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REPUBLICAN PARTY OF



March 16, 2018

Robert Torres

Acting Secretary of the Commonwealth
Of?ce of the Secretary

Department of State

302 North Of?ce Building

Harrisburg, PA 17120

RE: 18th Congressional District Special Election on March 13, 2018 
Dear Mr. Torres:

Please be advised that I represent the Republican Party (?Party?). I am
formally requesting that the Department of State open an investigation into a number of
irregularities that took place during the Special Election on Tuesday, March 13, 2018.
voters deserve a speedy and thorough investigation based on the overwhelming
evidence of voter confusion and election mismanagement outlined in part below. In the interest
of transparency and nonpartisanship, we ask that you consider assigning this task to a
Commonwealth elections of?cial capable of conducting an impartial investigation in light of the
positions you?ve taken on ongoing redistricting litigation.

First, an authorized campaign attorney, Russell Giancola, presented several forms of
permissible credentials but was prevented from observing the computation of the vote count in
Allegheny County Tuesday night. In order to satisfy Allegheny County Election Manager Mark
Wolosik?s unprecedented preconditions to admission, attorney Giancola ultimately provided the
demanded but unnecessary redundant letter of authorization. While attorney Giancola was
?nally able to obtain this compliance with the inappropriate preconditions, the delay deprived the
campaign of the right to have counsel present during the computation reporting process. The
Allegheny County Elections Division?s refusal to acknowledge his poll watcher certi?cate, an
email from the campaign, or an email from the Chair of the Republican Committee of Allegheny
County violated the Elections Code, including but not limited to 25 PS. 3153 and 2650, as
well as the Campaign?s rights pursuant to 42 U.S.C. 1983.

Second, we have received reports and preliminarily determined that Allegheny County
and Washington County failed to properly provide notice of the Special Election under the
Uniform Military and Overseas Voters Act. County election boards are required to provide
notice of elections 90 days in advance of regular elections and as soon as practicable before a
special election. See 25 PS. 3514(a). Notices must be made available on the county election
boards? websites. See 3514(d). The Allegheny County Elections Division website does not
mention the Act, and Washington appears to have wholly failed to add this notice to its website.

Shaner Republican Center 0 12 State Street 0 Harrisburg, PA 17101 0 Phone: 717?234-4901 0 Fax 717-231-3828

 

Paid for by the Republican Party of 

 

Third, we received multiple complaints throughout the 18th Congressional District
regarding calibration issues involving the voting machines. Numerous voters have called the
Party and the Saccone campaign to complain that they selected Rick Saccone on the voting
screen, only for Conor Lamb to appear on the con?rmation screen. It is our understanding that
some of these issues were not resolved during the Special Election.

Fourth, the Party received numerous complaints about voters not appearing on the voter
rolls, and being denied the ability to cast a provisional ballot at their polling place. In at least
one instance, a voter was denied a provisional ballot at his precinct and directed to vote at his
prior precinct in the neighboring county where he used to reside before moving several months
ago. This violates voters rights under the Help America Vote Act and the Commonwealth?s
implementing statutes and regulations. In addition, given the closeness of this election, denial of
the right to vote for even a small number of eligible voters could cast the outcome of this election
into doubt.

Finally, as your of?ce was made aware on election day, the Department of State?s
website errantly directed voters to polling places matched to their address
under the recently imposed Supreme Court map. Any voter who visited your
website and clicked on the ?Find Your Polling Place? link on the homepage was provided their
polling place under the new map rather than the congressional district lines in use for the Special
Election. Since election day, we have heard from potential voters in 18th
Congressional District who attempted to vote but were informed that they did not live in the
district any longer.

All bene?t from having faith in the integrity of our elections. We
therefore request that you immediately commence an investigation into the numerous
irregularities that took place during the Special Election on Tuesday.

Sincerely,
A

Joel L. Frank

PA GOP General Counsel