Remaining defendants may raise any factual or legal issues that are specific as to that particular defendant, do we agree that that would be the best way to proceed . Good afternoon, i would like to take the lead. If any other lawyers have any other we would do a little round robin if everyone is going to be acknowledged. I dont think i need an Opening Statement but i will give you the opportunity to make one, i have Read Everything that has been docketed, there are a couple minuscule issues i want to take up. You can reasonably anticipate with his desk what those issues will be. Let me just make sure before i to Opening Statements clarify a few items, make sure we are all on the same page, i think we all are. The plaintiff amended a complaint which was filed this has essentially removed several counts from the original complaint. As i understand now, the only two remaining counts are for alleged violations of equal protections clause of the 14th amendment and the electoral clause, am i correct . That is correct. And to the ash do the plaintiffs agree that the United States court of appeals opinion at the end of last week that the plaintiffs cannot assert standing in this circuit to raise their elections and electors clause claims . Yes, the only clarification seekat we are going to comparative to amend this complaint to restore our due process claim which was mistakenly removed. But we are withdrawing we are preserving for appeal the elector and elections clause, but we will not be proceeding on that. That is one of the issues i would like to talk about at the end of the oral argument. Then, circle back to you we will attend to that issue about a further amendment to the complaint. Claim only outstanding really before this court at this point is the equal protection claim. Speaking for your collective defendants do you agree . Agree, your honor. Thehe plaintiffs bear burden of proof, so ill ask them to present first, mr. Giuliani, go ahead. Your honor would you like me to is it is the easiest for counsel to speak from the table . Thats fine. If you need to use the podium you are welcome to do so, we have just found that during this remained seated at the counsel table, it is not my general preference but i understand. Court, myplease the name is Rudolph Giuliani and i am here on behalf of the plaintiffs, i think the court very much for allowing me to be admitted. Your honor the best description of what we are alleging and again on a motion to dismiss our allegation has to be deemed to be accurate and true, of course that is subject to testing during the hearing. The best description is the situation to widespread, nationwide voter fraud of which is the daypart and that is part of the reason i am here because this is not an isolated case, it is a case that is repeated in at least 10 other jurisdictions. It seems to me in the words of is one of those situations where you never let a serious crisis go to waste. It is an opportunity to do things you think you could not do before. Specifically, the crisis of the pandemic that was taking place. The opportunity to do something had been resisted for two decades which is to create a widescale, open mailin ballot process which we had been warned about by none other than jimmy baker in ajames report they did in 2006 i believe on election reform. They very seriously want us quote mailin ballot and is the Largest Force of voter fraud. I dont think there is any dispute about that, mailin ballot ding is extremely balloting is a stream a dangerous and can be used for voter fraud. We believe in this case we are going to prove that former president carter and former secretary aker were baker were prophets. This new mail and system which i said president carter warned timest, even the new york wrote an article explaining how dangerous this was, they have since changed their position. The whole situation on a smaller scale goes back to as early as 1960 when they held back about couldko chicago so he tidy up the result and make it came out the way they wanted or you can go to 2018 in florida and the governors election and the senate election, the votes from Palm Beach County and Broward County were withheld for town 10 days to see if they could catch up until a group of ballots were found adding from jacksonville to palm beach that appeared to be fraudulent ballots. The election came to an end. We did not have that happen again this year. This practice of holding back votes which happens in my city also, your honor, is a timehonored rectus that is done in the big practice that is done in the big cities. Candy we now have store. We now have a wonderful opportunity to hold back votes even to produce votes after the election to make up a deficit. So what happened . In 2016, in this state in the commonwealth, there were only 256,000 absentee ballots, this year, so far, 2. 6 million. That is a totally different world and a number of and of the allegations take place in these counties, but the principal ones are in philadelphia and allegheny. Democrat controlled by democrats in the case of philadelphia. 60 years, wellknown for voter fraud, i dont know if you kept a list of all the voter fraud convictions in philadelphia, it is just this year a judge claimed guilty to put her fraud and a congressman has been indicted. I can go on and on. Relevant to this case, anddelphia, pittsburgh just a little bit to the west, detroit similar allegations. Milwaukee, similar allegations. The firstudden for time ever, inspectors, watchers, observers, they are called Different Things in different states. Were not allowed to observe the counting of absentee ballots. I have never heard of that happen. I have never heard of an inspector being kept out of an absentee ballot counting because that is the only time that you can assure the validity of the ballot because the minute they are separated, the ballot goes off anonymous and it is lost forever, you can never link it paper. Certifying it seems to be wrong and you cant figure out which vote to cancel. That is why so much emphasis is put on the inspection process before this became the way of voting. Critical, it is our only way to assure that this new form of voting which has been widely criticized as open to massive fraud can be at all policed. It has been not violated in this case, it has been trashed, it has been stepped all over, it has been disregarded here and in 10 other places. In in a nearly similar pattern and also, in the places it happens, they all happen to be big cities controlled by democrats who suddenly have decided that you dont have a right to inspect and absentee ballot. 50 states have this rule, i dont remember this problem ever existing before. The point is this is not an accident. You have to be a full to think this was an accident, that somebody woke up in philadelphia and pittsburgh and milwaukee and detroit and phoenix all the way in las vegas and then way back weatlanta and they decided are going to all over the republicans today. Were not going to let them see it. They also did we are not going to let them see a single absentee ballot. I can give the court these examples of fences put up, as described as corrals or cages. Had a subcontract in all of these places to get that. The point that im making, your, this is not an isolated case. Least 10happened in at other jurisdictions, precisely the same time. What happened in atlanta is totally outrageous. , who is in Lancaster County voted by absentee ballot. I believe that he made a mistake in his vote for absentee ballots. This is a critical mistake. Developed ininsert the secrecy to insert the ballot in the secrecy envelope. Isa vote by absentee ballot a lot. I traveled a lot. I used two vote by absentee ballot a lot. I traveled a lot. The absentee, the outer ballot has all of the information that you need to see. Ive been in these contests myself. They are kind of like wrestling matches. Instead of doing it this way, he unfortunately just put the ballot in without what they called the secure envelope. So that his vote could remain anonymous. , and when they opened quite properly disregarded the ballot. The government is quite strict about that, because again, this is the only way to secure the validity of these results. The same thing happened with mr. Roberts. Philadelphia, in pittsburgh, Allegheny County, and eight other counties, with the encouragement of the secretary of state, there was total disregard. Disregarded this, and they were allowed to cure and inform people that there was something wrong with the entry. Strict re are quite in new york, we call it an assembly district. To have an assembly district, a precinct number, your voter id number, your address, and you need to sign it. If anyone of those things are missing, the ballot is tossed. Anyone. Henry, and of mr. Mr. Roberts, they made mistakes. They were given no opportunity to cure. Thousands of people. It could be hundreds of thousands of people in certain part of the state. The more democratic part of the state regular very full opportunity to cure. We are very many cases where they are being told that they made a mistake. You made a mistake, he did not sign your forename. Your honor, that is a classic violation of equal protection. I have no idea what the standing rejection is. That is bush v gore. This is a bush v gore violation example. They are being discriminated based on their location. And what part of the state you can and what part you can cure the bout, and in the other part of the state you cannot cure the ballot. This denies the right to vote. I do not know what is more serious than being denied the right to vote in a democracy. Therefore, how they could object the standing is almost frivolous, your honor. Now, lets get to the campaign. Caused theat has pleading of the pleadings, it went totally different than that. It was a harm that might possibly happen in the future. It had not happened. This is a harm that has happened. Haveenry and mr. Roberts been denied their right to vote. Their votes have been canceled. The trouble to paint been totally the Trump Campaign has been treated totally different then the bush campaign. Comeest of the state applied with the law. The rest of the state complied with the law. We have no complaints from republican, neutral part of the state about this happening. The only place we have this masse is on bass en counties controlled by the democratic machine that have quite an impressive list of voter fraud convictions as a part of their history and tradition. They did thisn, opportunity on a grand scale. I do not understand what the standing argument is. I do not understand how the president of the United States and the campaign does not have standing to assert, if we are right, which we have to assume that we were treated totally differently in another part of the state, mainly philadelphia and pittsburgh, where we cannot get in a single ballots. And the rest of the state, we had no problem with that. We have never had a problem with that in 50 years. This has never been a problem before. I believe that we are going to prove it. I believe that we are going to prove it way beyond the numbers that we have now. One of the problems that we have in this case, and why we had to amend, is because at the end of last week, we have twice as much evidence as last week. It is not just here, but all over the country. Just yesterday, in clark county, which is las vegas, the election board in clark county, which is five democrats and no are republicans, preferred the election of a democrat, based on irregularities in clark county. He was only part of it. We have five times more. Up ae not bringing frivolous argument here, your honor. This is happening, and to happens in all of these cases. We have begun for lawsuits. We have another one opening tomorrow. We have three others starting, asserting the same thing. How is this not real and tangible and already happening . Why do we come to a federal court . We come to a court because the enforces and protects people against violation of equal protection. It protects voters who had their votes stolen from them. It protects a candidate who appears to have an election stolen in the state of pennsylvania. And i believe in other states. Should we come, but today federal courts when we are talking about an election of the president of the United States . This not an injury. This is not an injury that might happen hypothetically. It happened. The votes have been counted. The illegal ballots that were not inspected at all have been entered and counted. 770 that we can count now. Rest week it was about last week it was about 340,000. When we get to the hearing, it it will probably be about 700,000 will be get to algona county Allegheny County pennsylvania. What am i talking about . Im talking about absentee or mailin ballots that were a singleithout republican having the opportunity to observe anything about the ballots. Behindre tabbed barricades star for away. Even after the closing, you could not see it. No possible chance of staying in the back. This is unfair. This is a disgrace. The is like saying to General Assembly in pennsylvania that we do not care about your law. Runearned we philadelphia the way that we want to run philadelphia. We laugh at your ballots. You have to have people present . We will have them present but behind barricades so far away that they cannot see a darn thing, even when they try to do it by binoculars. They had to . They have to use binoculars this is it fraud . This is total bully this is totally fraud. This would not happen in a bipartisan county. Enter the record, all the political corruptions all the political corruption convictions in photo via over the last 20 years. This does not happen in on displays. It did not happen in the rest of the state which is an honest state. This is an outrage. I have several people back here who entered in thought of you and got nasty. And philadelphia, we objected. We are pushed further back. Several people were assaulted. Several people were percheron, including women. We went to court and got a clarification that we could be six feet closer. , and the general who the gentleman who had the order forgot to bring the order with him. They moved them 12 feet further back instead of six feet closer. Days in philadelphia and we do not see two and a half days in philadelphia and we did not see a single ballots. These people wasted two days of their time to be made fools of. When we got the order and showed it to the sheriff, the sheriff said that if you move one step closer, i will arrest you. This is america. There are going to arrest somebody because they want to observe a ballot to make sure that his candidate is not going to be cheated in a blaze that is well known for cheating . And a place that is well known for cheating echo the net result is to the point that we are at 338,000 and pittsburgh. Over 340,000 and philadelphia. Let me correct what i said. When you look at the separate counties and look at them together it is 1. 5 million votes that were entered illegally. 1. 5 million votes that went in there. Knows to have who complied with the law is an employee of the democratic controlled city or county. Nobody else. In many cases, even democrats were not allowed to see it. They were not allowed to see it because they could not count on the fact the fact that ultimate cracks are crooked. When detroit did it, there was a witness. She was so distracted by the process, she came and reported. They made sure that it stayed with their mafia though be quiet about it. They did not let democrats or republicans see it. Nobody got to see it, completely flaunting the law of pennsylvania. Completelyant, violating what has been universally recognized as a fundamental fairness with these ballots. Every state in the union has inspection requirement. That is not by accident. If it did not have an inspection requirement, now that a third of our vote is being counted by absentee ballots, then you have to have one. You have to have one the youre going to enforce. Is allowed without serious sanctions, this could become an epidemic. You give them an inch, they are going to take a mile. They have already taken a mile. They take a mile, they are going to take the whole city. This cannot be allowed. [indiscernible] they stole an election. These votes are way more than enough to overturn the result of the election. Questions was did they have enough votes to overturn the results of the election . More votes that we need, and we are still getting complaints that we would overturn the results of the election. This is a real controversy. I want to law school. It is always been the simple test for whether or not you have standing. I really do believe that the argument on standing as an argument that delays this. They would like to delay this as long as possible. Court tor, i ask the motion soo deny this that we can quickly move to start to put before you the proof that we have. We have hundreds of affidavits. We question here, is if proceed to a hearing, that is your decision. We question will be, how do present the evidence without burdening the court . A lot of it is repetitious. The repetition proves it over and over again. Have 300ay that we affidavits, declarations, or our own statements written down that will be subjected to the process of affidavit. We do have, in addition to these , which i will submit to the court, judge brann you are welcome to do so. Have they had the opportunity to see this . Mr. Donovan i have not. I do not believe they are part of the complaint. Mr. Giuliani in paragraphs 142 to 149 i marked it. Judge brann we can go back to that. A set tou can supply mr. Donovan. Mr. Giuliani i believe it is 132 two 150. Judge brann continue your argument. Clear, thei to be first one is a picture of the center and philadelphia for the woman appears to be 20 to 30 feet away from the closest accounting area, obviously unable to see anything of significance. I will call that exhibit a. Cocounsel. I used to be a clerk. I hope im doing this right. I like this exhibit a. Judge brann so far so good. Mr. Giuliani in case i need a job after this. This is exhibit a. Again, as second picture to show how far away they were. As you might imagine, there is very serious objection to people who worst thing there like plotted like potted plants. Who were standing there like potted plants. The second one is in philadelphia. The second two, which we will a young woman who is having to use a binocular to try to see. As you imagine, it did not accomplish anything. She was not able to see youing, largely because cannot find anything. And that is pittsburgh. Of ff the course [indiscernible] judge brann mr. Giuliani is representing that exhibits a and b are from philadelphia county. Is inng exhibit c Allegheny County. D. Giuliani