me v3 10:17 —t00B — 9 RETURN DATE: NOVEMBER 9, 2019 MARTHA DEAN * SUPERIOR CouRT vs, + JUDICIAL DISTRICT OF HARTFORD GEORGE C. JEPSEN and THE SECRETARY OF THE STATE OCTOBER 26, 2010 VERIFIED COMPLAINT IFIED COMPLAINT State officers and agencies ~ namely, admission ‘o the bar ~ and the practical experience ‘0 likgate effectively,” as explained by the Supreme Court in Bysiewicz v. DiNardo, 8.C. 18612, in an opinion issued on Friday, October 22, 2010, 5. On information and belief, much of defendant Jepsen's professional career thas been spent in non-legal political positions otyez/or| 9 ia) | 8. In addition, also upon information and belief, most of defendant Jepsen's legal experience has been in of-counsel and in-house Positions not involving litigation 7. In addition, also on information and belief, defendant Jepsen is not admitted to the Court of Appeals for the Second Circuit or admitted to the United States ‘Supreme Court, and was only admitted to the U.S. District Court for Connecticut in 2009 and has no oF very little experience litigating in Federal Court | 8. In addition, also on information and belief, the defendant Jepsen has spent the majority of his time living or working in Florida between 2004 and 2009, where, upon 5208998 -JURIS NO. 58478 information and belief, he is not admitted to practice law. i 8. On various dates throughout the campaign, defendant Jepsen has stated that: 90 GULETT STREET HARTFORD, CT (609): “I don't have a background in litigatio I'm nota litigator by background or nature,” and “I'm not a litigator by background.” 10. In light of defendant Jepsen's background and statements, there is a substantial question whether he is qualified to serve as Attomey General, as he does not ‘appear to have sufficient litigation experience or court admissions to meet the requirements of CGS. § 3-124. 11, Pursuant to C.G.S. § 9-329b, this Court may issue an order removing a candidate from a ballot label if that candidate is improperly on the ballot, it appears to 42. The plaintiff will incur substantial injury in the loss of votes to what app be an unqualified opponent in the event her opF | fications are not promptly adjudicated. ponent were to win next week's election if | defendant Jepsen's quali | \ TaNZ LOST atvazsaT UNGN\NANSNSRGNGN 9 | 1 Tem raratnamaey ical anite inde en | The pee re tot yb epi ey te Panos cn ca ftw a hn wl pn tes on em a | cermin ney mi | crm en isc tot cra | Sem cmt oy nt eo | se on ome Ee ps fo Neorint dons nen one nae dd)) ad (Nlomaleiii ce aba callin AOS CADE ENO 45010ORTON, SHIELDS & KNOX, P.C.- ATTORNEYS AT LAW 90 GLLET STREET HARTFORD, CT» (860) 522-8330 JURIS NO. 28478 1 9000) RETURN DATE: NOVEMBER 9, 2010 MARTHA DEAN vs. GEORGE C. JEPSEN and THE SECRETARY OF THE STATE SUPERIOR COURT JUDICIAL DISTRICT OF HARTFORD OCTOBER 26, 2010 VERIFICATION OF COMPLAINT |, Martha Dean having read the foregoing Complaint, do hereby verify that itis true and correct to the best of my knowledge and belief. (le 3 — ‘Subscribed and Swom to before me this 26th day of October ,2010 Zornnigdoner of the Superior Court “Notary Pubtic “My Gemmission Expires:RETURN DATE: NOVEMBER 9, 2010 MARTHA DEAN SUPERIOR COURT vs. : JUDICIAL DISTRICT OF HARTFORD GEORGE C. JEPSEN and THE SECRETARY OF THE STATE OCTOBER 26, 2010 APPLICATION FOR TEMPORARY INJUNCTION and ORDER TO SHOW CAUSE 4000 a2 Pursuant to Conn, Gen. Stat. § 52-471 ot seq., the plaintif, Martha Dean, hereby 28 makes application for an ofder that the defendants be ordered to appear to show cause gs winy the prayer for a temporary injunction in accordance with her Verified Complaint should é 4 nat be granted. <3 PLAINTIFF, MARTHA DEAN gg z b dz By f______—— Sc Westey W. Horton ze Kimberly A. Knox ge HORTON, SHIELDS & KNOX, P.C. gE 90 Gillett Street 3 Hartford, CT 06105 fe Juris No. 38478 quswenetiogmry: 90:11 ot/9z/0r78 STIORNEYS AT LAW 600) 522-8398 -JURIS NO. 2047 ‘ORO, CT & KNOX, PC. “A HORTON, SHIELDS. 0 GILLETT STREET HART 9000 RETURN DATE: NOVEMBER 9, 2010 MARTHA DEAN vs. GEORGE C. JEPSEN and THE SECRETARY OF THE STATE SUPERIOR COURT JUDICIAL DISTRICT OF HARTFORD OCTOBER 26, 2010 MOTION FOR ORDER OF NOTICE ‘The plaintiff moves that the court order that notice of the pendency, and date and time of hearing, of this lawsuit be placed immediately on the judicial website. — PLAINTIFF, MARTHA DEAN By ‘We J. Horton Kimberly A. Knox HORTON, SHIELDS & KNOX, P.C. 90 Gillett Street Hartford, CT 06105 Juris No, 38478 eee 1 60:11 ot/9z/0TRETURN DATE: NOVEMBER 9, 2010 MARTHA DEAN + SUPERIOR COURT | vs. JUDICIAL DISTRICT OF HARTFORD | GEORGE C. JEPSEN and THE SECRETARY OF THE STATE OCTOBER 26, 2010 PROPOSED TEMPORARY INJUNCTION ORDER Having duly considered the Plaintiff's Verified Complaint and Application for ‘Temporary Injunction and Order to Show Cause, the Court finds that: (1) the plaintiff will suffer irreparable harm if the Secretary of the State is not ordered either (i) to remove defendant Jepsen from the ballots for the November 2, 2010 election or (ji) not to certify the result of the election until further order of this Court, or (Ii) fo postpone the election; (2) the plaintiff has no adequate remedy at law; and (3) the balance of the equities favors granting | an injunetion because the plaintiff will suffer greater harm if her application is denied than will he defendants if the application is granted a once pAewereped C6220 255 gnome