BEFORE THE DULY CONSTITUTED ELECTORIAL BOARD © \v FOR THE HEARING AND PASSING UPON OF NOMINATION OBJECTIONS TO NOMINATION PAPERS OF CANDIDATES FOR ELECTION TO THE OFFICE OF ROCK ISLAND COUNTY STATES ATTORNEY ROBERT STRADT Petitioner-Objector, vs. DORA “VILLARREAL” NIEMAN, Respondent-Candidate VERIFIED OBJECTOR’S PETITION Now Comes ROBERT STRADT (hereinafter referred to as the “Objector”), pursuant to the Illinois Election Code, to state the nature of the objections to the certification of nomination ‘and nomination papers of Respondent-Candidate as follows: 1, The Objector resides at 11121 22* Street, Milan, Rock Island County, Ilinois and is ‘duly qualified, legal, and registered voter at that address, which is within the political subdivision in which the Respondent-Candidate is to be voted. 2. The Objector’ interest in filing this Petition is that of a voter desirous that the laws governing the filing of nomination papers forthe office of Rock Island County State's Attorney are properly complied with and that only qualified candidates appear on the ballot for said office. 3. The Objector states that the laws pertaining to the securing of ballot access requires that certain requirements be met as established by law. Filings made contrary to such requirement must be voided, being in violation of said laws. 4, The Objector states that pursuant to section 7-10(j) ofthe Illinois Election Code, if'a candidate seeks to run for state's attorney, then the candidate’s petition for nomination must contain at least the number of signatures equal to 0.5% of the primary electors of his or her party in the territory comprising the county. Dora “Villarreal” Nieman Objection5. Inthe instant cause, pursuant to section 7-10, nomination papers for the office of Rock Island County State’s Attomey to be voted for at the March 17, 2020 primary election ‘must contain the signatures of not fewer than 197 duly qualified, registered and legal voters within Rock Island County, Ilinois, collected in the manner prescribed by law. 6. Respondent-Candidate’s Primary Petitions purport to contain the signatures of in ‘excess of 197 such voters, and further purport to have been gathered, presented and executed in the manner prescribed by law. 7. The Objector makes the following objections to the purported nomination papers ("Nomination Papers") of DORA “VILLARREAL” NIEMAN as a candidate for the office of Rock Island County State’s Attorney to be voted for at the Primary Election on March 17, 2020: ‘A. Whether casting a ballot or signing a petition supporting the nomination of a ‘candidate to public office, it is axiomatic that our democratic form of government is well- grounded in the premise of one person, one vote; no one should be more intimately familiar with this vital thread of our democracy than the elected county clerk, whose primary purpose is to safeguard the electoral process. Yet, Rock Island County Clerk Karen Kinney provided not one, but two signatures in support of a single candidate. Sec, petition numbered 1 and 23. Equally egregious is that both signatures were collected by the Respondent-Candidate, Rock Island County’s acting state’s attomey, who swore an ‘oath to preserve and protect the constitution, which has been carelessly disregarded. B, While constitutional scholars may debate whether a citizen duly elected to conduct fair elections and impartially tally the votes sheds their liberty to support a nominee for political office, prudence dictates that a county clerk and her employees refrain from publicly supporting a candidate's nomination to elected office. By acting as petition circulators, the county clerk and her deputy clerk undermined the citizenry’s traditional expectations that a county clerk conduct a fair and impartial election. Dora “Villarreal” Nieman ObjectionC. That the Rock Istand County Clerk and her Deputy Clerk failed to refrain from the appearance of undermining our fundamental right to elect our public officials without interference, merits striking their petitions and invaliding the signatures therein. See, petition numbers 9 (Karen Kinny) and 3 (Nick Camlin). D. Section 7-10 requires each petition to include @ swom statement by the circulator, affirming that the signatures were signed in his or her presence and certifying the signatures are genuine. 10 ILCS 5/7-10 (West, 2019). Duly elected Rock Island County ‘Treasurer Louisa Ewert circulated a petition and swore that the signatures were signed in her presence and were genuine; yet her petition contains the name of a relative, once under his first name, then again under his middle name. See, petition numbered 14, row 2 and 8, Adherence to her oath to preserve and protect the constitution dictates that the Rock Island County Treasurer, who is statutorily required to replace the County Clerk on the Electoral Board in certain situations, refrain from the appearance of impropriety; yet the treasurer failed to do so when she circulated a petition supporting the nomination of a political candidate; and as such, merits striking petition 14 and invaliding the signatures therein E, The Objector states that Respondent-Candidate’s failure to disclose her name ‘changes merits grounds for denying certification of the candidate's name for the ballot and in support thereof, Objector states the following factual basis: a.) Section 7-10.2 states: “Ifa candidate has changed his or her name ... within 3 years before the last day for filing the petition or certificate for that office ... then (i) the candidate's name on the petition or certificate must be followed by “formerly known 4s (list all prior names during the 3-year period) until name changed on (list date of each such name change)” and (ii) the petition or certificate must be accompanied by the candidate's affidavit stating the candidate's previous names during the period specified in Dora “Villarreal” Nieman Objection(9 and the date or dates each of those names was changed. 10 ILCS 5/7-10.2 (West, 2019). ,) Simply stated, section 7-10.2 requires a candidate to disclose use of a former ‘name and when the name was used, if such use occurred within 3 years before filing nomination papers. This disclosure is required on a candidate’s petition sheets; thus any candidate who has used a different name within 3 years of December 2, 2019 must disclose the prior name and when the change was made. ,) “Failure to [disclose] shall be grounds for denying certification of the candidate's name for the ballot or removing the candidate's name from the ballot.” 10 ILCS 5/7-10.2 (West, 2019). ¢.) The Objector states that Respondent-Candidate changed her name within 3 ‘years of December 2, 2019, not once, but twice and failed to disclose the prior names and ‘when the changes were made on her petition sheets as statutorily required by section 7- 10.2. See, Respondent-Candidate’s Statement of Candidacy and petitions sheets, 1-48. «.) Prior to her marriage to Nate Nieman, the Illinois Attorney Registration and Disciplinary Commission listed Respondent-Candidate as “Dora A. Villarreal Miller” on the master roll of currently licensed attorneys. ©.) After Respondent-Candidate’s marriage to Nate Nieman, the master roll listed Respondent-Candidate on the master roll of licensed attomeys as “Dora A. Nieman.” See, Exhibit A. £) When the office of state’s attorney became vacant in 2019, Respondent- Candidate, despite her registration on the master rolls as “Dora A. Nieman,” applied for the vacancy, was appointed, took the oath and satisfied her statutory bond obligations, all, under the name of “Dora Villarreal.” Dora “Villarreal” Nieman Objection£) On June 26, 2019, despite her registration on the master rolls as “Dora A. Nieman,” Respondent-Candidate satisfied her bond requirement as “Dora Amelia Villarreal.” See, Exhibit B, the bond. ‘h.) On July 1, 2019, despite her registration on the master rolls as “Dora A. Nieman,” Respondent-Candidate swore her oath as “Dora Villarreal.” See, Exhibit C, and ‘operates the office as “Dora A. Villarreal.” See, Exhibit D. i) On July 29, 2019, despite her current registration on the master rolls as “Dora A. Nieman,” Respondent-Candidate printed and signed “Dora Villarreal” on the Illinois, State Board of Elections D-1 Statement of Organization form, formalizing her campaign committee, She named the committee “Friends of Dora Villarreal” with its purpose “to ‘lect Dora Villarreal for Rock Island County State’s Attorney.” See, Exhibit E. 4.) After repeated instances where Respondent-Candidate changed her name from “Dora A. Nieman” to “Dora Villarreal,” on December 2, 2019, despite the master rolls still listing her as “Dora A. Nieman,” Respondent-Candidate changed her name yet again to “Dora ‘Villarreal’ Nieman” when she filed her Statement of Candidacy and ition sheets as “Dora ‘Villarreal’ Nieman.” k.) Within the time frame required for disclosing name changes under section 7- 10.2, Respondent-Candidate first used the name “Dora A. Nieman,” then “Dora Villarreal,” and now “Dora ‘Villarreal’ Nieman;” that Respondent-Candidate changed her name not once, but twice and failed to disclose the prior names and when the changes were made on her Statement of Candidacy and petition sheets as statutorily required by section 7-10.2 is grounds for denying certification of the candidate's name for the ballot or removing the candidate's name from the ballot. 10 ILCS 5/7-10.2 (West, 2019). 1) Moreover, given the clear name changes, the Respondent-Candidate has failed to accompany her petition with an affidavit stating her previous names and the Dora “Villarreal” Nieman Objectiondates those names were changed; therefore, Respondent-Candidate’s name cannot be printed on the ballot. 10 ILCS 5/7-10.2 (West, 2019). F. The Objector states that the statutorily required Statement of Candidacy is insufficient in fact and in law when Respondent-Candidate failed to comply with the specific statutory requirement that her statement of candidacy explicitly state she is a licensed attorney-at-law of this State, and in support thereof, Objector states the following factual basis: 4). Section 7-10 of the Election Code provides each petition must include as a part thereof, a statement of candidacy. This statement shall set out the address of such candidate, the office for which she is a candidate, shall state that the candidate is a qualified primary voter of the party to which the petition relates, shall state that she has filed (or will file before the close of the petition filing period) a statement of economic interests as required by the Illinois Governmental Ethics Act, shalll request that the candidate’s name be placed upon the official ballot, and shall be subscribed and sworn to by such candidate before some officer authorized to take acknowledgment of deeds in the State. 10 ILCS 5/7-10 (West, 2019, emphasis supplied), .) Section 7-10 further and specifically states “in the case of a state's attorney candidate” the candidate shall include with their nomination petition a sworn statement of candidacy attesting that he or she “is atthe time of fling such statement a licensed attorney-at-law of this State.” 10 TLCS 5/7-10 (West, 2019, emphasis supplied). ©.) That the Legislature specifically distinguished the statement of candidacy qualification requirements “in the case of a state’s attorney candidate” from other candidates whom are merely required to generally state qualifications (holds any license ‘that may be an eligibility requirement), is indicative of the legislature’s intent that ‘candidates for state’s attorney shall specifically state “is a licensed attorney-at-law in this state” in their statement of candidacy. Dora “Villarreal” Nieman Objection4.) The Respondent-Candidate’s use of the “suggested” Statement of Candidacy form with the general qualifications provision violates the specific statutory requirement that she comply with the specific legislative intent to state she “is atthe time of filing such statement a licensed attomney-at-law of this State.” €.) “The primary goal of statutory construction, to which all other rules are subordinate, is to ascertain and give effect to the intention of the legislature. The best indication of legislative intent is the language used in the statute itself.” Schwartz v, Kinney, 50 N.E.34 59, 401 Ill. Dec. 339 (Il. App. 3" Dist., 2016) citing Jackson v. Board of Election Commissioners, 2012 IL. 111928, 4 48, 363 Ill. Dec. $57, 975 N.E.2d 583 (IL, 2012). ‘The intention of the legislature was made clear in Public Act 76-1420 when the legislature added the mandatory language, which the Respondent-Candidate omitted. See, Exhibit F. £) To the extent section 7-10 includes specific and general provisions relative to qualifications of candidates, specific statutory provisions will control over general provisions on the same subject. YanDyke v. White, 433 Il. Dee 153, (Il. 2019), Section 7-10 states specific qualification requirements for state’s attomey candidates and general ‘qualifications for all other candidates; therefore Respondent-Candidate can’t reasonably rely upon the general provisions to satisfy the more specific qualifications requirement. ,) “Where the same, or substantially the same, words or phrases appear in different parts of the same statute they will be given a generally accepted and consistent ‘meaning, where the legislative intent is not clearly expressed to the contrary.” Maksym v. Bd. of Election Com'rs of City of Chicago, 242 Dl, 2d 303, 322, 950 N.E.2¢ 1051, 1062 (2011). Again, clear and unambiguous legislative intent is found in Public Act 76-1420. h,) In Bowe v. Chicago Electoral Board 79 1.24 469, 38 Ill. Dec. 756, 404 N.E.2d 180 (Ill, 1980), the Illinois Supreme Court held the requirements of section 7-10 of the Election Code are mandatory and not directory. See also, Cinkus v. Village of Dora “Villarreal” Nieman ObjectionStickney Municipal Officers Electoral Bd., 228 111.2d 200, 886 N.E.2d 1011, 319 Ill.Dec. 887, (Il. 2008), citing, Serwinski v. Board of Election Commissioners, 156 Ill.App.34 257, 259-61, 108 IIl.Dec. 813, 509 N.E.2d 509. (1* Dist. App., 1987), Lawlor v. Municipal Officer Electoral Bd., 28 \App.34 823, 329 N.B.2d 436 (1* Dist App. Ct., 1975) (finding the Legislature’s spelling out of the required contents of the statement of candidacy intended that compliance be mandatory rather than directory), and Jackson- Hicks v. East St. Louis Bd. of Election Com'rs, 2015 IL. 118929 (Ill. 2015) (explaining that if a statute prescribes a consequence for failing to obey its provisions that isa strong indication that the legislature intended it to be mandatory). Section 7-10 provides such a ‘consequence in that the name of no candidate for nomination shall be printed upon the primary ballot unless a compliant statement of candidacy is submitted. i) In David Towns v. Boone County Officers Electoral Board, 91 MR 26 (17" Judicial Cireuit, Boone County, Tl, 1991), the circuit court upheld the decision of the Boone County Illinois Electoral Board to remove a state’s attomey candidate from the ballot for failing to fully comply with section 710 when he did not expressly state on his Statement of Candidacy that he was a licensed attorney-at-law in this state. See, 786 F.Supp. 699 U.S. Dist Ct. 1992. See, Exhibit G. See also, Lawlor v. Municipal Officer Electoral Bd., 28 Il_App.3d 823, 329 N.E.2d 436 (1 Dist App. Ct., 1975), where the Court upheld the electoral board which ruled petitioner's statement of candidacy did not comply with the statute because it was lacking in the essential elements required by section 7-10 and concluded that the petition for nomination was therefore invalid. J) The Illinois Supreme Court in Lewis v. Dunne, 63 Ill. 24 48, $4, 344 NE2d 443, 447 (1976) stated “the apparent purpose of the requirement that a statement of candidacy be included as a part of @ candidate's nominating papers is to obtain a sworn statement from the candidate establishing [their] qualifications to enter the primary lection for the office [sought].” “In the case of a state’s attorney candidate,” Dora “Villarreal” Nieman Objection‘establishing qualifications means the state’s attorney's candidate shall specifically state “is.a licensed attomey-at-law of this State” in their statement of candidacy. k.) Phrased in the present tense, section 7-10 requires a candidate for State's Attomey to state in their statement of candidacy “that the candidate isa licensed attomney- at-law of this State.” 10 ILCS 5.7-10 (West, 2019) emphasis added. 1) As the Ilinois Supreme Court stated in Goodman, the legislature's use of “is” evinces an intention to require candidates to meet the qualifications as stated in section 7- 10, which a candidate for state's attomey shall swear or affirm that they have met. Goodman v. Ward, 241 Il.2d 398, 948 N.E.2d 580, 350 Ill. Dec. 300 (I. 2011). 1m.) “The statement of candidacy and accompanying oath are phrased in the present tense, Thus, when a candidate submits his or her nomination papers to run for office, the candidate swears that he or she is qualified,” as specifically stated in section 7- 10. Cinkus v. Village of Stickney Municipal Officers Electoral Board, 228 lll.24 200, 212, 319 Ill Dec. 887, 886 N.E.2d 1011 (Il. 2008). 1.) Respondent-Candidate’s sworn statement fails to establish she is qualified ‘when she omitted statutorily required language that she is a licensed attomey-at-law in this state, Moreover, as stated in the preceding paragraph relative to Respondent- Candidate's failure to disclose her various name changes, Respondent is unable to affirmatively state that she, “Dora ‘Villarreal’ Nieman” is a licensed attomey at law in this state as that name is not on the master roll of licensed attorneys in this state. ©.) Respondent-Candidate’s sworn statement “that I am legally qualified (including being the holder of any license that may be an eligibility requirement for the ‘office to which I seek the nomination) to hold such office” fails to satisfy the statutory content requirements of section 7-10 in two regards: first, it disregards entirely section 7- 10's requirement that the candidate “shall” state she “is a licensed attorney-at-law in this state,” and second, the content suggests only that she “may” possess “any” license, not Dora “Villareat” Nieman Objectionthat she “is a licensed attomey-at-law in this state.” And as such, the Respondent- Candidate's statement of candidacy is insufficient to satisfy the statutory, mandatory declarations as set forth in section 7-10. .) That Respondent-Candidate’s Statement of Candidacy omits the required language that she is at the time of filing such statement a licensed attorney-at-law of this State, she failed to meet statutory requirements as established by law and therefore her Statement of Candidacy must be voided, being in violation of said laws. 4) Assuming arguendo, a general qualification may be sufficient, Respondent is ‘unable to affirmatively state that she, “Dora ‘Villarreal’ Nieman,” is the holder of any license that may be an eligibility requirement as that name is not on the master roll of licensed attorneys in this state. G. The Objector states that Respondent-Candidate’s petition sheets lack the requisite ‘number of signatures as a result of Respondent-Candidate striking “the city of Rock Island” from the header of her petitions after having circulated said petitions and in support thereof, Objector states the following factual basis: 4.) The name of no candidate for nomination shall be printed upon the primary ballot unless a petition for nomination has been filed on his behalf as provided in this Article in substantially the following form: We, the undersigned, members of and affiliated with the... party and qualified primary electors of the ... party, in the wu Of wu in the county of ... and State of llinois, do hereby petition that the following named person or persons shall bbe a candidate or candidates of the .... party for the nomination for (or in case of committeepersons for election to) the office or offices hereinafter specified, to be voted for at the primary election to be held on (insert date). ‘Wherein the candidate must completely fill in the blanks with the statutorily mandated information. 10 ILCS 57-10. (West, 2019). Emphasis supplied. b,) The Illinois Supreme Court held the requirements of section 7-10 of the Election Code are mandatory. Bowe v. Chicago Electoral Board 79 1.24 469, 38 Il Dora “Villarreal” Nieman ObjectionDee. 756, 404 N.E.2d 180 (Ill. 1980). See also, Cinkus v. Village of Stickney Municipal Officers Electoral Bd., 228 M124 200, 886 NE.2d 1011, 319 IlLDee. 887, (I. 2008), siting, Serwinski v. Board of Election Commissioners, 156 Ul.App.3d 257, 259-61, 108 ULDec. 813, 509 N.E.2d 509. (1* Dist. App., 1987), and Jackson-Hicks v. East St. Louis Ba. of Election Com'rs, 2015 IL 118929 (Il. 2015) (explaining that if a statute prescribes a consequence for failing to obey its provisions that isa strong indication that the legislature intended it to be mandatory). Section 7-10 provides such a consequence in that the name of no candidate for nomination shall be printed upon the primary ballot unless @ compliant statement of candidacy is submitted. ‘c.) That prior to circulating, and at the time circulators presented Respondent- ‘Candidate's petition to electors, each of Respondent-Candidate’s forty (48) petitions herein submitted stated: We, the undersigned, members of and affiliated with the Democratic Party and qualified primary electors of the Democratic Party, in the City of Rock Island in the county of Rock Island and State of Illinois, do hereby petition that the following named person or persons shall be a ‘candidate(s) of the Democratic Party for the nomination/election for the office or offices hereinafter specified, to be voted for at the Primary Election to be held on March 17, 2020, ‘See, Respondent-candidate’s petition sheets, 1-48. Emphasis supplied) (See, Exhibit H, pre-circulated petition sheet). 4.) That after circulating petitions, when circulators presented the petitions to be swom to before the notary as required by section 7-10, circulators, Respondent-Candidate included, struck the-Gig-ef Reek-Island from the header of their respective petitions on the advice of Rock Island County Chief Deputy Clerk Nick Camlin, also a circulator. For example, compare matching ink impressions of strack language with that of the ink impressions used by the circulator to complete the circulator statement on petitions numbered 1-3, 21-31. Dora “Villarreal” Nieman Objection©.) Objector states that the Respondent-Candidate’s Primary Petitions, contain less than 197 validly collected signatures of qualified primary electors of the Democratic Party after striking electors not living in the City of Rock Island as stated atthe time the lector signed the Respondent-Candidate’s petition sheets. £) That Respondent-Candidate’s Primary Petitions contain fewer than the ‘number of signatures required under section 7-10()), as indicated in her petitions, Respondent-Candidate is ineligible to be placed on the ballot. &,) Alternatively, the Objector states that Respondent-Candidate’s petition sheets, are invalid even if Respondent-Candidate struck “the city of Rock Island” from the header of her petitions before having circulated said petitions, which would still render all signatures invalid for failing to complete the city information in the header of the petitions as required by section 7-10. 10 ILCS 5/7-10 (West, 2019). 1H, The Objector states that Respondent-Candidate’s petition sheets are insufficient in fact and law when Respondent-Candidate failed to comply with the statutory ‘requirement that her petition sheets “shall be sworn to before some officer authorized to administer oaths in this State;” and in support thereof, Objector states the following factual basis: 4). Section 7-10 requires each candidate to add a circulator statement “sworn to before some officer authorized to administer oaths in this State.” 10 ILCS 5/7-10. (West, 2019), ). The Objector herein states Candidate-Respondent’s petition sheets were not “swom to before some officer authorized to administer oaths in this State” as required by section 7-10 and as illustrated here, the signature of “Carrie Clark” is not a genuine signature. Dora “Villarreal” Nieman Objectionnnn sa li@izBH, 202 top signature appears to be a Be ve 2 ts — genuine signature of Carrie } Sete Clark while the bottom does Hapa — most om ‘east = _ not. ©). Similarly, the circulator signatures of Catrie Clark (petition sheets mumber 32, 33, 38, 39, 40 and 41), as does Larry Burns (petition numbered 12), Angela Hoppes Normoyle (petition numbered 17), and Jose Moreno (petition numbered 38) are not ‘genuine signatures. 4). ‘That Respondent-Candidate’s petition sheets contain petition sheets that were not “swom to before some officer authorized to administer oaths in this State,” and signed by as required by section 7-10, Respondent-Candidate failed to comply with this statutory requirement, rendering the petitions 12, 17, 32, 33, 38, 39, 40 and 41 invalid, 1. The Objector states that Respondent-Candidate’s petition sheets lack the requisite ‘number of signatures as a result of circulator Erwin King’s failure to provide his complete address and in support thereof, Objector states the following factual basis: 4.) As stated in the preceding paragraphs, Section 7-10 mandatorily requires cach circulator to state “the street address or rural route number, as the case may be, as well as the county, city, village or town, and state.” 10 ILCS 5/7-10 (West, 2019). ,) That Erwin King failed to provide his correct, complete address renders petitions numbered 43, 44, 45, 46, 47 and 48 invalid for failing to comply to the mandatory directives of section 7-10. J. The Objector states that Respondent-Candidate’s petition sheets lack the requisite number of signatures as a result of petition sheets containing names of electors for whom are either not registered at the address indicated, whose signature is not genuine, failed to Dora “Villarreal” Nieman Objectionprovide a complete address, or signed more than once; and in support thereof, Objector states the following factual b a), Section 7-10 requires a candidate's petition “shall be signed by qualified primary electors ... and opposite the signature of each signer, his residence address shall be written or printed, The residence address required to be written or printed opposite each qualified primary elector’s name shall include the street address or rural route ‘number of the signer, as the case may be, as well asthe signer’s county, and city, village or town, and state. 10 ILCS $/7-10. (West, 2019) Emphasis added. b). The Objector herein states that Respondent-Candidate’s purported primary electors listed in Exhibit I are either not registered at the address indicated, whose signature is not genuine, failed to provide complete addresses or signed more than once. ). That Respondent-Candidate’s purported primary electors as indicated in Exhibit I are either not registered at the address indicated, whose signature are not ‘genuine, failed to provide complete addresses, or signed more than once, merits striking said signatures for failure to comply with section 7-10. WHEREFORE, the Objector prays that the purported nomination papers of Dora “Villarreal” Nieman as a candidate of the Democrat Party for nomination to the office of Rock Island County State’s Attorney be declared by the Honorable Electoral Board to be insufficient and not in compliance with the law of the State of Illinois and that the Candidate's name be stricken and that this Honorable Electoral Board enter its decision declaring that the name of illarreal” Nieman as a candidate of the Democrat Party for nomination to the office of Rock Island County State’s Attorney NOT BE PRINTED on the OFFICIAL BALLOT to be voted at the Primary Election to be held March 17, 2020. Dora “Villarreal” Nieman ObjectionPetitioner-Objector OBERT STHADT Address: 11121 22™ Street, Milan, Illinois 61264 VERIFICATION STATE OF ILLINOIS ) SS. COUNTY OF ROCK ISLAND ) 1, ROBERT STRADT, being first duly swom upon oath, depose and state that I have read the above and foregoing ROBERT STRADT, and that the matters and facts contained therein are true and correct tothe best of my knowledge and belief. ERT STRADT Subscribed and swom to before me by Robert Stradt this Bei of December, 2019. Beedle tae rustic OFFICIAL SEAL JENNIFER M KLINE oral Pui STMT OF ELnogs IY Couision Brome ROS Dora “Villarreal” Nieman Objectionv BEB? 400g (uopeuue JLGIHXa 40} Aeuso tuor: ‘sep Jot 98 eoQoeud 4943 JO G’MyBU 84} 0} ENP eBereAdD AED jou ABW ‘sieAMe} @JB10J09 esnoy-u) pue “sueAme) yueweAct 32 yons ‘eXewioNe euiog) “eBeueno9 soyoKudjew ensy Jou seop eys/ey Je4) Peyodes AaWOWE ‘uORENS|Gal JENUUE Ut ‘ G10z see, peueysiBex y827 - me] eo;}DeI 0} pezuOYINe pue eAyoy| uopeNsil : eU0y, 00zE-a9s (608) bOZE9 I ‘Pueys| YOO 400|J puooes enueny PIE ALE} | =S8@sPP\ ‘SyOUy|| “AUNoD puzis} YOON 002 ‘9 saquenon, sno; 8 voyssyu JOIN [BGLIEIA “W B10Q) UeWEIN ‘y 80g | :eweN po YS'SL'L 18 6L0Z ‘9 Jequisdeg Jo se LoyeUNO;L] Ayygesi pue AreUIIdIOSIQ 21;9Nd pue UOHENS|GEY dy\QNg JO P10Dey AeWUOYY [EN nn 282 G21 CYODTH AUVNITAIDSIG PITAN UNV NOLLVULSIDTA SATNYOLLY ‘HOUVALSelective Insurance Company of America 40 Wantage Avenue Branchville, New Jersey 07890 973-948-3000 PUBLIC OFFICIAL BOND Bond No. B 1217741 Know All Men By These Presents: That Dora Amalia Villarreal of 1824 22nd Avenue Rock Island State of IL 61201 (hereinafter) called the Principal) and the Selective Insurance Company of America (hereinafter called the Surety) a corporation under the laws of the State of New Jersey, with its principal office in the City of Branchville and the State of New Jersey are held and firmly bound unto Rock Island County (hereinafter called the Obligee) in the sum of Ten Thousand Dollars Dollars ($ 10000.00 ) for the payment whereof to the Obligee the Principal binds himself, heirs, executors, administrators and assigns, and the Surety binds itself, its successors and assigns, jointly and severally, firmly by these presents. Signed, sealed, and dated this 26th day of June 2019 ‘Whereas the above-named Principal has been duly appointed or elected to the office of: State's Attorney Now, therefore, the condition of the foregoing obligation is such that if the Principal shall during the period beginning on the 26th day of June, 2019 and ending onthe 26th day of Sune, 2020 {faithfully perform such duties as may be imposed on him by law and shall honestly account for all money that may come into his hands in his official capacity during such period, then this obligation shall be void; otherwise it shall remain in force. Dora Amalia Villarreal Were _ Selective Insurance Company of America Witness: (we Frnaipaly EXHIBIT Beta o8i6en00 Phylis setae B B-232 2186) dh p tebeCERTIFICATE To All To Whom These Presents Shall Come, Greeting: I, JESSE WHITE, Secretary of State of the State of Illinois, do hereby certify that the attached is a true copy of the Oath of Office of Dora A. Villarreal, States Attorney of Rock Island County, as filed in this office on August 29, 2019. IN TESTIMONY WHEREOF, I hereto set my hand and cause to be affixed the Great Seal of the state of Mlinois. Done at the City of Springfield, December 6, 2019. DeAk oB3temw CMeSTATE OF ILLINOIS dss. COUNTY OF ROCK ISLAND ) I, DORA A. VILLARREAL, do solemn): States and the Constitution of the State of Illinois, f ’s Attorney in and for Rock Island County, ly swear that J will support the Constitution of the United and that J will faithfully discharge the duties of the Office according to the best of my ability. G, DORA A. VILLARREAL STATE’S ATTORNEY ‘Taken and subscribed before me this 1 day of July, A. D. 2019. Giwh 2, hy JUDGELaw& Justice Health Vialtors Home Business Departments State's Attorney: ‘State's Attomey Home State's Attorney's Office (imine Case Processing ‘Our mission at the Rock Island County State's Attomey's Office is to serve and protect the “Fetony Case Guus public by seeking criminal justice and providing efficient legal services to the county Feeny Cues Se _ ‘goverment as @ whole. The State's Attorney's Office has two central goals set to Inernship Opportuntes Secomplsh our mission. First, to prosecute criminal cases with feimess and equality. Second, to work with ether county departments to act with fiscal responsiblity on behalf Unk of eres of the residents of Rock Island County. Falmess and equality are the comerstones of the criminal justice system. At the Rock Island County State's Attorney's Office, criminal prosecution is fair but firm. We work closely with local law enforcement agencies and do not discriminate on the basis of race, Color, Sex, creed, or national origin. It is the role of every prosecutor within our efice to ‘act with the commitment to seek justice, and in so doing, we do not simply act to convict. [As the chief legal advisor for county government, the State's Attorney provides sound legal services to the ‘county board, elected county officials and other county departments. Our legal advice seeks to promote fiscal responsibility on behalf of the residents of Rock Island County. In county government we must never forget that we serve at the will of our constituents, By achieving our goals, we work toward our mission. Our mission is designed to listen and to serve our dverse public. At the Rock Island County State's Attorney's Office, we gain professional and personal satisfaction from Public service. Our office works for the people of Rock Island County. We are proud to be at your service and {do our part to keep your families safe and help improve our community Dora A. Villareal State's Attorney ots Dorm A. Villarreal 1 - State's Attorney Rock Island County Courthouse (map &) Second Floor - 1317 3°4 Avenue, Rock Island TL 61201 1:00 AM to 4:30 PM - Monday thru Friday ‘OF Document Phone: (309) 558-3250 “end questions or comments about our website to the Rock Island County click here @ e Copyright © 2011 County of Rock Island, llinots. All rights reserved, a External LinkSTATEMENT OF ORGANIZATION PLEASE TYPE OR PRINT IN BLACK INK WI9 ML 29 PM 3 7 Full name and complete malling address of Political Committee: Friends of Dora Villarreal 1 citer ror aporess cance 329 18th Street Rock Island IL 61201 POLITICAL COMMITTEE BB cveacurne 0 sec cron NoTFKEATIONS VA EMAL OMY IDENTIFICATION # EMAILADDRESS: natenieman05@yahoo.com 3553 /-14 SEE PAMPHLET “A GUIDE TO CAMPAIGN DISCLOSURE” FOR GUIDANCE By NEW COMMITTEE {ymusT Be FLED WITHIN 10 DAYS OF CREATION, OR WITHIN2 OAYS IF CREATED WITHIN 30 DAYS BEFORE AN ELECTION) [1 Amenomenr. ¢wust se Fue WITH 10 DAYS OF AMY CHANGES. ENTER ONLY THOSE CHANGES FROM LAST©D-1 ON ELE) 10 Reacrivarine "AMOUNT OF FUNDS AVAILABLE AS OF [2| DATE COMMITTEE CREATED: 07/05/19 GREATION DATS Boy POLITICAL COMMITTEE DESIGNATION (ALL COMMITTEES CHOOSE ONLY ONE) Ba canonoare poumicasconnarrree® rs pinot cron prin sea ome *For purposes of contbrion Init nd repicemer ofc elected a diferent elections rust designate an eoction cycle by sting the ofe current So ‘Toe lr Aes hander i Pourca. action commarrer LD pourica parry commarres Dy extort wimamve commrrree 1 inoePenoenr execnorrure commMTTEE POLITICAL COMMITTEE'S AREA OF ACTIVITY, SCOPE, AND PARTY AFFILIATION ‘A. THIS COMMITTEE WILL PRIMARILY OPERATE IN THE FOLLOWING COUNTIES OR DISTRICTS: . (operating statewide orsupportng/oppocig statewide candidates r bat Iie, eve Dia) Rock isan County _— 8. POLITICAL PARTY AFFILATION: Democratic C. NAME AND ADDRESS OF EACH SPONSORING ENTITY (Fepplabe) NY PURPOSE OF THE POLITICAL COMMITTEE To elect Dora Villarreal for Rock Island County States Attorne: CANDIDATE(S) THE COMMITTEE 1S SUPPORTING OR OPPOSING (IF AMENDING, LIST ALL AS OF TODAY'S DATE) NAME AND ADDRESS Dora Villarreal 1317 3rd Avenue Rock Island IL 61201 ‘F MORE SPACE 1S NEEDED, PLEASE ATTACH ADDITIONAL SHEETS. ‘THIS FORM MAY BE REPRODUCED PAGEL OF2"ADDRESS, PHONE NUMBER, AND E-MAIL ADDRESS [posmon [Nae ‘829 18th St., Rock Island, IL 61201 mn | Eva Savala 309-798-0340 awwsavalalat4i4@gmalicom > 829 46th St, Rock Island, I. 61201 ress Nate Nieman + 309-798-0340 - ‘natenieman05@yahoo.com 929, 78th Street, Rock Island, |L 61201 309-788-5460 cfeuerbach@tthelawcentre.com HID nvanciaL WSsTTUTIONS AND OTHER REPOSTTORIES OF COMMITTEE FUNDS po Nae Tas AND PHONE HUMBER: , '804 Tech Drive, Milan, IL 61264 IHMVCU 308-783-6200 DISPOSITION OF RESIDUAL FUNDS IN THE EVENT OF DISSOLUTION OR TERMINATION OF THE COMMITTEE ICD erunw-T0 conrmBUTORS Iv AMOUNTS NOT TO EXCEED THEIR INDIVIDUAL CONTRIBUTIONS IDI Transren to aNorHER POLTIcAL coMMITTE: BQ Teansren To acHaRITABLE ORGANTzATION; — LULAG. IF MORE SPACE iS NEEDED, PLEASE ATTACH ADDITIONAL SHEETS 'VERPIEATON: BALLOT ITA COMMATTEE OMY {1 oecAte AT Te BACLT SOMITE FORMED FoR POE GF PORTIA OFESNG A GUESDON CF PURLEYOUCY ALLCONTRRUTING AAD EPO OF ev EE on THE MAYER DERRY ATT OF ONION. TE COVMETE KAY ACT UMLAITED CONTR A A SE, RODD eas avon coma, DD tain To ABE He GMS Sl DEA THE CONDETEE MLACH CF AGATE HDS}. PRINTED AND WRITTEN SIGNATURE OF COMMITTEE CHAIRPERSON ven AL eOLTcaL coat oezane Tat Th ATE OF OROADATIN NELUSNG A AoSOMPAMING SED JUS MO STATEVENS NS BEN AMINED BY ME AND TO THEBES CF RIDE ‘ee Al OAR, COMP TATEET OF ORGAMEATON AS RED RATES THeLECDO CoE ONDEASTAND TT WALMLLY Raa FALSEGHTMECMMLE EATEN OF ONNCATONIS SURE TOA PENALTY OF ATLLAST 301A TOSSED. Poa ana DAVID H. TOWNS, ) Plaintifé, ) d ) No. 91 MR 26 ) BOONE COUNTY OFFICERS ) ELECTORAL BOARD, SYLVIA ) SCHROEDER, CHAIRMAN, JULIE ) Cl LED KLIEVE, GORDON SPOONER AND 5 ROONE CBUNFY ILLINOIS ROGER T. RUSSEL, ) Defendants. ) JAN 10 1992 Judgment Order pe —— ‘rk oft Circuit Cour This cause coming on for hearing on the Motion for Judgment on the Pleadings filed by the Defendant, Roger Russell, and the Motion for Summary Judgment filed by the Defendants, County Officers Electoral Board, Sylvia Schroeder, Chairman, Julie Klieve, and Gordon Spooner, and the Court after arguments by counsel and being fully advised in the premises: It is Ordered that the Motion for Judgment on the Pleadings, be, and the same is hereby Granted. Judgment is entered in favor of the Defendant, Roger Russell, and against the Petitioner, David H. Towns. It is further Ordered that the Motion for Summary Judgment, be, and the same is hereby Granted. Judgment is entered in favor of the Defendant, County Officers Electoral Board, Sylvia Schroeder, Chairmn, Julie Klieve, and Gordon Spooner, and against the Petitioner, David H. Towns. It is further Ordered that the Petition for an Order of Mandamus is Denied, and that 2 Writ of Mandamus shall not issue. It is further Ordered that the Defendants' prayer for attorney fees, expenses and costs are hereby Denied. Enter: January 10, 1992Suggovied Reviews March 2018 'SBENG. P10 Party and quoted pimery alert Rock lend ine County of the lolowing names person or persons shat be a candidate) of the 9 ofoes harris species to be tose fo: a be Prinary oto to‘An or °V* indicates that signatures on the designated sheet/line is objected to for the reasons set forth above the column in which the “x” or “V appears, in accordance with the Objector’s Petition, of which this Exhibit Recapitulation is incorporated therein, Sheet [Line [Signer not — | Signer’s | Signer’s address | Signer signed No. registered at | signature not | missing or Petition more than address shown | genuine incomplete | once Lae v zit ev 2/27 a zi 4 4 Zit a [sts - Ls |e —— Wa | | fe 1 we LG@le we Le wa po a cs < — $ 1 — - — can) - ea & lo v elz <= 7 Lota a = ¢ 13 wa — £ a WA ol? Fi — we SEP ele - lS = = = 10 | 7a a 12 | wa 213 a Tz 7 | lps 13 a — Dora “Villareal” Nieman objection Page 1 of 6‘An*X" or °V" indicates that signatures on the designated sheetline is objected to forthe reasons set forth above the column in which the “x” or “¥” appears, in accordance with the Objector’s Petition, of which this Exhibit Recapitulation is therein, Sheet /Line | Signer not —[Signer’s | Signer’s address | Signer signed No. registered at | signature not_| missing or Petition more than address shown | genuine | incomplete _| once 112 |@ “ 13 | 2 Va 1319 < iy | ¢ x wa | 9 A mle “ m | LY | x — Wf | a 3 ra wal is we is] 7 e AST g v isl a | wz [is | 12 (e| © = ie | 2 w wT o Alt wa nie z WS | 1 4 DeeXT0C peg Blialine fee commie s | (2 yt zw) z mo Ze = Zp ~ Dora “Villareal” Nieman objection Page 2 0f6‘An “x” or “J” indicates that signatures on the designated sheeUline is objected to forthe reasons set forth above the column in which the “x” or “V” appeats, in accordance with the Objector’s Petition, of which this Exhibit Recapitulation is incorporated therein, Sheet |Line | Signernot | Signer’s | Signer’s address | Signer signed No. registered at | signature not_| missing or Petition more than address shown | genuine | incomplete __| once au ilv wa zl 4 a - } a {10 wz 2 22] | Wa az L2z| 2 wa 213 = 22] 0 ve > 2B eo C = a 23/3 a 23/5 ia ze z/3 a Wa | vam w]e 7 eS | ett Ss a eae a zw? |S wv Zl iy wm — wis Ze L vw Wa Le | 3043 = |g i Wa tt va = == 3 a se eS . 3[ljo | 4 - Dora “Villareal” Nieman objection Page 3 of 6‘An “x” or “J” indicates that signatures on the designated sheet/line is objected to for the reasons set forth above the column in which the “x” or “V” appears, in accordance with ‘the Objector’s Petition, of which this Exhibit Recapitulation is incorporated therein. Sheet | Line | Signer not ‘Signer’s address | Signer signed No. registered at missing or Petition more than address shown | genuine incomplete ‘once (3277 - 2 | wa ea 32/5 7 a 2] @ se — 33/4 uv a [33ty7 2 Jo y — 3 t ia xz 211 F — wv Lay wa ay) 3 z ay] ie 34 ia a [2s - — ¥ Ke va Lis” a — 3S| | a as| 3 = gp fra] 12 | = Zz is | 6 | ie. ae ‘e| 2 — a | wi? oS —_| ae a ecm S z 10 ca — 38 wv Dora “Villarreal” Nieman objection Page 4 of 6‘An “x” or “J indicates that signatures on the designated sheet/line is objected to for the reasons set forth above the column in which the “x” or “¥” appears, in accordance with the Objector’s Petition, of which this Exhibit Recapitulation is incorporated therein. Sheet |Line | Signernot | Signer’s Signer’s address | Signer signed No. registered at | signature not | missing or Petition more than address shown | genuine incomplete once 36 ie Be Be 7 3? a9 YO. Yo Yo YO 2 uo! & ye 4O 4 a We 4 4 Lu] Lie ue ue qe 4u Yel PPB Bhis VI NN T Is wb | Ws AER KINSN oPeL le Lbeg \ Dora “Villareal” Nieman objection Page 5 of 6‘An "x" or “J” indicates that signatures on the designated sheet/line is objected to for the reasons set forth above the column in which the “x” or “V" appears, in accordance with the Objector’s Petition, of which this Exhibit Recapitulation is incorporated therein. Sheet |Line | Signernot —['Signer’s | Signer’s address | Signer signed No. registered at _| signature not_| missing or Petition more than ‘once Dora “Villareal” Nieman objection Page 6 of 6