Julie Levin, Mark’s wife, was part of the successful repeal of ‘no excuse’ absentee ballots in Pennsylvania. While pundit Andrew Wilkow mistakenly blames this on judges exceeding their jurisdiction, it was actually the PA legislature who passed a law allowing it without checking their own state constitution.
We have incompetent legislators who are weak in constitutional law, and/or don’t read bills and analyze their consequences.
Here is the text of the letter send March 6, 2023:
Re: Absentee Ballots and Harvesting Unconstitutional Under Equal Protection Clause
Post-2016 Election Laws are the New ACORN
Repeal of No Excuse Absentee Ballots and Ballot Harvesting is a Prima Facie case
Pennsylvania No Excuse Ballot and Ballot Harvesting in Arizona Declared Unconstitutional
The beauty of a Prima Facie case is that once the elements of unconstitutionality are established, it is the burden of the defendants to prove those elements don’t exist or do harm.
In Arizona’s Brnovich vs DNC, the court held that it was a state’s legitimate interest preventing fraud so “citizens cast ballots with appropriate weight,” i.e., the vote reserved for ‘qualified citizen voters.’
While Pennsylvania’s constitutional challenge specified violation of specific conditions required in their state constitution, the unconstitutionality of accepting ‘no excuse’ and ‘harvested’ mail ballots is a general matter of constitutional rights. It is a matter of public policy based on equal protection viz-a-viz ballot integrity, and banning disenfranchisement of ‘qualified citizen’ voters. This has precedent over any claimed ‘civil rights’ of those who claim Proof of Citizenship an unacceptable burden.
The prima facie case, therefore, also relies on the state proving mass mail databases used by Ballot Harvesters do not include illegal aliens who were issued drivers’ licenses or receive social services.
Unlike apportionment of federal funds and, in some states, enough illegal aliens counted in the census to add electors to the Electoral College, the inferior mail ballot and No Proof of Citizenship in voter registration has become a great enough issue to alter election outcomes; and estimates of illegal aliens reached by ‘ballot harvesting’ are enough to have changed the 2020 election from Trump to Biden.
There are enough illegal aliens in sanctuary states and cities in Georgia, Nevada, Arizona and Wisconsin to have flipped the 2020 election from Trump to Biden, and by less than 1%. In GA, the flip was Trump with 2X Biden’s votes to a 0.22% margin of victory. In Arizona, the flip was by .33%, Wisconsin by .65%, and Nevada by 2.49%. Those four states alone, with illegal alien populations many times those margins, were 42 electors. Trump only needed 38 of those to win.
If recent Ballot Harvesting and No Excuse Absentee Ballot laws are not repealed, Republicans will never regain political power
Republicans do not have to prove that mail ballots were used to undermine election integrity, or if the outcomes of 2020 and 2022 were compromised and corrupted.
All Republicans need to do is file a ‘prima facie’ case in the U.S. Supreme court, declaring that due to No ID, No Proof of Citizenship, and two standards of ballot exist, the recent and massive abuse of the mail ballot disenfranchises ‘qualified citizen voters,’ and violates the Equal Protection Clause.
Massive mail ballot harvesting is less valid than the ‘in-person’ vote. Dr. Shiva of the Arizona Audit proved that signature verification was unreliable, and some reports revealed county clerks merely ‘rubber stamping’ applications for absentee ballots. In Colorado, a Secretary of State admitted she mailed voter registration cards to at least 31,000 illegal aliens.[1]
Recently, Donald Trump and Republican pundits admit that if Ballot Harvesting flipped 2020 to Biden, then they’d ‘have to play the game.’ This isn’t news. A 2021 Philadelphia Inquirer article chided Republicans for not taking advantage of the new Ballot Harvesting and No Excuse Absentee Ballot laws, passed in state legislatures after Hillary lost 2016.
Here are the graphics from that article:


Note, that while Trump led on Election Night with 2X Biden’s votes, days of ‘counting’ mail ballots flipped 2020 to Biden by 1.2%. While Trump’s mail ballots were consistent with previous elections, Biden’s mail ballots were 60% of his vote.
While the Philadelphia Inquirer article ridiculed Republicans, WE DO NOT TRUST election workers to ‘vote our ballots for us.’ That is what happened in Arizona in 2022. The MCTEC sabotaged the ballot printing machines to disenfranchise the massive in-person Maricopa turnout.
In effect, Hobbs and the MCTEC took possession of the rejected in-person ballots, denying Republicans their right to ‘vote their own ballots.’ In every state, ‘voting someone else’s ballot’ is illegal, but the new mail ballot laws exempt election workers who tabulate the ballots in scanning machines and ‘cure spoiled ballots’ at ‘adjudication’ desks. One of the most infamous videos showing this were the Fulton County workers chasing observers out of the counting room, pulling ‘boxes of ballots’ out from under tables, and scanning them furiously until 1AM.
Those mail ballots were shown on the tabulation center real-time updates flipping Trump’s 2X Election Night lead to Biden winning by 0.22%, less than 11,000 votes. This graphic shows this trend in other states, Trump’s huge in-person victory flipping to Biden from mail ballots.

In New Mexico, promotion of mail absentee ballots by Democrats, thanks to their 2018 Absent Voter Act, doubled mail ballots from 20% to 40% of the vote. Again, like Pennsylvania, while Republican mail ballots were consistent with previous elections, Democrats got 3X as many. 235,000 (D) to 83,000 for Republicans, a difference of 152,000; Biden won New Mexico by 99,720 votes.
Pew Research estimates 63,000 illegal aliens in New Mexico, but the last report was 96,000 were issued driver’s licenses and the number may be even higher. I did not include New Mexico in the spreadsheet as their potential illegal population isn’t a multiple of the margin of victory.
WHY MAIL BALLOTS ARE UNCONSTITUTIONAL
Limited use of the absentee ballot is justified, and should be reserved for defined acceptable excuses from voting in-person. However, with the new No Excuse absentee ballots, ballot harvesters take advantage of NO ID and NO PROOF OF CITIZENSHIP, and inferior ‘hand’ verification. This creates an UNEQUAL vote, unconstitutional under the Equal Protection Clause and constitutional laws forbidding of even fractional ‘disenfranchisement of qualified citizen voters.’
Here is a quote from Brnovich vs DNC (2021):
Fraud can affect the outcome of a close election, and fraudulent votes dilute the right of citizens to cast ballots that carry appropriate weight,” the Court continued. “Fraud can also undermine public confidence in the fairness of elections and the perceived legitimacy of the announced outcome. . . The state has legitimate and important interests in ensuring even distribution of voters among polling places and preserving the integrity of election procedures. Brnovich vs DNC – 594 U.S. ___ (2021)
So, the ‘legitimate state interest’ is in PREVENTING POTENTIAL DISENFRANCHISEMENT, not for the courts to require Republicans prove Democrats actually cheated, and by how much.
Without delay, Republicans MUST file an for injunction and/or repeal of these new Ballot Harvesting laws, because the inferior and inadequate verification of voter registration is merely the reincarnation of ACORN, the voter registration fraud James O’Keefe uncovered ten years ago.
ILLEGAL ALIENS CORRUPTING OUR ELECTIONS
In 1993, Democrats rammed through Congress the National Voter Registration Act, making it illegal—illegal—to require proof of citizenship that prevents illegal aliens and noncitizens from registering to vote. Why did Democrats do that? Simple. To steal elections, of course. Rep. Mo Brooks objecting to Arizona Electors on January 6, 2021 Congressional Record, January 6, 2021 Pg H89
The following spreadsheet compares large illegal alien populations to miniscule margins of Biden victories in four states. Those fours states, won by merely 77,000 votes, have at least 850,000 illegal aliens ripe for harvesting. https://ballotpedia.org/Automatic_voter_registration
Trump only needed 38 Electoral Votes to preserve his Election Night landslide; these four states accounted for 42 electors. Three of them had Trump ahead by 2X, but flipped by less than ½ of a percent. How many of those 77,000 votes were ballots harvested from illegal aliens? Consider that at least 850,000 illegal aliens are estimated living in those four states.

CONCLUSION:
‘Playing the game’ is impossible, for it puts Republicans in potential violation of the 1996 Illegal Alien Reform and Responsibility Act.
Registering to vote, or voting in a federal election, by persons who are not entitled to vote under applicable state law, most notably persons who have committed serious crimes, and persons who are not United States citizens (18 U.S.C. §§ 1015(f), 611, and 52 U.S.C. § 20511). Falsely claiming United States citizenship in connection with registering to vote or voting in any election (18 U.S.C. §§ 911, 1015(f)). Voting in a federal election by anyone who is not a United States citizen in those States where citizenship is a requisite for the franchise (currently all 50 States) (18 U.S.C. § 611)
Again, there is enough precedent to file in the U.S. Supreme Court to end Ballot Harvesting and the No Excuse Absentee Ballot, but it needs to be filed ‘yesterday.’ 2024 waits for no one.
Sincerely,
Leonard A. Daneman
Paralegal
[1] https://www.theepochtimes.com/watchdog-group-clashes-with-colorado-secretary-of-state-over-31000-non-citizens-who-were-mailed-voter-registration-information_4970273.html
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