Boards, 10 F.3d at 589 (holding that this definition encompasses applying for an absentee ballot). Thus, while the clearest use of Section 10307(e) is to prosecute pure ballot forgery schemes, the statute can also apply to other types of schemes when voters are manipulated, misled, or otherwise deprived of their votes. See, e.g., Cole, 41 F.3d at 310–11 (witness believed the defendant was merely registering her to vote, not helping her vote). Schemes to steal the votes of the elderly, infirm, or economically disadvantaged may constitute multiple-voting, especially if there is a clear absence of meaningful voter participation. Because of their vulnerability, these persons are frequent targets of ballot schemes, and often do not even know that their ballots have been stolen or their voting choices ignored. Further, if they have been intimidated, they are generally reluctant to say so. There is a significant evidentiary difference between voter intimidation and multiple-voting that suggests that the multiple-voting statute may become the preferred charging statute for voter “assistance” frauds. Voter intimidation requires proof of a difficult element: the existence of physical or economic intimidation that is intended by the defendant. In contrast, the key element in a multiplevoting offense is whether the defendant voted the ballot of another person without consulting with that person or taking into account his or her electoral preferences. In conclusion, if the facts show manipulation of “vulnerable victims” as referenced in the sentencing guidelines for the purpose of obtaining control over the victims’ ballot choices, the use of Section 10307(e) as a prosecutive theory should be considered. 5. Voter Intimidation Voter intimidation schemes are the functional opposite of voter bribery schemes. In the case of voter bribery, voting activity is stimulated by offering or giving something of value to individuals to induce them to vote or reward them for having voted. The goal of 49

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