Now that a recount in the U.S. Senate contest has been ordered by the Pennsylvania Department of State (DOS), the Dave McCormick campaign is laying out its strategy for ensuring that its lead in the race remains intact.

Once the 67 counties in the Commonwealth submitted their unofficial results on Tuesday to DOS, Secretary of the Commonwealth Al Schmidt was required to call for a recount, as state election law calls for a mandatory recount should the difference between candidates in the unofficial results be within 0.5%.

McCormick’s lead over Democratic incumbent Bob Casey Jr. currently sits at 29,338 votes or 0.43%, according to DOS. The New York Times website shows the lead for the Republican at 26,486 votes. Either total necessitates a recount.

“The first thing I want to make clear, up front, is there’s one inescapable truth of all this, is that when counting is done, that Dave will be winning by 10s of 1000s of votes,” said lead strategist Mark Harris. “It will not be close. We are well outside of any range of what changes in recounts or other adjudication processes. So the first point to make is that there is no path for Bob Casey. The math is simply not there for him.

“Since 2000, no U.S. Senate candidate leading by more than 500 votes, let alone 5,000 or 10s of 1000s going into a recount, has had the result change and in Pennsylvania, the average change is less than 100 votes for a statewide recount. It is the prerogative of Senator Casey’s to pursue a recount, but there is a 0% chance that the outcome of this race is going to change.”

The Department of State has estimated that there are still 80,000 uncounted ballots around the Commonwealth, but Harris stressed that figure is “the absolute maximum.”

“They’re going to continue to gain a few a handful of 1000s of votes as we move forward here, just because of what is left,” said Harris. “So again, the inescapable reality is that 10s of 1000s of Pennsylvanians more voted for Dave McCormick than voted for Bob Casey.”

James Fitzpatrick, counsel to the McCormick campaign, discussed the timing of the recount which can begin within all 67 counties at 5:30 p.m. today. Some counties may begin at that time, while others may start Friday. He noted that Philadelphia County may not start until Wednesday or later next week.

Counties must complete their recount by noon on November 26 and submit its results to DOS by noon the next day.

Fitzpatrick, in discussing the campaign’s legal strategy, announced that various GOP committees throughout the state filed an application for extraordinary relief, asking the Pennsylvania Supreme Court to reaffirm its ruling that the mail-in date requirement is mandatory and must be enforced in this election. He also said that the McCormick campaign filed suit last night in Bucks County on this issue, and are prepared to file suit in any county that does not comply with the law.

He also spoke to allegations that the Casey campaign is attempting to count the votes of unregistered voters.

“There have been many instances across the Commonwealth where the Casey campaign has advocated the (county) boards of election re: unregistered voters who cast a provisional ballot should have their vote counted. This is a totally frivolous and meritless argument,” Fitzpatrick stated. “Now, the Casey campaign position is that they are the ones who need to confirm whether a voter is registered or not, not taking the word of the local board of elections and the SURE (Statewide Uniform Registry of Electors) system.

“We think this is a totally extreme argument and just very much outside the mainstream. Everyone knows that the boards of election and the SURE system are the arbiter of who is registered and who is not registered. So again, just to fully summarize, unregistered voters cannot have their vote counted in any way. Any attempts to legitimize this frivolous argument by the Casey campaign, by any local boards of elections, will be met with litigation.”

The Casey campaign objected to the McCormick campaign claims that it is attempting to count ballots from unregistered voters, calling them “categorically not true.” It notes that many boards of election across the state erred in their determination of whether voters who cast provisional ballots were registered or not.

“No one is trying to count votes from individuals who were not registered. This is categorically false,” said attorney Adam Bonin who is working on behalf of the Casey campaign. “This is a blatant attempt by the GOP to lie and distract from their efforts to disenfranchise Pennsylvanians by throwing out votes from registered voters.”

The campaign has challenged various boards over their rejection of provisional ballots due to missing signatures or statements from judges of election or the absence of a secrecy envelope, citing that voters’ rights may have been violated.

“While McCormick and his allies are working to disenfranchise voters in Pennsylvania and spread misinformation, we are working to ensure that Pennsylvanians’ voices are heard,” said Tiernan Donohue, campaign manager for Bob Casey for Senate.

updated to include quotes from Bonin and Donohue