Amicus Brief to Florida Supreme Court

Michael Marks

New member
Amicus Curiae means "friend of the court"; it is a brief submitted with the intent of making sure the Court has access to all of the facts relating to a given decision. As the decision of the Florida Supreme Court will begin on Monday, I felt that there was significant chance that members of the Court could have missed some of the news items which have come out regarding this case in the days since the election of November 7th. This represents an open Amicus brief, made available to the general public, in the hope that the matter is resolved with all of the facts taken into consideration. Though somewhat lengthy, please take the time to give this document thoughtful consideration and contact the Florida Supreme Court with your views. Their email address is supremecourt@flcourts.org

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Open Brief Amicus Curiae of a United States Voter

IN THE SUPREME COURT OF THE STATE OF FLORIDA
November, 2000

AL GORE, et al.,

Petitioners,

V.

THE CITIZENS OF THE UNITED STATES,
The Florida Secretary of State
The Florida Election Board, et al

Respondents.


STATEMENT AMICUS CURIAE OF
REGISTERED VOTER MICHAEL E. MARKS,
IN SUPPORT OF RESPONDENTS' POSITION THAT
THE ELECTION BOARD OF THE STATE OF FLORIDA
SHOULD CERTIFY THE ELECTION UNDER THE
EXISTING LAWS OF THE STATE OF FLORIDA.

Michael E. Marks
Herndon, VA
(703) 262-0164
marksman@patriot.net


Interest of the Amici Curiae

Amici is a United States citizen and registered voter, former resident of Florida for 16 years and graduate of the University of Florida. Amici has amassed a lifelong practice of voting and participating in the United States political system, and moreover considerable experience in researching and assembling factual information for the purpose of assisting in a thorough analysis of fact in legal, corporate and military arenas, as well as nine years experience in law enforcement training and issues. Given the extremely abbreviated timeframe involved in this case and the rapidly emerging facts regarding the practices engaged on or since the Presidential Election held on November 7, 2000, this brief is submitted for referencial purposes to insure that the court has access to as much information as possible when evaluating this matter.

Amici, through scholarship and practice, has contributed to the thoughtful and informed resolution of executive, technical and legal analyses. Amici therefore seek leave to present his view to the Supreme Court of the State of Florida concerning the significance of a ruling on the application of Al Gore and the Democratic Party to prohibit the Secretary of State from executing her duty and finalizing the November 2000 election according to the established laws of the State of Florida.

Argument

On November 7th, 2000, the State of Florida initiated, in concert with the whole of the United States, an election process to determine the next President of the United States. During that process, and in an ongoing manner since its conclusion, a continual and mounting series of irregularities have been documented which at this stage threatens the integrity of this election and the rights of Florida voters. While the individual weight of any single instance may prove insufficient to sway the course of events, it seems clear that the aggregate value of these incidents, when viewed en toto, establish an unmistakable pattern of malfeasance which at the very least indicates a severe impact on the integrity and reliability of the voting process, and which could ultimately meet the threshold for a reasonable determination of election tampering.

1) On November 7th at 7pm Eastern Standard Time CNN, followed immediately by the other major networks, announced that Al Gore had won the State of Florida. At the time this announcement was made, the polling sites in the Florida panhandle, to include the state capitol of Talahassee, were still open and would remain open for another hour. Upon unfounded declaration that the election had been decided, numerous voters either left their place in line at the polling places, or turned back from en route to the polling place. This section of Florida has been recognized as a significant Republican voting block. The Republican Leadership Council commissioned a phone survey of more than 35,000 Panhandle voters in which 2,380 Bush supporters said they decided not to vote after hearing that Gore had won the state. This action on the part of the networks cannot be passed off as a mere oversight; the Florida panhandle has been in the Central Time Zone since time zones were invented. It has been so for every election. When they decided to announce a winner at 7pm they did so with full knowledge that the polls were still open. On any standard this is a gross breach of professional ethics and responsibility. By knowingly announcing a winner in the election while the polls were still open for a significant window of time in a significant portion of the state, the networks committed an act which reasonably falls between gross incompetence and deliberate abuse of the public trust.

2) On November 9th the Judicial Watch issued allegations that the Florida District of the Imigration and Naturalization Service (INS) "engaged in a systematic program of rushing aliens through the naturalization process to meet INS headquarter goals." INS sources stated that this program, defined as the 'Backlog Reduction Program' is identical to the 1996 Citizenship program wherein thousands of aliens, some with criminal backgrounds, were improperly and illegally rushed through the naturalization process in order to obtain Democratic votes for the presidential election. INS examiners and clerks who met or exceeded headquarter goals and quotas were rewarded with various types of bonuses, including 40 hours of paid time off. These charges are currently being pursued.

3) On November 9th, Irving Slosberg was caught by police in illegal possession of an official state voting machine in his car. Slosberg, a democratic member of the Florida state legislature, was already under investigation for allegations that he tampered with his own election by buying votes. Mr. Slosberg denied possession of the voting machine to both election officials and law enforcement officers, becoming belligerent before the police seized the voting machine from Mr. Slosberg's car. Having illegally removed a voting machine from a polling place, Slosberg had the ability to create false ballots, or to double-punch and thereby invalidate existing ballots for an indeterminate amount of time. Palm Beach County’s supervisor of elections, Theresa LePore declined to press charges, according to the report. She noted that this incident did occur during the hand count of the presidential election and LePore, a Democrat herself, stated she did not wish to pursue this matter at this time due to extenuating circumstances. The immediate question of why a county supervisor would refuse to press charges for the clear felony of theft and possession of a voting machine during a national election is currently being investigated.

4) On November 16th, Mark Bruce Richter and Steven Robert Solomon were arrested in possession of a second stolen Palm Beach county voting machine. This machine was out of official possession for over a week and could have been used to create countless false ballots or invalidate existing ballots as well.

5) On November 16th Broward County Law Enforcement officers noted 78 displaced chads on the floor of the "manual recount" area. As each chad represented a ballot which had been altered, the officers correctly determined that the significant number of alterations constituted a material change in the voting record and as such constituted the crime of vote tampering. The chads were placed in an evidence envelope, marked as crime evidence, and delivered to the Broward County board of elections. Subsequent reports have been made from across the state raising the number of dislodged chads (ergo altered votes) to over 600.

6) On November 17th over 1,000 overseas absentee ballots, primarily representing members of the United States Armed Forces serving overseas, were thrown out by Democratic officials on false or incorrectly applied technicalities. These ballots, traditionally cast in overwhelming percentage for the Republican candidate, were disallowed by Democrats on such technicalities as :

a) lack of postmark, when in fact the U.S. military postal system used to transport the votes does not use a postmark when time constraints for proper delivery would be prohibitive, and when in fact the absentee ballots were delivered to the election office on time;

b) 110 of 113 military ballots in Miami-Dade County were invalidated for "lack of a witness and witness address" even though the form does not indicate in any fashion that a witness is necessary. Similar unjustified invalidations have been documented in numerous counties across the state. Representatives of Armed Forces personnel are currently pursuing this matter.

7) On November 18th the Miami Herald reported that at least 39 felons, overwhelmingly Democrat, illegally voted in the Nov 7th election. These felons were guilty of crimes which included rape, murder and drunk driving. One of the seven felons was working as a poll worker for the election. If this level of illegal felon voting were extrapolated across the remaining counties of Florida, it could represent as many as 2,000 votes. Under Florida law, felons are banned from voting.

8) On November 18th, it was reported that Al Gore's lead attorney had a prior arrest in a Miami strip club having sexually attacked one of the strippers. Kendall Coffey entered the Lipstik lounge in Miami, purchased a bottle of expensive champagne, and retained the private services of a "lapdancer" named Tiffany. Upon retiring to a private room, Mr. Coffey assaulted the woman leaving, (much in the fashion of shamed sexual predator Marv Albert), "bite marks in her arm". While this does not contribute to the actions at present, it certainly goes toward the lack of moral terpitude of the highest members of the Gore staff, and brings into question the integrity of any man, much less one seeking the White House, who would select a sex offender as his lead attorney.

9) On November 18th Former Secretary of State Warren Christopher called the Democratic lawyer Bruce Rogow, the attorney for Theresa LePore, Palm Beach County's Elections Supervisor. Christopher called Rogow in an attempt to get the attorney to use his influence to sway the Election Supervisor into initiating an otherwise unwarranted manual interpretation of the ballots, just like the process Christopher helped orchestrate elsewhere in Florida. Rogow felt it was completely inappropriate for Christopher, a member of the Gore campaign, to ask him to abuse his capacity in that manner and try to unjustly influence the proceedings. Rogow instead reported the incident to the proper authorities. This event occurred concurrent with the decision by Judge Myriam Lehr to inexplicably reverse her original vote and force a manual interpretation in Miami-Dade County, again without any form of legal foundation for that decision. Given the lack of any other change prompting the reversal, there is a very real question as to the likelihood that Judge Lehr was influenced in precisely the same manner as the Gore camp attempted to influence the Palm Beach elections officials.


Amici contend that this Court should now hold in favor of the voters of the Secretary of the State of Florida who, according to the letter and spirit of Florida law and all Florida precedent, seeks to accurately and faithfully execute her duty and validate the machine count of the Florida ballots under normal Florida regulations, which, combined with the overseas ballots, constitutes the sum total of votes cast by Florida voters in the Nov 7th election. It is Amici's belief that the criteria put forth by the Democratic party in this matter is entirely ad hoc, fabricated as needed to circumvent the standard rules and established practices of the state of Florida. Moreover, that Mr. Gore and his representatives have demonstrated a clear and unquestionable disdain for the rules and sovereignty of Florida by continuing roughshod in their activities when those actions directly contravened the decision of the duly authorized Election Board and the Secretary of the State of Florida, and doing so with a contemptuous disregard for the unauthorized expense of a manual interpretation of the ballots on the Florida taxpayer.

The process put forth by Mr. Gore has no foundation in Florida law. Incorrectly termed a "recount" for public relations purposes, the manual process is actually an unscientific interpretation whereby individuals with no demonstrable qualification are called upon to observe ballots which do not meet the voting requirement and make a "best guess" as to the intent of the voter who created the ballot. It is a manual re-casting of the votes, NOT a re-counting of them. There is no court in the land which would base a decision upon a "guess as to the intent" of a defendant, and there is certainly no way that humans can determine, as though through divine inspiration, which of two holes in a ballot was the one the voter really intended. This process has been foisted upon an unsuspecting American public as having the potential to be more accurate than a machine count, when in fact it is immediately obvious that the manual handling is in fact steadily destroying the ballots by dislodging chads in significant quantities. Calling an immediate halt to the manual process will help preserve whatever veracity remains of the now-contaminated public record.

The Petitioner's motion for a stay can and should be denied in favor of Respondent, in order to prohibit further damage to the ballots and preserve the voting record for posterity. Moreover, the temporary injunction against the Secretary of the State of Florida should be lifted, allowing her to proceed with the election process under a strict interpretation of the election laws as they exist.

This decision would protect the rights of Florida citizens, as well as the United States as a whole. In the view of Amici, any ad hoc alteration of the election rules brought about during or after the election itself can only be interpreted as self-serving and an attempt to defraud the established election process. The highly selective nature of interpretations and locations for these activities only demonstrates the lack of good faith on the part of the Gore campaign, and the unwavering belief that they are sufficiently above the law as to be able to change the rules where they want, when they want, as long as they package those changes in a gossamer wrapping that appears palatable to the popular media.

Continuance of the stay on the Secretary of State will cause irreparable harm to Respondent and the nation as a whole. The Gore campaign has and continues to alter ballots through their unfounded and unsupported manual interpretation process, at the same time heaping upon the Florida taxpayers a growing bill for the process. There is not, nor has there ever been, any allegation whatsoever of malfunction of the voting machines or any impropriety in the management of the voting process. There is, therefore, no assertion that the mechanical count has failed to determine the correct answer following the laws of Florida. The only aspect the Gore campaign is contesting is the outcome, and the only relief sought is a fabricated change of rules in only those areas as to change that outcome in his favor. At a personal level, this is a dispicable and contemptible affront to the basic honesty of every American citizen, as well as an insult to every member of the United States Armed Forces and those who gave their life to insure that America would be free to choose its leaders.

Likewise, there are "compelling reasons" for this Court to exercise a strict interpretation of the election laws in this case. At a fundamental level, this case reaches far beyond the underlying facts of the clarity of a given ballot. A decision for the Gore campaign will set a catastrophic precedent which will affect the way elections are henceforth run in this nation. No decision will be safe from subsequent litigation, and no election law will be safe from ad hoc revision. Every rule and regulation will become the subject of a legal contest fought largely on TV in the court of public opinion. As citizens believe that their vote is meaningless compared to the follow-on litigation, we will see participation in the election process dwindle even further, which on its face is a terrible price. The election process will spiral into an interminable tar pit of litigation and counter-suit which, regardless of any given outcome, will transform our election process from participatory to adversarial. Elections will cease to be an affirmation of the people's right to choose and instead become an expensive, protracted and reviled legal battle in which the American citizens will be the ultimate losers.

Amici respectfully suggest that this Court should weigh the potential consequences of this outcome upon the United States in making their decision.


Conclusion

However this Court rules, the present case will set a precedent regarding this Nation's respect for the voting process and the validity of election laws. This Court has the responsibility to determine the important questions raised by Petitioner's request to selectively invent new rules and standards in the midst of an election. For the reasons set forth above, this Court should lift the current injunction against the Secretary of the State of Florida to ensure a fair and legal election under the current laws of the State of Florida

Respectfully submitted,
Michael E. Marks
 
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