Scribd Logo
Upload

Welcome to Scribd!

  • 2K views

    DCRP V DCDP Part 1 of 2

    Uploaded by

    Mede Nix
    Part 1 of Dallas County GOP lawsuit

    Copyright:

    © All Rights Reserved
    Download as PDF or read online from Scribd
    Flag for inappropriate content

    You might also like

    DCRP V DCDP Part 1 of 2

    Uploaded by

    Mede Nix
    2K views89 pages
    Part 1 of Dallas County GOP lawsuit

    Original Title

    Dcrp v Dcdp Part 1 of 2

    Copyright

    © © All Rights Reserved

    Available Formats

    PDF or read online from Scribd

    Did you find this document useful?

    Is this content inappropriate?

    Report this Document
    Part 1 of Dallas County GOP lawsuit

    Copyright:

    © All Rights Reserved
    Download as PDF or read online from Scribd
    Flag for inappropriate content
    Download as pdf
    2K views89 pages

    DCRP V DCDP Part 1 of 2

    Uploaded by

    Mede Nix
    Part 1 of Dallas County GOP lawsuit

    Copyright:

    © All Rights Reserved
    Download as PDF or read online from Scribd
    Flag for inappropriate content
    Download as pdf
    of 89
    CAUSE NO. ‘THE DALLAS COUNTY REPUBLICAN PARTY, MISSY SHOREY as Dallas County Republican Party Chair, IN THE DISTRICT COURT PLAINTIFFS, JUDICIAL DISTRICT ‘THE DALLAS COUNTY DEMOCRATIC PARTY, CAROL DONOVAN, as the Dallas County Democratic Party Chair, DEFENDANTS. DALLAS COUNTY TEXAS PLAINTIFFS’ ORIGINAL PETITION CHALLENGING THE CERTIFICATION OF CANDIDATES WHOSE APPLICATIONS WERE NOT CERTIFIED BY THEIR PARTY CHAIR, WITH RELATED APPLICATION FOR TEMPORARY RESTRAINING ORDER AND TEMPORARY INJUNCTION COME NOW, the Dallas County Republican Party (the “DCRP”) and Missy Shorey (“Shorey”), as Chairwoman of the DCRP, and file this, their Original Petition Challenging the Certification of a 128 (one hundred and twenty-nine) Democratic Candidates’ Applications For a Place on the Democratic Primary Ballot, & Application for Temporary Injunction complaining of CAUSE NO. DCRP v. DCDP — Plaintiffs’ Original Petition & Application for TRO / Temporary Injunction Page 1 and against the Dallas County Democratic Party (the “DCDP”), Carol Donovan (“Denovan’) as Chairwoman thereof, and for cause of action would respectfully show unto the Court as follows: I. CLAIMS FOR RELIEF 1. This lawsuit arises out of the certification of compliance for and submission to the Secretary of State by the DCDP of 128 candidates for places on the Democratic Primary Ballot, whose applications were not accepted by the DCDP’s Chairwoman Donovan, the only individual with the statutory authority to do so under the Election Code. 2. The Pl iff seek injunctive relief to prevent Donovan and the DCDP from including: (a) any of these candidates, whose applications are attached in Plaintiffs’ Appendix to this Petition om the March 2018 Democratic Primary ballot; and (b) any of these candidates on the November 2018 General Election Ballot as a result of any such candidates participation in the March 2018 Democratic Primary. 3. The Plaintiffs also seek injunctive relief to prevent Donovan and the T "DP from dectaring any of these candidates administratively ineligible and replacing them, where statute permits, with a candidate of Donovan's choice so as to avoid a ruling in the Plaintiffs favor on the { merits, ILDISCOVERY CONTROL PLAN, Procedure 190.3. CAUSE NO. 3. This matter is subject to Discovery Level 2 in accordance with the Texas Rule of Civil DCRP x. DCDP — Plaintifts' Original Petition & Application for TRO / Temporary Tojunction Page 2 TILPARTIES 4, The DCRPis a political party organized in accordance with the Texas Blection Code, with its principal place of business located at 11617 N. Central Expressway, Suite 240, Dallas, ‘Texas, 75243. 5, Shorey, as the Dallas County Republican Party Chairwoman, is an individual who resides in Dallas County, ‘Texas. 6. The DCDP is a political party organized in accordance with the Texas Election Code with its principal place of business located at 4209 Parry Avenue, Dallas, Texas 75223. The Dallas County Demoora Party may be served with process by serving its Chairwoman, Carol Donovan, at its principal place of business, or its General Counsel, Sarah Duncan, at 3500 Maple Ave, Dallas, TX 75219, or wherever else eithor two may be found. 7. Donovan, as the Dallas County Democratic Party Chairwoman, is an individual who resides in Dallas County Democratic Party located at 4209 Parry Avenue, Dallas, Texas, 75223. Donovan may be served with process at her principal place of business, or by serving its General Counsel, Sarah Dunean, at 3500 Maple Ave, Dallas, TX 75219, or wherever else either may be found. IV.JURISDICTION AND VENUE 1, Jurisdiction is proper in this Court in accordance with Texas Election Code §§ 145.035 and 172.117 and the Plaintiff is seeking an injunction against the Defendants in accordance with ‘Texas Civil Practices & Remedies Code § 65.021. CAUSE NO. DCRP », DCDP — Plainti * Original Petition & Application for TRO /Teraporary Injunction Page 3 2. Venue is proper in Dallas County, Texas, because the events giving tise to Plaintiffs? causes of action occurred in Dallas County, Texas and because all parties are residents of (or have their principal place of business in) Dallas County for venue purposes. V.FACTS Background 3. The deadline to submit applications for placement on the March Primary Ballot for Judicial Races in Dallas County was December 11, 2017. 4. After the filing deadline, a candidate may not file and the county Chair may not accept, an amended application or an amendment to an application.! 5. The candidates whose petitions are the subject of this challenge submitted their applications and/or applications and petitions, along with a fee, to the DCDP for offices sought wholly within Dallas County, between, DATE RANGE, in accordance with The Texas Election Code §§ 141.031, and 172.022 (@)(2). 6. Anagent or agents of the DCDP accepted these petitions petition, 7. Thereafter, these applications were signed by an unknown individual or individuals purporting to be Donovan, so certifying the candidates for inclusion on the primary ballot, in violation of the Texas Election Code, §§ 141.037 and 72.029(@}(2) 8. The Primary Election is scheduled to be held on Match 6, 2018, and early voting ballots were initially scheduled to be mailed January 20, 2018, ‘Tex, Blee. Code §141.032(g). CAUSE NO, DCRP » DCDP ~ Plaintfis' Original Petition & Application for TRO / Temporary Injunction Page 4 B, THE 128 CANDIDATES WHOSE APPLICATIONS WERE NOT SIGNED, ACCEPTED, AND CERTIFIED TO COMPLY BY THE CHAIR OF THEIR PARTY ARE NOT ELIGIBLE FOR PLACEMENT ON THE BALLOT BY THE SECRETARY OF STATE 9. The Texas Election Code states that a candidate’s application for a place on the ballot, must be “be timely filed with the appropriate authority.” 10. The Election Code also makes clear that for any oflice that is wholly within one county, a candidate's application for a place on a party’s primary ballot must be filed with that political party, specifically with the County Chair or the County Party Seeretary.? LL. The Election Code gives the Secretary of State the authority to create and preseribe different forms for varying levels of government! 12, The application form (Form 2-2), contains a further admonition within the form warning that failing to provide required information could result in rejection of the application: “All fields MUST be completed unless marked optional. Failure to provide required information may result in rejection of application.” 13. The Election Code requires that, onee those applications are received by the appropriate authority (for placement on the March 2018 Dallas Democratic Primary Ballot, the DCDP), that “authority with whom the application is filed shall review the application to determine 2 Tex, Elec. Code §141.031(@)(3) 2 Tex, Blee, Code Section §171.021 (a); $172.022(a2) 4 Tex. Elec. Code §141.031(¢). 5 Plaintiffs” App’x at 1. CAUSE NO. DCRP ¥, DCDP — Plaintiffs’ Original Petition & Application for TRO / Temporary Injunction Page 5 whether it complies with the requiremenis as to form, content, and procedure that the application and petition must satisfy for the candidate's name to be placed on the ballot.” 14, After making the relevant authority makes that determination, the Election Code requires it to certify the names of all candidates who comply, as the names are written on the application, for placement on the ballot.” 15. The County Chair, alone, is the presiding officer of a county party, under the Election Code.* 16. The Flection Code designates the County Chair, alone, as the sole person responsible for certifying and authorized to submit the names of complying candidates to the Secretary of State,910 17. And though the Secretary of State may prescribe deadlines by which these submissions must be delivered, the Code makes very clear that those candidate submissions are to be made by the Chair.) 18. The form also indicates, at the bottom, that the certification for submission to the Secretary of State is “TO BE COMPLETED BY CHAIR.” 19. This authority may not be delegated except in very limited circumstances. In fact, the Code only makes provision for the a State Party Chair to perform a County Chairs? job, and then ‘only makes this provision if: (a) there is an absence of County Party leadershi (b) the Tex, Elec, Code Section §141.032(a), Tex, Elee. Code Section §141.037. 8 Tex, Blec. Code Section §171.022(a)(1) 9 Tex, Hlee. Code Section §172.029(a)(1). 10 Tex. Blec. Code Section §172.029(0}2).. 1 Tex, Blec, Code Section §172.025(6). CAUSE NO. DCRP y, DCDP —Plaintfls? Original Petition & Application for TRO /"Temporary Injunction Page 6 County Chair does not perform a duty in a timely manner. However, even then, a State Chair must make special notice to the County Chair or the County Executive Committee if he or she is going to ot has performed one of the Chait’s duties for him or her, including the submission of candidate information under Section 172.29. 20, If the Party Chair has a reasonable impediment to being able to perform those tasks which ‘the Election Code requires of them with regard to Primary Elections, the County Chair may request, in advance, that the State Chair or the State Chair's Designee perform the duty instead of the Chair. 21, But there is no provision in the Election Code that makes it possible or permissible for anyone else to perform the Chair’s Election Duties. 22, On information and belief, Donovan made no such a request to the Texas Democratic Party’s Chair, nor is there any indication that the Texas Demoeratic Party Chair notified Donovan or DCDP of a determination that Donovan was not performing her duties in a timely manner, so authorizing the State Chair to perform them. 23. Political Parties are expressly prohibited by the Code from making nominations to public office by any other method.!* 24. In the attached Appendix, Plaintiffs submit all 151 Applications submitted to the DCDP by candidates (and submitted by the DCDP to the Secretary of State) for inclusion on the March 2018 Democratic Primary Ballot. +2 Tex. Blee, Code Sect 18 Tox. Blec, Code Section §172.130(a)-b). ‘4 Tex, Blee, Code Section §161.003, CAUSE NO, DCRP v. DCDP Plaintiffs’ Original Petition & Application for TRO / Temporary Injunction Page 7 25, Donovan signed only 23 of these 151 Applic: ns, The remaining 127 applications bear someone else’s forgery of Donovan's name — the forgeries do not resemble Carol Donovan’ signature as it appears on her own application for inclusion on the Democratic Primary Baltot for the Office of Party Chairman, 26. Only @ county party chair may accept applications for ballot access (or, in the narrow exceptions provided by the Code, the State Chair or Designee) or submit complying candidates to the Secretary of State for inclusion on the ballot. 27, The following applications for the following candidates in the following district are indeed accepted and signed by the County Chair, with a signature that matches Defendant Donovan’s signature on her own application for inclusion on the party primary ballot for Pasty Chair: 4. Barbara Mallory Caraway, United States Representative District 30 Eddie Bernice Johnson, United States Representative District 30 Nathan Johnson, State Senator, District 16 Joe Bogen, State Senator, District 16 Robert Alonzo, State Representative, District 104 ‘Thresa “Terry” Meza, State Representative District 105 Nowagep it 8. Brandy K. Chambers, State Representative 112 9. Billy Ingram, State Representative 113 10. John TurnerState Representative 114 11, Martin Hoftiman, District Judge, 68th Judicial District 12, Mary Brown, District Judge, 301st Judicial District 18. Cheryl Lee Shannon, District Judge 305th Judicial Distriet 14,Clay Jenkins, County Judge 15, Sally Montgomery, Judge, County Court at Law No. 3 46, Brenda Hull Thompson, Judge, County Probate Court-at-Law No.1 17. Johnny J. Lanzillo IV, Judge, County Criminal Court of Appeals No. 2 19 Tex. Blee. ‘ode Section §172.029(8}(1); §172.130(@)-(). cause NO. DCRP ¥, DCDP ~ Pisintits" Original Petition & Application for TRO ‘Temporary Injunction ‘Yvonne Davis, State Representative, State Representative, State Representative Page 8 18.Dan Patterson, County Criminal Court-at-Law CrtNo.1 | 19. John F, Warren, County Clerk } 20. Curtis “Traylor” Harris, Constable Pot, 3 : 21, Jeff Bryan, Constable Pet 5 22, Michael Orozco, Constable Pet. 5 28. The following applications for the following candidates in the following district are not accepted and signed by the County Chait, and are instead signed by a John Doe #1 with a signature that does not matche Defendant Donovan’s signature on her own application for inclusion on the party primary ballot for Party Chair: 1. Royce West, State Senator, District 23 2, Bric Johnson, State Representative, District 100 3. Ang-Maria Ramos, State Representative District 102 4. Jessica Gonzalez, State Representative, District 104 5. A.D. Jenkins, State Representative, District 105 6. Victoria Neave, State Representative, District 107 ! 7. Joanna Cattanach, State Representative District 108 8. Zac Dufly, State Representative District 108 | 9. Toni Rose, State Representative, District 110 10. Rhetta Andrews Bowers, State Representative, District 113 | 11, Rock Bower, State Representative, District 115 | 12. Julie Johnson, State Representative, District 115 13. Bonnie Lee Goldstein, District Judge 44th Judicial District 14, Jim Jordan, District Judge, 160th Judicial District | 15. Craig Smith, District Judge 192nd Judicial District | 16, Bridget Whitmore, District Judge 193rd Judicial District | 17. Carl Ginsberg, District Judge 193rd Judicial District 18. Hector Garza, District Judge 195th Judicial District 19. Emily G. Tobolowsky, District Judge, 298th Judicial District 20. Dennise Garcia, District Judge, 303rd Judicial District 21. Tracy Holmes, District Judge, 363rd Judicial District 22. Carter Thompson, Criminal District Judge, Dallas County, Number 5 23. Jobn Creuzot, Criminal District Attomey, Dallas County 24. D’Metria Benson, Judge, County Court-at-Law No.1 CAUSE NO. DCRP v, DCDP — Plaintfis’ Original Petition & Application for TRO / Temporary Injunction Page 9 25. 26, 27. 28. 29. 30. 31. 32. 33. 34, 35. 36. 37. 38. 39. 40. Mark Greenbert, Judge, County Court-at-Law No.5 Julia Hayes, County Criminal Court-at-Law No. 2 Audrey Faye Moorehead, County Criminal Court-at-Law No. 3 Remeko Tranisha Edwards, County Criminal Court-at-Law No. 7 Carmen White, County Criminal Court-at-Law No. 8 Peggy Hofiman, County Criminal Court-at-Law No. 9 Wini Cannon, County Commissioner Pet. 2 Thomas G. Jones, Justice of the Peace, Pet. 1, Place 1 Valencia Nash, Justice of the Peace, Pet. 1, Place 2 Nortis “Stretch” Rideaux, Justice of the Peace Pet. 4, Place 1 Fred “Action” Jackson, Justice of the Peace Pet. 4 Place 2 Sara Martinez, Justice of the Peace, Pet. 5, Place | Juan Jasso, Justice of the Peace, Pet. 5 Place 2 Tracey Gulley, Constable Pet. 1 Rolando Garcia, Constable Pet. 5 Susan E. Lopez-Craig 29. The following applications for the following candidates in the following district are not accepted and signed by the County Chair, and are instead signed by a John Doe #1 with a signature that does not match Defendant Donovan’s signature on her own application for inclusion on the party primary ballot for Party Chair: CAUSE NO. John Biggan, U.S. Representative District 2¢ Eric Williams, U.S. Representative District 30 Sandra Crenshaw, State Representative, District 100 Christopher Graham, State Representative District 109 ‘Deshaundra Lockhart Jones, State Representative District 109 Victoria Walton, State Representative District 109 Carl Sherman, State Representative District 109 Amanda Ghagar, District Judge, 68th Judicial District Staci Williams, District Judge, 101st Judicial District Tonya Parker, District Judge, 116th Judicial District Bonnie Wulff, District Judge, 160th Judicial District, Lynda Lee Weaver, District Judge, 160th Judicial District Aiesha Redmond, District Judge, 160th Judicial District DCRP », DCDP — Plaintiffs’ Original Petition & Application for TRO / Temporary Injunction Page 10 14, Gena Slaughter, District Judge, 191st Judicial District 15, Lindsay Harrison, District Judge, 193nd Judicial District 16. Joan Ballard, District Judge 193rd Judicial District 17. Emest White, District Judge 194th Judicial 18. Teresa Havthome, District Judge, 203rd Judicial District 19. Raquel “Rocky” Jones, District Judge, 203rd Judicial District 20. Tammy Kemp, District Judge, 204th Judicial District 21. Stephen Duplantis, District Judge, 204th Judicial District 22. Darlene Ewing, District Judge, 254th Judicial District 23. Kim Cooks, District Judge, 255th Judicial District 24. Sandre Moneriffe, District Judge, 255th Judicial District 25. David Lopez, District Judge, 256th Judicial District 26. Myra Mcintosh, District Judge, 265th Judicial District 27. Jennifer Bennett, District Judge, 265th Judicial District 28. Amber Givens-Davis, District Judge, 282nd Judicial District 29. Lele D, Mays, District Judge, 2831d Judicial District 30. Stephanie N. Mitchell, District Judge, 291st Judicial District 31. Brandon Birmingham, District Judge, 292nd Judicial District 32, Sandra Jackson, District Judge, 302nd, Judicial District 33, Thelma Sanders Clardy, District Judge, 302nd, Judicial Disteiet 34, LaDeitra Adkins, District Judge, 304th Judicial District 35. Andrea Martin, District Judge, 304th Judicial District 36. Andrea Plumlee, District Judge, 330th Judicial District 37. Tina Yoo Clinton, Criminal District Judge, Dallas County Number 1 38. Monique Ward, Criminal District Judge, Dallas County Number 1 39. Jeanine Howard, Criminal District Judge, Dallas County Number 6 40. Alison Grinter, Criminal District Judge, Dallas County Number 6 41, Mark Watson, Criminal District Judge, Dallas County Number 7 42. Heath Harris, Criminal District Judge, Dallas County Number 7 43. Blizabeth Davis Frizell, Criminal District Attorney Dallas County 44. 45. Dorotha Ocker, Judge, County Court-at-law No 2 Melissa J. Bellan, County Court-at-law No 2 46. — Rachel Rider, County Court-at-law No 4 47. Tanja Martini, County Court-at-law No 4 48. Ken ‘Tapscott, County Court-at-law No 4 49. Paula Rosales, County Court-at-law No 4 50. Ingrid Michelle Warren, Judge, County Probate Court-at-Law No.2 51. Margaret Jones-Johnson, County Probate Court-at-Law No.3 (CAUSE NO. DCRP y, DCDP ~ Plaintiff Original Petition & Application for TRO / Temporary Injunction Page 1 52. Marty Jo Taylor, Judge, County Criminal Court of Appeals, No. 1 ; 53. Kristin Wade, Judge, County Criminal Court of Appeals, No. | 54. Pamela Luther, Judge, County Criminal Court of Appeals, No. 2 55. Bruce Kaye, County Criminal Court of Appeals, No. 2 56. Marilynn Mayse, County Criminal Court of Appeals, No. 2 57. Roberto Canas, County Criminal Court-at-Law, No. 10 58. Etta J. Mullin, County Criminal Court-at-Law, No. 10 59. Shequitta Kelly, County Criminal Court-at-Law, No. 11 | 60. Symone Redwine, County Criminal Court-at-Law, No. 3 61. Nancy C. Mulder, County Criminal Court-at-Law, No. 4 62. Lisa Green, County Criminal Court-at-Law, No. 5 ‘ 63. Angela M. King, County Criminal Court-at-Law, No. 6 ‘ 64. Felicia Pitre, District Clerk 65. Marian Brown, Sheriff { 68. Roy Williams, Jr, Sheriff 67. Pauline Medrano, County Treasurer 68. Elba Garcia, County Commissioner, Pot. 4 69. Anthony Elland, Justice of the Peace, Pet. 2, Place 1 70. Margaret O*Brien, Justice of the Peace, Pet. 2, Place 1 71, Katina Whitfield, Justice of the Peace, Pet. 2, Place 2 72, Shannon Bradford, Justice of the Peace, Pet. 3, Place 1 73. Mauri Long, Justice of the Peace, Pet, 3, Place 2 74, Mike JOnes, Justice of the Peace, Pet. 4, Place 1 75. Sasha Moreno, Justice of the Peace, Pet. 4, Place 2 76. Katy Hubener, Justice of the Peace, Pet. 4, Place 2 ' 77. Andrew “Bundy” Goldsmith, Justice of the Peace, Pct. 5, Place 2 i 78. — Alvin “AJ” Johnson, Constable Pet. 1 79. Bill Gipson, Constable Pet. 2 80. Curtis “Traylor” Harris, Constable Pet. 3 81. Kevin Solomon, Constable Pet. 4 82. Bryan D. Woodard, Constable Pet. 4 83, Edward Wright, Constable Pot. 4 84. Donald G. Artis, Constable Pet. 4 85. Sha Steger Knight, Constable Pot. 4 86. RonF. Bivins, Constable Pet. 4 87. Beth Villarreal, Constable Pet. 5 88. Henry Brown, Justice of the Peave Pet. 2, Place 2 CAUSE NO. DCRP ¥. DCDP — Plaintiffs? Original Petition & Application for TRO /'Temporary Injunction Page 12 30. DCDP sent certifications of compliance to the Secretary of State for 128 Candidates whose applications were accepted in violation of the Election Code, No candidate wrongly accepted by an unauthorized individual can legally be included on a ballot for the March 2018 primary election, CDCRP TIMELY FILE THIS CHALLENGE TO THE 128 CANDIDATES’ INCLUSION ON THE PRIMARY BALLOT 31. The Election Code authorizes challenges to the form, contest, and procedure of an application until the end of the day before any ballot to be voted on via early mail voting has been mailed out." Early voting ballots for voting by mail were initially scheduled to be nailed out by the Dallas County Elections Department on Saturday January 20, 2018. 32. This Original Petition initiates a challenge to the form, content, and procedure of the 128 candidates’ whose applications were not accepted and submitted by the DCDP Chair well within this time limit. VILCAUSES OF ACTION Count One — Declaratory Judgment 33. The Plaintiffs re-allege and incorporate-by-reference the facts and. allegations set forth above. 34, A justiciable controversy has arisen between the Plaintiffs and the Defendants, The Plaintiffs ask the Court to declare that the 128 Candidates whose applications were not accepted by 16 Tex, Elec. Code §141.034, CAUSE NO. DCRP », CDP —Pi s' Original Petition & Application for TRO / Temporary Injunction Page 13, Donovan before their wrongful submission to the Secretary of State are not eligible for inclusion on the March 2018 Democratic Primary Ballot. 35. Tt was necessary for the Plaintiffs to employ counsel to prosecute this action. In accordance ‘with §37.001 et seq. of the Texas Civil Practice & Remedies Code, the Plaintiffs are entitled to recover their reasonable and necessary attorneys’ fees and costs herein, for which they now sue. 36, All conditions precedent to recovery have been performed, have occurred, ot have been waived. Count Two — Application for Temporary Restraining Order & Temporary Injunction 37. The Plaintiffs re-allege and ineozporate-by-reference the facts and allegations set forth above, 38. One of the principal purposes behind the Texas Election Code is the prevention of election fraud and clectoral misconduct, and to protect the integrity of the electoral process. Tex. Flee. Code §1.003(a); In re Bell, 91 8.W3d 784, 787 (Tex. 2002), “A person who is being harmed or is in danger of being harmed by a violation or threatened violation of this code is entitled to appropriate injunetive relief to prevent the violation from continuing or occurring.” Tex. Elec, Code §273.081 39. The DCDP has submitted to the Seoretary of State, in violation of the provisions of the Texas Election Code in Section 172.029(a), 128 different candidates for the Democratic Primary who were not accepted by the DCDP Chair Donovan. It is past the statutory deadline set by CAUSE NO. DCRP y. DCDP — Phaintis’ Original Petition & Application for TRO / Temporary Injunction Page 14 | | | the Secretary of State for any additional Applications to be submitted to the Secretary of State by the DCDP. 40. Many of the 128 identified candidates seek offices for which the DCRP was unable to timely certify to the Secretary of State its receipt of a statutorily compliant candidate application. When no party timely submits to the Secretary of State the name of a candidate certified by the proper authority as having met the application requirements established by the Election Code for inclusion on a primary ballot, the Election Code authorizes the parties to subsequently nominate a designated candidate for office. Accordingly, the Plaintiffs are in danger of being denied their statutory right to designate nominees for the many offices for which Donovan, the only individual with the statutory authority to certify candidates? compliance and submit them to the Secretary of State, did not do so. 41, Others of the 128 identified candidates seck offices for which the DCRP did timely certify to the Sectetary of State ils receipt of one or more statutorily compliant candidate applications. Jn these instances, the PlaintiffS are in danger of being harmed by by having to face an opponent in the November 2018 General Election, who the Texas Election Code bars from inclusion as a candidate, Risner v. Harris County Republican Party, 444 8.W.3d 327, 345 (Tex, App—Housion [Ist Dist] 2014, writ of mandamus denied, 2014 Tex. LEXIS 801 (Tex. September 8, 2014)). 42. DCRP, and Shorey, have complied with their statutory obligations. ‘They, and their candidates, would suffer harm from upholding the stringencies of the Election Code, when their counterparts have not done the same. Additionally, the Plait like all Dallasits, would suffer harm in the form of the damages to the integrity of the elections process that CAUSE No. DCRP » DCDP — Plaiatifls' Original Petition & Application for TRO / Temporary Injunction Page 15 43. would result from an unequal application of the law allowing 128 candidates onto the ballot, despite the DCDP’s flagarant, willful, systematic submission of eandidates to the Secretary of State who had not been certified as compliant by Donovan, . The injunctive relief sought herein is necessary to adequately protect the interests of the Plaintiffs, and the voting public, from election fraud, misconduct, and manipulation of the election process. The Plaintiffs do not have an alternative, after-the-fact, adequate remedy at law, If a temporary restraining order is not immediately entered, there is a substantial likelihood that the Defendants will allow the 128 identified candidates to be placed on March 2018 Democratic Primary Baallot, and, thereafter, on the November 2018 General Election Ballot, all in violation of the Texas Election Code. ‘The Plaintiffs will suffer immediate and irreparable harm unless the Defendants, their agents, representatives, servants, employees, affiliates, and anyone with actual or constructive Knowledge of this injunction are immediately restrained from, directly or indirectly, engaging in the following acts: (@) Certifying any of the identified candidates for inclusion on the Mareh 2018 (0) Certifying any of the identified candidates as DCDP nominees on the November General Election Ballot as a result of participation in the March 2018 Demoer Primary; (©) Verifying or certifying the printing of ballots including any of the identified candidates’ names as candidates for office in the March 2018 Democratic Primary ot in the November 2018 General Election; CAUSE NO. DCRP v. DCDP — Plaintiffs’ Original Petition & Application for TRO / Temporary Injunetion Page 16 (@ Conducting any Primary Election, or authorizing anyone else to conduct on their behalf, a Primary Election in which any of the identified candidates are listed as candidates for office; (© Conducting the November 2018 General Election, participating in the November 2018 General Election, or authorizing anyone else to conduct on their behalf the Novernber 2018 General Election, to the extent that any of the identified candidates is listed as the DCDP’s primary winner for any office or as the DCDP’s nominee for any office; and/or (P) Declating each and every any identified candidate ineligible under Tex. Elec. Code §145,003(1); 45. The Plaintiffs have a substantial likelihood of prevailing on the merits. Given the high likelihood that the Plaintiffs will prove that the Defendants did not comply with the Election Code and prevail on the merits, no legitimate harm or prejudice will result to the Defendants, from the Court granting the requested injunctive relief before trial. On the other hand, the Plaintiffs will suffer immediate and irreparable harm from a denial of such injunctive relief. 46, There is no remedy at law for Plaintifis’ additional statutory rights if the TRO is not granted. The Texas Election Code provides that when there has not been a Primary Blection in either party, the County Party Committees may so appoint a representative to represent them on the ballot. Ifthe TRO is granted, particularly in eases where the is no Republican candidate, and no primary race is held in that scat in either party, both Parties could still appoint an candidate for the November ballot. However, if the TRO is not granted, and Plaintiff were to CAUSE NO. DCRP¥, DCDP ~ Plaintifs" Original Potition & Application for TRO / Temporary Injunction Page 17 prevail between the Primary and the General Election, because the Democratic Party held a primary, Plaintiff could not appoint a representative to represent them in November. VILCONDITIONS PRECEDENT 47. All conditions precedent necessary for Plaintiffs to have and recover in this action have been performed, have occurred or have been waived. WHEREFORE, PREMISES CONSIDERED, the DCRP, acting through Shorey, respectfully requests that: (a) citation issue and process be served on the DCDP and Carol Donovan, its Chairwoman; (b) the Court grant both a Temporary Restraining Order, and, after a heating, both a Temporary Injunction and a Permanent Injunction against Defendants; and (c) the Court grant the Plaintiffs a declaratory judgment as requested, including in its relief the Plaintifi reasonable and necessary attorney's fees incurred prosecuting this action, costs and expenses of suit herein, and both pre- and post-judgment interest on all monetary relief sought herein at the highest rates allowed by law, Finally, the Plaintiffs ask for any other and further relief to which the Court determines the Plaintiffs may be justly entitled. RESPECTFULLY SUBMITTED this 19th day of January, 2018. /s/Elizabeth D.Alvarea, Elizabeth D. Alvarez ‘Texas Bar No. 24071942 CAUSE NO, DCRP v DCDP — Plaintiffs’ Original Petition & Application for TRO / Temporary Injunction Page 18 Law Office of Elizabeth Alvarez, 555 Republic Drive Ste 200 Plano, Tx 75074 ‘Telephone: (972) 422-9152 Facsimile: (972) 767-3655 E-mail: Elizabeth@alvareztxlaw.com COUNSEL FOR PLAINTIFFS DALLAS COUNTY REPUBLICAN PART & MISSEY SHOREY CAUSE NO. DCRP v. DCDP — Plaintits* Original Petition & Application for TRO / Temporary Injunction Page 19 LOCAL RULE CERTIFICATION In accordance with Local Rule 2.02, the undersigned hereby certifies that atleast two hours before presenting this application to the Court, the undersigned notified the Defendants of this application. The undersigned sent a copy of the application and proposed order to Defendants via email to those Defendants whose e-mail address the undersigned was aware of notifying them of Plaintiffs’ intention to present this application to the Court ex parte as follows: Carol Donovan ~ carol @dallasdemocrats.org Sarah Duncan - sduncanattorney@ gmail.com, In the e-mail, the undersigned provided his cell phone number so that Defendants could contact her, At least two hours before presenting this application to the Court, the undersigned notified the following Defendants of the application by telephone and sent the Defendants who provided her with their e-mail addresses a copy of the application and proposed order as follows: (s/Elizabeth D. Alvarez Elizabeth Alvarez CAUSE NO. DCRP y, DCDP -Plaintills' Original Petition & Application for TRO / Temporary Injunction Page 20 VERIFICATION 1 STATE OF TEXAS 8 COUNTY OF DALLAS § I, Davin Bernstein, state and declare that I am over 21 years of age and fully competent to make this declaration. The facts set forth herein are true and correct and are within my personal knowledge. I have read the foregoing Plaintiffs’ Original Petition Challenging the Certification of the Improperly Certified Democratic Candidates Application for a Place on the Democratic Primary Ballot, Application for Temporary Restraining Order, & Application for Temporary Injunction, and that the facts stated in paragraphs 4-7, 3-32, 37-43, and 45-47, are within my personal knowledge and are true and correct, unless otherwise qualified therein. My name is Davin Bernstein, my date of birth is 08/24/1965, and my address is 228 Hollywood Drive, Coppell, Tx, 75019. 1 declare under penalty of perjury that the foregoing is true and correct, Executed on January 19,2018, Missy Shorey As Chairwoman, Dallas County Republican Party CAUSE NO. DCRP v. DCDP — Plaintiffs? Original Petition & Application for TRO / Temporary Injunction Page 21 CERTIFICATE OF SERVICE { certify that on January 19th, 2018, | served a copy of this Petition on all counsel of record in accordance with the Texas Rules of Civil Procedure via email, and through service of process. DEFENDANTS DCDP & Donovan Carol Donovan carol @dallasdemocrats.org Dallas County Democratic Party 4209 Parry Ave, Dallas, TX 75223 COUNSEL TO THE DEFENDANTS DCDP & Donovan Sarah Duncan sduncanattorney@email.com Sarah Duncan, Attomey-at-Law 3500 Maple Ave, Dallas, TX 75219 ds! Elizabeth D, Alvarez, Elizabeth D, Alvarez CAUSE NO. ‘DCRP y, DCDP ~ Pisintffs' Original Petition & Application for TRO / Temporary Injunction Page 22 CAUSE NO. THE DALLAS COUNTY REPUBLICAN § IN THE DISTRICT COURT REPUBLICAN PARTY, § MISSY SHOREY as Dallas County Republican Party Chair, PLAINTIFFS, JUDICIAL DISTRICT. 8 8 8 § § 8 § THE DALLAS COUNTY DEMOCRATIC § PARTY, CAROL DONOVAN, as the § Dallas County Democratic Party Chair, § DEFENDANTS. § DALLAS COUNTY TEXAS PLAINTIEES? ENDIX IN PLAl ” ORIGINAL j PPLICAI TEM STRAIN) AND AP) TION RY : CAUSE NO. DCRP y. DCDP. et al S APPENDIX TO Tul “TITION, APPL FORA TEMPORARY RESTRAINING ORDER, & APPLICATION POR TEMPORARY INJUNCTION TABLE OF CONTENTS. EXmIBIT A: CHAIRWOMAN CAROL DONOVAN’S APPLICATION -23, CATEGORY TWO: APPLICATIONS SIGNED BY JOHN Dor #1. we DA-64 CATEGORY THREE: APPLICATIONS St NED BY JOHN DOE #2.. wssnseer ee 6 TSO CERTIFICATE OF SERVICE, 158 CAUSE NO. DCRP », DCDP, etal, PLAINTPES” Appreuprx To THEIR ORIGINAL. PETITION, APPLICATION FORA TEMPORARY RESTRAINING ORDER, & APPLICATION FOR TEMPORARY INJUNCLION u Prony smn ot econ. a0 fms rn ae co _Alinformationragavedto he provideduness indicated es optional. ‘APPLICATION FOR Count CHAIR ON THE Semnocvoici c. __ PARTY GENERAL PRIMARY BALLOT YO: County Chale request that myname be placed on the shove narned offal primary ballot asa candidate for lection to the ofice indicates elo ‘OFFICE SOUGHT (include any pace number or other dsthgulshing number, any.) Dallas Ctunty Lepoctites [x Char "FULL NAMAE (Fist, Middle, Lab} ‘BRRgT NAME AS YOU WANT IT TO APPEAR ON THE BALLOT Cavo\ Donovan wvo\_ Donovan ‘BERIAANEIT RESIDENCE ADDRESS [Do notlncluds s PO, Baxot Rural | PUBUC MATING ADDRESS (Address for which you reseve cathode Route, W you do not have a reskéence address, doscrbe locaton of | related corrapordence,) rasteneal BBE rhocKimaloind Ln E putt IFT Box $00 ay aE av aaa Dallas, x _..__ [Rattas Tx 73914 PLETE RODRES wail) | GELUPATION ona ave Bho) "| BATEOF ERT —| VOTEERTEATON VOD carattrowandernerahctoor Oral] Rrorney, | sone (Opene) STAT ROAR OE ERG BTN UGS RSIDENEE ASF DATE APPLORTON SORA vom IWSTaTE INPRECINGT ROM WHUCATHE SOUGHTISUEETD | Wore (8) 895-1400 BT yen sear cat svombis)__ L_trontis ‘Wusing 8 lhneme as part oF our norma to appear on the ballot, you are aso signing and swearing to the following stetements: {further swear | that my nekname does not constitute slogan ner does It ndieata a polite, econom, socal or reiglous view or afiiaton, 1 have been common known by thisnckrame fr atleas three years por tots elation. sefoa ie te undergrad nator onthe cerpewonarecpewed name) Ch Yo) Lora Vad ro wenety me here and now duly sworn, upon oath Says 5, (name) Covo\, Donovan ss of Qailas. ‘county, Tenas, being @ aaah ore oti f-Dais € fasta Demande, Ci vei Olli aaportand defer he Cnt arn the United States and of the Sat of Tens. bya cen ofthe United Sites lle te hal ach offs under the constton a awe of| {hsstte Fhevenot been aly etced af ofan fer wich hee ot been paren or hd my flights of zershpreoredy ther afidl acon. | havo et been determined by ial carer of cour exercig probes urscton tobe totaly mentally espacated or portal mertaly ineapactated without the ht vets lam awaro ofthe napots la, Chapter 873, Government Code, tacherswoar that he foraging steterents nde In ny epleaton aetna things trun aed correct? x a "SGNATURE OF CANDIDATE ‘Swom to and subscribes eforome at_ pRB thisthe WY day of yubaase APPENDIX PAGE 001 itietnete non aad ag eld NS ne competed urls mare optlonal. Faure to prove rere flonan ma rept eton of apse "APPLICATION FOR A PLACE ON THE Demonratic. PARTY GENERAL PRIMARY BALLOT Toisatecoanty Geir Scorer ‘request hat myname be laced on te abe nomad offi rary blo ta onda for nofnaton 1 ated baion. Sauer aida oy pace turer or ter daingashing umber, Wan] | WRICATETERM Dallas County Commissioner, Distlat 4 au _—_ [ETueeraco = Toit ae Te eT SFR WARS WOU WANT 110 APPEAR ON THE HALOT® Maria Elba Garcta-Ibancovichi Eloa Garcia ‘PERIAARIENT RESIDENCE AOORESS [Ba not Inclds 6 P.O. Box or Rural | PUBLIC MAILING ADDRESS (Actress for which you recive carapalgn Route, If you do not have a residence eddttss, describe location of | related cdtrespondente, If avalable) asitonen) 618 W. Jefferson E 7 = | oe ony ‘STATE ad arr i Se ‘STATE ae Dallas TX Dallas TX _|75208 FUNC EMAIL ADDRESS wasn)” | OCCUPATION DATE OF TT Tore easreanon Wid : NUMBER Opto Dentist o, “ELEPIONE CONTACT IOAMIATION [Optional _EiVGTH-OF CONTINUOUS RESIDENCE RS GF DATE PLICATON SWORN Rome: wstate IN TERRITORY /OISTICT/PREGICT FROM WHICH THE OFFICE SOUGHT S ELECTED ‘Work, (214) 946-2277 33_ years] 8 _yeatle) it 9 rons) _ 7_ ont) Sige 0 FA Fm TW pp TD FT, you aT sing aod sagt Th ong nanan ae aoe ee eae coat a ogen o carts ae, nar des end a pl enor, sos of revs vw or ‘rion (nave been commonly cn by ths nkname fost east tree year pox ois eecton. ‘before me, the undersigned authority, on ths dey porsonaly appeared {name of candidate} Marla Elon Garcla-lpancoviet!__ who baingby me he end now duly wor, apo eth sa! 4 yame of candkstn}, Mette Elba Garciabanoovihl of Dallas county, Tors, relearn ez of Dallas County Comrissonat-DisfeL4_—__,evear att wi suport abd tnd te contain ang ote Untad Sates and ofthe Sat of Teas lama cen of the United Sates elle to ld sch offen unr the canton sod aan errs thave ret ben Ral onvcted ofa flon for whic havent bean ptdoned or had ny fll gh of tense restored west tna acton, I fave not betn determina bya fil dame of court eect probe ure to baetay manaty Pr ote at or paraly ronal Iezpactated without the ite vote a aware nepousm lw, Chepar 573, Gower os jenscaregh often Administering Oat PLETED BY CAR: THIS APPLICATION 1S ACCOMPANIED ¢17] castes check, OAL] PETTTION IN LIL OF FILING FEE. ‘this document and 395 “Sng fe or a nominating ptilon of_“—E pager reeavod. (cee Section 2.07) LLL. ‘Voto Resstretfon Status Veritod (1 ~~ one nesevod Date Acca ‘Slane of Cale APPENDIX PAGE 002 ——[-this document and §-—--——-fling fee ora nominating pettion of ——‘s pages recehved= & red yseeet ss sea 98 85a Cal on ‘All folds MUST be completed unless marked optional. Faure to provide requirad Information may result in rejection of applcation. "APPLICATION FORA PLACE ON THE L)@mot¥anC, PARTY GENERAL PRIMARY BALLOT ‘TO: State/County Clr {request that my name be placa on the sbove-named ofl primary ballots a candidate for nominetlon to the office Indeated below, ‘OFFICE SOUGHT (nude anyplace number or other distinguishing numbar, any.) eee L State Representative, District 13 Pispeiet et FULL NAME (First, Middle ast) ‘PRINT NAME AS VOU WANT IT TO APPEAR ON THE BALLOT™ i . Ingva Billy |ngvam i RESIDENCE {0 nak odes 66. Boor ral | PUBLIC MAING ADRESS (Adres or which yourecaNGcaToaen route ‘do not have a residence address, describe location of | related cserespondence, f avalabe.) P.O. Box 7630 IF cau wor A/a, 3b eons 32 years => snonthis) ont) Sl [Bate ie | | Nov Tx 7 PUBLIC EMAIL ADDRESS [if avallable) ‘OCCUPATION ‘DATE GF BIRTH “VOTER REGISTRATION VUID- i NuMBER (opto | Inava jlo Retired. L NE CONTACT IREOAMATIN (opens TENGTH OF COrTo0s HERDING OTE APRCATON SHORT Home: 9/A- WwstaTe | nvressrony/oiscrfoneccr rom TWH THE OPAC SOUGHT If LECTED “Ff weing a alcknatie as pert of your name to appear on the ballot, you are also signing and swearing to the following statements: | further wear thot ery nlelrame does not constitute a slogan ot contain ate, nor does it maleate 2 pots, economic, sock, oF religous MeW oF afliation. Hhave been commonly known ty thi alckrame fora east three years pric to this leror exer india ontvdarsenneet estonia Bul ly FE ing cand being by ma here and now duly sworn, upon oath says: rane of ann ; «Dallas onan, Yom bekag candidate forthe ee tat wl support andl defend the Conston tnt of ths Untiad States and ofthe Sate of Teas, fama lien ofthe United States elt to hold such offce under ie conettution and {avis ofthis sate, | have not been fnaly convicted of afelany for which | have not been pardaned or had my flights of eienship restored by other offal acton. Ihave not been determined by a final Judgment of a court exerlsng probate jrisdtion to be totally mentally Incepadtated or partially mentally neapadkated without the right to vote, | am aware ofthe nepatis law, Chapter 573, Government Code, ‘Turthersiear thatthe foregsing statements incoded In my application aren all things tua ane correct.” “Sworn ig pnd subscribed before me this tha 13° day of NeugaaGe ti £ 2 ay Sai ——Notae___ Senate oat “Hiv of Oar Adnan "TO BE COMPLETED BY CHAR: THIS APPLICATION IS ACCOMPANIED BY THE REQUIRED FILING FEE PAID BY: cone, LI casisers cxeck, on] reTmon i teu OF FILING FEE. SBRSIEY' Ay Roy 1 8 tet {See Section 1.007) = ‘ | Noe agen Sates etd Tea epaad ple ered APPENDIX PAGE 003 red Sty fee ‘Ses tebe ra Tens ao Coe ‘eat npleted unless marked optional Flue to pravide required Information may rest nection of applet. [APPLICATION FOR A PLACE ON THE _l-dmvoers Ka PARTY GENERAL PRIMARY BALLOT TosSeatelCounty Chale request that riyname be plced onthe shovenamad ofa prnaty blot a cana for nomination othe ofeeigdeaedblo. \ ‘OFRGESOUGHT finan place number er ther digs number, any) | INDIEASE ERMA 7 Shite Sretor VesfeieT Mp iaasaies i aL ak Ta ae ERE VOU WANT To APPEAR ON TEGAN? Nathan Metts Soros Nathar Sebrso~ 'PERIAANENT RESIDENCE ADDRESS (Do rot Includes .O. ax or Rural | PUBLIC AAIING ADDRESS (address for which you rcahe campaign Route, if you do not have @ residence address, describe losatlon of j related correspondence, i avaliable) | resdence) I2AAD Cort Ponck Bitty Sue Hod _ a 1 av ame Da a aC { Delles TA Cf Deku | R525) TORIC ADDRESS alae) TOCATPATION BREOF aR TASTED ; i i IQ relenroetxes. com a frre fa i “TELEPHONE CONTACT INFORMATION (Optional) ‘LENGTH OF CONTINUOUS RESIDENCE AS OF DATE APPLICATION SWORN | Home: UN STATE, | INTERRITORY/DISTRICT/PRECINCT FROM. 'WHeH Te OFrce SOUGHT Is zCTED ee 2% veer 24 oats I cot Be Snes “if using a rickrame as part of your nar fo appear on the Halo, you are ao cing and sweing tothe folowing statements: Warthor _swaar that my nleerame does not constitute a slogan or contain a te, nor dose It ndieata @ pala, economic, sod, ofrlous Vw oF affllaton, theve bean commanly known by this niekname forat leat threo years gor to this lection, ‘fore me, the undersigned authorty, on this dey personally sppeared (name of conckiste)___AleT hen, Tolnsen who feng byrne here and new duly sor, upon on ay 4 name of canciste) _Mathan TJobonsor ot DekOy, cay, To, bcing wean for the ofr of wea tht wi sppon wid fed the Coneton ‘and bn ofthe United States and of ie Sate offs lama cin fihe Uied Sas ela te ha sur ofc undor pe onan and Isws ofthis stats havent been Maly conde of fan for wich hav nt been pardoned or had my legs ef czar reered by oer ofl cian, Ihave not been detwrbed by a a! adgmen of aut sercing probate rsdn tobe tal meray Incaastood oc pry exttyIcapadatedwkhout the gto vot. vac ofthe nepelom an Copa 573, Goverment Cada | turther smear thatthe foreyoing statements nuded ny a oy x a weey Sinaturd of le of Offcar Administering Osth_ ‘TO BE COMPLETED BY CHAIR; THIS APPLICATION Is ACCOMPANIED BY THE REQUIRED BLING FE PAID conven, LI castnens cHeck, on L] PErIriGN IN LEU OF FILING FEE, crs FGaece Toner — | of ‘hs docment ara 2g fo era nominating ptton of sree non ‘Alfiolds MUST be completed unioss marke optional allure to provide required Information may rerun election of application. "APPLICATION FOR A PLACE ON THE DZIAGL42 TC. _ PARTY GENERAL PRIMARY BALLOT ‘o:sate/County Catt ‘request that my name bo placed on the above-named fda rimary ballot asa eandato for nomination to the offee Indes bow. eork Jodunal Diatief Cort (Pec Bo2rd Jods a PERMANENT JESISENCE ADDRESS (03 set include aP.0. Box or ural dees for which you recave tapalan ott if y39 do not have a residence addres, dasrbo location of | related cor’spondence, avaible) | _ bts & Frospect law a. 7 ‘STATE! FP ‘STATE ue lls al, trae He funesedul id WH enscrarte ee "TELEPHONE CONTACT INFORMATION (03 Homes AJ [A INSTATE 1 TERRITORY /DISTRICT/PRECINET FROM e ‘WHICH THEOFT|CE SOUGHT ELECTED “ GD esta DT vem ere oa eee ee month swonthis “fing a wcknarse 8 BATE of your nave wo Sppaar onthe bal, you are also signing and sweasig to the folowing satements (futher ‘wear that my nickname doet net constfaa 2 slogan or conta a tite, not does fneleate a poiticah economic, soe, or egos view or ition, \favebean comment known by tis nikrzie for teas thre years port hs lato. afore re,the undersimed athory, on hs day perso spp (nae of rain [RAO/ HoLues he ‘being by me here and now duly syorr, upon gath sys: 4, (name of candidate) . of ‘county, Texas, ‘bing « candidate forthe afes of, ~FEvoar that wil mupport and defend the Consthuton eet laws ofthe United Seates and ofthe State of Texas, lama clizen ofthe United States aligibe to hol such oftce under te constnin and fans ofthis sate. [have not been nally convicted of felony for which 1 have nat heen nardoned of had my fll lh of itsenshp restored brother affdal aden, Ihe not been determinad by 8 Yl judgment ofa court exerdsng probate jurltion to be totaly mentally ‘Reapostated or paraly mentally Ineapactated without tho right to voto. lam aware ofthe nepotism tay, Chapter 573, Government Code, further swear that the foraging stateens eluted i my appiation are in ‘Sworn to ahd sabserbed before merthisthe 2 day of A7OU ay: z et = see adap & aan See SER PLETED oY CHAK TH APPUCATION S ACCOMPANED BY THE REQUIRED LNG Fee PAD av Teasn cl Iwoner | coos, L] castitens cHeck, on] permiow wv usu OF FLING Fee, 02 rile donnent nd 5297 fng en raring petionet 27s preset (sx secon 000, LAN fas lu : rng Sons Ved aa tobe ced

    You might also like