(c) involve conduct outside the seven Defendant Counties, and (d) by their own terms were isolated incidents that could not have affected the presidential election’s results by offsetting the Biden majority of over 80,000 votes. RESPONDENT’S ASSERTIONS OF CONSTITUTIONAL VIOLATIONS 31. Respondent argued to the district court that the extraordinary judicial remedies he requested were proper because the Defendant Counties’ used a noticeand-cure procedure for mail-in ballots and imposed physical boundaries on candidate representatives who were observing the counting of votes in violation of: (a) the Equal Protection Clause of the Fourteenth Amendment; (b) the Due Process Clause of the Fourteenth Amendment; and (c) the Electors and Election Clauses of the Constitution, although he declined to pursue this last claim. a. Equal Protection--Notice and Cure 32. Some Pennsylvania counties chose to offer voters within their jurisdiction who submitted deficient mail-in ballots prior to Election Day a notice of the defect and the opportunity to vote a provisional ballot. Pennsylvania state law neither requires nor prohibits this so-called “notice-and-cure” procedure. 33. Respondent contended that the Defendant Counties violated the rights of Plaintiff voters, Mr. Roberts and Mr. Henry, under the Equal Protection Clause. Yet, Messrs. Roberts and Henry were residents of other non-defendant Pennsylvania counties that Respondent chose not to sue. Respondent failed to allege that the 12