STATE OF NEW YORK
SUPREME COURT : COUNTY OF NIAGARA
WILLIAM L. ROSS, as Chairman and Member
of the Niagara County Committee of the Conservative
Party of the State of New York and as voter and taxpayer of
Niagara County and the State of New York,
JOSHUA WALKER, as the incumbent candidate for the
‘office of Town Councilman in the Towa of Royalton,
‘Niagara County, as Vice Chairman and Member of the
Niagara County Committee of the Conservative Party
of the State of New York, and as voter and taxpayer of
Niagara County and the State of New York,
NIAGARA COUNTY COMMITTEE OF
‘THE CONSERVATIVE PARTY OF THE
STATE OF NEW YORK,
CONSERVATIVE PARTY OF THE,
STATE OF NEW YORK, and
GERARD KASSAR, as Chairman and Member
of the Conservative Party of the State of New York
and as voter and taxpayer of Kings County and
the State of New York
Plaintiffs,
vs. Index No.
STATE OF NEW YORK,
BOARD OF ELECTIONS OF
‘THE STATE OF NEW YORK,
GOVERNOR OF
‘THE STATE OF NEW YORK,
SENATE OF THE STATE OF NEW YORK,
MAJORITY LEADER and PRESIDENT
PRO TEMPORE OF THE SENATE OF
THE STATE OF NEW YORK,
MINORITY LEADER OF THE SENATE OF
THE STATE OF NEW YORK,
(8365503: )ASSEMBLY OF THE STATE OF NEW YORK,
MAJOIRTY LEADER OF THE ASSEMBLY,
OF THE STATE OF NEW YORK,
MINORITY LEADER OF THE ASSEMBLY,
OF THE STATE OF NEW YORK;
SPEAKER OF THE ASSEMBLY OF
‘THE STATE OF NEW YORK, and
NIAGARA COUNTY BOARD OF ELECTIONS,
Defendants.
VERIFIED COMPLAINT
Plaintiffs, William L, Ross, as Chairman and Member of the Niagara County Committee of
the Conservative Patty of the State of New York and as voter and taxpayer of Niagara County and
the State of New York; Joshua Walker, as the incumbent candidate for the office of Town
Councilman in the Town of Royalton, Niagara County, as Vice Chairman and Member of the
Niagara County Committee of the Conservative Party of the State of New York and as voter and
taxpayer of Niagara County and the State of New York; Niagara County Committee of the
Conservative Patty of the State of New York (“Niagara County Conservative Pasty”); Conservative
Patty of the State of New York (“New York State Conservative Party”); and Gerard Kassar, as
Chairman and Member of the Conservative Party of the State of New York and as voter and
taxpayer of Kings County and the State of New York (collectively, “Plhintiffs”), for their Verified
‘Complaint against Defendants, State of New York (“State”); Board of Elections of the State of New
‘York (“Board”); Governor of the State of New York (“Governor”); Senate of the State of New
‘York (“Senate”); Majority Leader and President Pro Tempore of the Senate of the State of New
York; Minotity Leader of the Senate of the State of New York; Assembly of the State of New York
(“Assembly”); Majority Leader of the Assembly of the State of New York; Minority Leader of the
£8365503:) 2Assembly of the State of New York; Speaker of the Assembly of the State of New York; and
Niagara County Boatd of Elections (collectively, “Defendants”), state as follows:
INTRODUCTION
1. Plaintiffs bring this declaratory judgment action against Defendants seeking a