application stage, there was no need for any
subsequent proof of identity when MIBs were actually submitted for voting, other than confirming that
address and some sort of signature facsimile had been entered on the outer envelope for those MIBs.
This was of course excellent news for implementers of the fraudulent scheme, since it meant that once
applications had been approved and MIBs delivered to the applicant, the scheme was for all purposes
complete, and the result the scheme was intended to guarantee assured.
All of this was adeptly and amply obscured by the cooperation of the mainstream media in
driving home the message that mail-in ballots were no more vulnerable to fraud than in person, election
day voting (a classic Alinsky/Nazi/Marxist propaganda tactic).
Completing the Scheme
February 15, 2021
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At this point the scheme to defraud the election is almost complete. After collecting the
fraudulent ballots from the various mail drops they had set up (referring here to mail drops that would
have been set up by the persons behind this scheme to receive the fraudulent mail-in ballots, not the
ballot mail drops set up by the state of Pennsylvania for voters to deliver their ballots to the state) 13, the
final processing stage would have evolved opening the delivery envelopes, extracting the ballots,
completing the ballots to record votes for Biden, loading the completed ballots into the secrecy
envelope, inserting those options into the outer mailing envelope, which would’ve already been filled
out with the appropriate information, complete with signature facsimile, every step of which could have
been automated. Finally, the implementers would have their choice of a number of methods to actually
deliver the completed ballots to various election boards – by regular mail, by dropping the ballots into
numerous drop boxes, or even by simply delivering them under cover of darkness in bulk, to be
processed dated whatever by complicit local election officials. 14
As the above description indicates, the principal challenges in executing this scheme would be
logistical – organizing the process, obtaining through various available sources the required information
on Republican registered voters, arranging physical facilities to house the processing operations,
obtaining automated equipment, etc. etc. And of course, last but not least the operation would have
required significant financing, which would have been absolutely no problem to obtain from any number
of sources, some of which are mentioned below in other sections of this memorandum (e.g. Zuckerberg
in particular, whose financing of democratic election operations, which should have been blocked by the
courts regardless of black letter law, since the law in almost every respect was simply not prepared to
deal with any of the fraud that occurred in this election; that said, given the support of democratic
politicians and appointees in key states and jurisdictions and the massive propaganda campaign that had
been underway by the mainstream media for the last four years, Zuckerberg not only got away with his
efforts to essentially purchase the election for Biden, he was able to flaunt it).
Evidence that the Scheme Actually Occurred
There is abundant evidence that the scheme described in this memorandum to obtain and
submit fraudulent MIBs in the 2020 General Election Evidence was actually implemented and did in fact
produce a victory for Biden that would not, and in fact could not, have otherwise occurred. In no
particular order, this evidence includes:
13
- It is entirely possible that the implementers of this scheme could have had the MIB sent to a handful or even fewer mail
drops, given the evident disinterest of election officials in Pennsylvania to secure the process or question any application or MIB
submitted. From the beginning, all evidence pointed to a policy fully endorsed by the Secretary of State and Governor not to
stand in the way of any application for mail-in ballot or any mail-in ballot actually submitted for voting, all in the name of "not
suppressing the vote," when in reality the effect of this policy was to suppress the vote of all legitimate registered voters voting
for Trump. There is simply no other way to justify or interpret the way election was handled across the board at the city,
county and state levels.
14
- Reference the well-known account of the USPS employee reported transporting a truckload of MIBs from New York State
into Pennsylvania, numbering in precisely the range that would've been required to fully implement this scheme. See below at
page **. This employee's account, while well-known and properly reported on all levels, including in several court filings, was
never legitimately investigated, yet one more indication of the tragic fact that the fix was in on the selection on virtually every
meaningful level.
February 15, 2021
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 Data Compiled and Reported by the Pennsylvania DOS. This evidence has been covered in the
text of this memorandum and the attached exhibits. It shows conclusively that but for
introduction of approximately 200,000 fraudulent MIBs submitted in the names of registered
Republican voters with votes for Biden, the resulting vote totals for Biden and Trump,
respectively, simply could not have been produced by the MIBs submitted, according to the
overall number of MIBs submitted for voting, the party affiliation of the voters submitting these
MIBs, and known election metrics by which actual votes cast for the candidates can be reliably
and accurately estimated from those numbers compiled and reported by the DOS. The relevant
metrics are: (a) crossover voting rates, i.e. percentages of registered Republican and Democratic
voters in Pennsylvania determined by exit polls to have voted for the candidate of the
opposition party, which allow us to reliably estimate the number of registered Republican voters
voting by MIB who voted for Trump, and those who crossed over to vote for Biden, and similarly
the number of registered Democratic voters who voted for Biden, and those who crossed over
to vote for Trump; and (b) the percentage of registered third-party and independent voters in
Pennsylvania who voted for Trump, and those who voted for Biden, also based on exit polls,
which allow us to reliably estimate the number of independent voters voting by MIB who voted
for Trump and those who voted for Biden. Even allowing for frankly absurd deviations from the
percentages determined by exit polls universally acknowledged as the most comprehensive and
accurate, those performed and compiled by Edison Research, there is simply no way that the
actual results could have been produced. In fact, results produced by using the percentages
reported by Edison Research for crossover voting and the split of independent votes between
the candidates, show Trump winning the election in Pennsylvania by an overwhelming margin of
approximately 350,000 votes.
 News Reports on or about October 10, 2020 that Approximately 336,000 Applications for MIBs
in Pennsylvania Were Rejected As Duplicates. On or about October 10, 2020 (depending on the
publication or media outlet), a story broke across multiple news outlets in Pennsylvania and
nationwide that 372,000 applications for mail-in ballots in Pennsylvania had been rejected, most
of which, approximately 336,000, were rejected, according to the Pennsylvania DOS, because
they were duplicates – meaning that an application had already been received for these 336,000
rejects. https://www.post-gazette.com/news/politics-state/2020/10/16/pennsylvania-rejected-
mail-ballot-applications-duplicates-voters/stories/202010160153. The official response from
the DOS and other Pennsylvania government offices was that these were probably due to
registered voters who voted in the 2020 primaries checking the box on their applications or
mail-in ballots at that time to sign up for automatic mail-in ballots for the future, which
according to the DOS would have resulted in any subsequent application being rejected as a
duplicate (which seems a bit of a stretch since checking the box on the primary application or
mail-in ballot would not technically have constituted making application for a mail-in ballot for
the general election, it simply would have been a red flag that any subsequent application by
the same registered voter would be redundant and could otherwise be ignored). No official
February 15, 2021
Page 21
investigation was launched to determine the actual cause of all these duplicate applications, and
none of the entire 372,000 rejections were recorded and made a part of subsequent data
reports on mail-in ballots, for reasons unknown. Perhaps the DOS wanted to preserve the
record of perfect management of the mail-in ballot process, and what better way to do so than
simply to pretend that a major snafu didn’t happen. The inconvenient truth is that duplicate
applications would have been the principal symptom of precisely the sort of scheme to obtain
fraudulent mail-in ballots described in this memorandum. The principal element of the entire
scheme was that the implementers would have submitted applications for mail-in ballots in the
names of registered Republican voters without their knowledge or consent; and that if some of
these voters subsequently decided to apply for mail-in ballot, their applications would’ve been
rejected as duplicates since the DOS would’ve already had the fraudulent application on file.
Alternatively, if the registered voter had actually applied for a mail-in ballot, the fraudulent
application, if filed subsequently, would have been rejected as a duplicate. Either way, this
problem constituted the reddest of red flags that a scheme to obtain fraudulent mail-in ballots
was underway. However, true to their agenda (which was that entire mail-in ballot process was
bulletproof against fraud, the administrative and executive branches of the Pennsylvania
government did absolutely zero to investigate this problem. Even the most cursory investigation
would very likely have revealed that many, if not most, of these 336,000 duplicate applications
were either rejected because a fraudulent application (meaning and application that was filed
by someone other than the registered voter) was already on file or because the second rejected
application was filed by someone other than the registered voter. As noted in section** below,
there are multiple ways that fraudulent applications could have been flag by a screening process
run on all applications received, once it became apparent that this problem existed.
 United States Postal Service Truck Transporting Hundreds of Thousands of Mail-In Ballots from
New York State to Pennsylvania Mysteriously Disappears – I refer here to the news item
reporting that Jesse Richard Morgan, a USPS driver, transported somewhere between 200 and
350,000 mail-in ballots from New York State to Pennsylvania, and specifically to Lancaster,
which just happened to be the one County in addition to the counties immediately surrounding
Philadelphia County where, according to my analysis, the vast majority of fraudulent MIBs
turned up. See ExhibitC_FraudBreakdown).xlsx, column U (the estimates of probable numbers
of fraudulent MIBs being introduced in the various counties is based on the difference between
what the vote count was projected to be, based on Edison Research’s exit poll estimates of
crossover voting and percentage split of independent MIBs, and the actual vote count, which for
all of the counties immediately surrounding Pennsylvania County, plus Lancaster County, were
wildly different in ways that could not be explained by any recognized voter or election metric,
but which could be perfectly explained by introduction of large numbers of fraudulent MIBs
applied for and obtained in the names of registered Republican voters and then subsequently
submitted with votes for Biden. Not only do the number of ballots transported by Jesse Morgan
matchup closely with the amounts that would have been required to deliver this fraudulent
February 15, 2021
Page 22
victory to Biden, but the other facts associated with Jesse Morgan’s truck and what passed for
the investigation of this matter by the authorities also point suspiciously towards fraud or some
other as yet unexplained irregularity. Regarding the truck, according to Morgan, there were no
procedures or precautions taken to ensure the security of these MIBs being delivered. Neither
was there any explanation for why this huge number of MIBs would’ve been transported from
New York State to Pennsylvania (although it’s perfectly sensible that the implementers of the
fraudulent strategy described herein would have processed the applications and the MIBs
actually submitted out-of-state for a number of reasons that anyone with common sense should
be able to imagine). Most concerning about this whole situation was the fact that no
investigation to speak of was ever held other than attempts by the authorities to convince Jesse
Morgan to recant his account and apparently by some sources, threats made to his relatives.
Numerous news outlets confirm all the facts I have just stated. The video of Morgan’s public
statement is also very informative. https://www.youtube.com/watch?v=Np6gBU3H1BU. Lastly,
and consistent with the cover-up that was facilitated and supported by the mainstream media
from the get-go on the selection, one can also find numerous reports of “fact checking” by
numerous outlets that purportedly discredit or contradict Morgan’s own account of these
events. We should be so fortunate that “fact checking” is a simple as Facebook and mainstream
media make it out to be, because were this actually the truth, and “fact checking” such an easy
exercise, we could soon do away with such expensive and inefficient institutions as our court
system and a tremendously wasteful and equally inefficient processes, like trials and other
mechanisms of due process, there were originally designed to ensure our constitutional rights,
but now have been casually cast aside in favor of “fact checking”.
 Investigations And Findings Reported by Matthew Braynard -- Matthew Braynard, a well-
respected political consultant and election analyst, provided a number of insightful reports to
attorneys filing lawsuits on behalf of Trump in a number of different state and federal courts,
and notably to the attorneys representing the state of Texas in their action filed directly with the
US Supreme Court. The Texas Complaint in intervention references Braynard’s work frequently
for multiple states, including Pennsylvania.
https://www.supremecourt.gov/DocketPDF/22/22O155/163392/20201214094636058_SCOTUS
%20Complaint%20in%20Intervention%20Final%2012-10-20.pdf. Braynard actually set up a call
center to make phone calls to registered voters in Pennsylvania who, according to DOS records,
had applied for and/or submitted MIBs, his purpose being to estimate the number of these
registered voters who were accounted for by the DOS as voting but who actually did not vote –
probably the number one evidentiary indicator of fraudulent mail-in ballot voting. Based on
extrapolating a small sample out to statewide numbers, Braynard estimated that approximately
54,000 registered Pennsylvania voters had fraudulent MIBs applied for and voted in their
names. See above Complaint in Intervention, page 30, and PA Declaration of Matthew Braynard
Appendix pg. 1331-1340, attached thereto. I believe the actual number to be significantly
higher, more consistent with the scheme described in this memorandum, although Braynard’s
February 15, 2021
Page 23
analysis by itself should have been far more than enough for any court to sustain a complaint
and permit discovery to proceed, the dismissal of the Texas Complaint being simply one more
example of the pervasive inability of courts to adapt their rules reasonably to the unique
circumstances presented by alleged election fraud. Needless to say, the consistent opposition
to any investigation by the Pennsylvania Governor and the Secretary of State simply confirms
their incompetence and bias. Truth be told, various governmental agencies and offices in
Pennsylvania and other states should have welcomed any and all efforts to investigate the
manner in which the election was held and results processed within their borders, if only to
confirm the integrity of the processes they so vociferously claimed were bulletproof.
 Zuckerberg -- What can you say about Mark Zuckerberg, who single-handedly did more to
ensure corruption and bias in the selection than any individual, organization, state, or sovereign
state (including China, assuming that China and Zuckerberg weren’t acting in concert)?
Zuckerberg’s contribution of almost $400 million exclusively to election processing operations in
critical city and County jurisdictions in swing states is perhaps the single most anti-American,
antidemocratic course of action ever undertaken in this country. I am aware that objections
were filed to the huge amounts of money he was pouring into these various jurisdictions, all of
which was directed to ensure that mail-in balloting would be as heavily promoted, loosely
supervised and overall corrupt as possible. Yet, in every case, the courts were universally unable
or unwilling to look past black letter law as reflected in legislation then in effect (which very
likely had never anticipated that one individual would have so much access to obscene amounts
of money that he or she could throw around hundreds of millions of dollars as if they were so
much confetti), and use their common sense, interpretive license, and desire to act in the best
interests of the United States of America to prevent Zuckerberg literally from buying the
election for Joe Biden. In Pennsylvania specifically, huge amounts of money from Zuckerberg
were poured into the critical counties surrounding the city of Philadelphia, which according to
the quantitative analysis presented in Exhibit C, attached hereto, is where most of the fraud was
concentrated, i.e. most of the fraudulent MIBs were introduced into the vote count. For a
detailed analysis of Zuckerberg’s unlawful, if not technically illegal, purchasing of the election,
please see Press Release, https://www.wfmj.com/story/43065534/press-conference-major-
new-report-exposes-how-mark-zuckerbergs-500-mil-caused-chaos-influenced-the-2020-
election, and the PowerPoint attached to this memorandum as ExhibitF_FINAL-PP-
AMISTAD.pptx. Of particular interest is the $50 million donated by Zuckerberg and his wife to
the Center for Election Innovation and Research (“CEIR”), a hard left shell 15 nonprofit
15
- I refer to CEIR as a shell organization because by all appearances, it serves no purposes other than to promote David Becker.
It purports to be dedicated to election security matters, among other things, although among the persons listed on its website
as employees or operatives, not a single one, including Becker, has any background or demonstrated expertise in election
security on a technical or operational level. https://electioninnovation.org/. In fact, examination of its most recent tax returns
show that Becker is the only person drawing a salary -- in other words, none of the so-called employees or operatives actually
work for the organization on a regular basis. Furthermore, although by its very title, CEIR purports to be a "research"
organization, over the entire four years of its existence, the only purportedly technical/research document it has produced,
entitled the “2020 VRDB (Voter Registration Database) Security Report”, is nothing more than a rehash of general information
February 15, 2021
Page 24
organization run by a man named David Becker, who has a long-running reputation for hard left
politics and unethical, unprofessional actions. See panel 19 of Exhibit F. Becker, through CEIR
and another nonprofit entity he helped found when he was associated with the PEW trust called
“ERIC”, short for the Election Registration Information Center, had full access to all voter
registration records for Pennsylvania, including driver’s license and ID numbers and Social
Security numbers. Although the $50 million ostensibly was donated to CEIR to be handed out to
grant applicants from various state and local jurisdictions, I have only been able to find records
supporting a few million dollars of grants actually made by CEIR, leaving one to speculate on
what might have been done with the remaining $45 million plus donated by Zuckerberg. For
some relevant insight on Becker’s politics and his ethics, see, e.g.
https://legalnewsline.com/stories/555822683-mark-zuckerberg-beneficiaries-promoting-fair-
elections-not-exactly-non-partisan-as-advertised. One attribute of the fraudulent scheme
described in this memorandum that I believe can be confidently predicted is that it would have
required significant amounts of funding as well as significant knowledge of Pennsylvania’s
scheme to manage mail-in ballots (as well as the different but equally porous schemes enacted
in other swing states), an utter lack of ethical standards, and a hard left political outlook willing
to sacrifice arguably the most important right granted to citizens under the Constitution – the
right to vote – in the self-interested pursuit of political power. CEIR and Becker fit this profile to
a very troublesome degree.
Further Investigation to Validate Existence of the Scheme
There are a number of avenues available to validate whether or not a scheme of this magnitude
was implemented. In addition to thoroughly investigating all of the above referenced evidentiary
matters, I believe much could be learned by surveying registered Pennsylvania voters to determine
the full extent and demographic characteristics of those voters who are recorded by the DOS as voting
in the election by MIB but as a factual matter, did not vote. Matt Braynard had the right idea in setting
up his own call centers to run preliminary surveys to estimate numbers of this type of fraudulent MIB
votes, although I believe a more thorough, more professionally conducted, and more targeted
approach is warranted. One of the objections made by opposing counsel to Braynard’s conclusions was
that his extrapolation of survey results to the overall population was amateurish or unjustified. This
problem is easily remedied simply by retaining a professional firm to do the survey, with demonstrated
academic and experiential qualifications to calculate overall population findings from survey results. In
addition, based on my quantitative and qualitative analysis, I believe a much more targeted approach
would be warranted – namely, surveying registered Republican voters listed in DOS records (which are
available to the general public, in which I have already obtained) in the counties in which the strategy
any college student could have thrown together from publicly available reports. https://electioninnovation.org/2020-vrdb-
security-report/. As a former securities attorney specializing in early-stage venture capital financing, the author of this
memorandum knows a sham organization and a fictitious background story when he sees one, and CEIR fits the bill. It is also
relevant that the organization's budget has never exceeded $1 million in its four years of existence, which should raise
questions as to why Zuckerberg would entrust $50 million to it. The tax returns for CEIR for the years 2020 and 2021, should
make interesting reading, especially concerning the disposition of Zuckerberg’s $50 million.The organization two
February 15, 2021
Page 25
appears to have been concentrated. This would effectively convert a shotgun investigative approach to
a small target sharpshooter approach. Assuming my analysis to be substantially correct, i.e. that the
fraudulent MIBs would have been submitted and the names of Republican registered voters and
would’ve been concentrated in the counties surrounding Philadelphia city and county, as calculated in
ExhibitC_FraudBreakdown.xlsx, Column V, the probable percentages of fraudulent MIBs as a component
of total Republican MIBs submitted for voting are shocking. It should not take a properly qualified and
experienced telephone survey company to substantiate these sorts of numbers. Once substantiated on
a survey basis, and properly extrapolated to the overall population of registered Republican voters in
these counties, a more granular follow-up can be conducted to identify a relatively huge number of
witnesses willing to testify that their identities and rights to vote were stolen. One gap in putting
together this data as a component of legal proof, which would surely be raised by opposing counsel,
would be that notwithstanding theft of identities and voting rights, it is impossible to determine for
which candidate the fraudulent MIBs were actually voted. That said, the numerical analysis showing
that Biden could not have achieved the total votes attributed to him unless these fraudulent MIBs were
cast for him should be powerful and convincing evidence for any jury. In addition, the mere fact that so
many fraudulent MIBs could have been cast right under the nose of the DOS in Pennsylvania should be
enough to cause any human being with a modicum of common sense to conclude that the election in
Pennsylvania was seriously mishandled and the results entirely unreliable.
Many people may believe that continuing investigation of fraud and other unlawful interference
in the 2020 presidential election is pointless, given that Biden has already assumed the office. This
author strenuously disagrees. It is important not only to expose the illegitimacy of the man and woman
who currently occupy the offices of president and vice president, respectively, but also should be
considered highly relevant to amending the laws and processes currently in place for mail-in balloting
throughout the country to prevent this kind of fraud from occurring in the future. Equally important,
President Trump deserves to have his reputation restored and his rightful claim to the office of president
acknowledged. The American citizens who voted for Trump deserves to have their votes rightfully
acknowledged. And lastly, thorough and unrelenting investigation of the fraud that occurred in the 2020
presidential election should have as its ultimate objective identification of the parties who ordered,
financed, and conducted the fraud.
About the Author:

Geoffrey Riggs is a professional with a background uniquely suited to tackling this problem. He
has a B.A. degree from Harvard University in economics, with a minor in applied mathematics, and a J.D.
from University of Southern California. His professional experience includes 10 years as a business
executive specializing in finance and qualitative/quantitative analysis, two decades as a practicing
attorney specializing in securities and corporate finance, and finally the most recent decade as a
computer software designer and architect, whose principal project involved development of software to
organize and auto classify large databases containing business and financial information for over 1
February 15, 2021
Page 26
million public and private business enterprises. This most recent work utilized a unique talent Mr. Riggs
possesses for identifying relationships among different data elements within a system and designing
mechanisms to segregate, classify, evaluate and compare these elements by mathematical formula.

Geoffrey Riggs: Park City, Utah 310-562-8373

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TO: Sidney Powell

 Creation of several computational and predictive models emulating processing of election-

 Columns J – N display intermediate calculations necessary to translate MIBs submitted for

o Projected Result, No Fraud, All MIBs Legal;

o Projected Result, Fraudulent MIBs Removed;

o Projected Result, Fraudulent MIBs Added.

In conclusion, let me re-acknowledge that my estimate of the numbers of fraudulent MIBs

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