Caveat Brief

IN THE PROBATE COURT OF CAMDEN COUNTY
STATE OF GEORGIA
IN RE: PETITION PURSUANT TO GEORGIA )

CONSTITUTION ARTICLE IX, SECTION II, )
PARAGRAPH I (b) (2) FOR SPECIAL ) Case No. 2021P271
ELECTION CONCERNING )
CAMDEN COUNTY'S PURCHASE )
OF UNION CARBIDE PROPERTY )
CAVEATOR’S BRIEF REGARDING THE

ADMISSIBILITY OF PHOTOCOPIED SIGNATURES
Petitioners have filed petition pursuant to Ga. Const., Article IX, Section II, Paragraph I(b)(2)
seeking referendum to repeal unspecified resolutions of the Caveator Camden County Board of
Commissioners. As Petitioners note in their brief, the bare language of Ga. Const., Article IX,
Section II, Paragraph I(b)(2) merely uses the word “signatures”.
When construing a statute, "we must presume that the General Assembly meant what
it said and said what it meant." Deal v. Coleman, 294 Ga. 170, 172 (1) (a) (751 SE2d
337) (2013) (punctuation omitted). Accordingly, we "afford the statutory text its plain
and ordinary meaning," "view[ing] the statutory text in the context in which it
appears," and "read[ing] the statutory text in its most natural and reasonable way, as
an ordinary speaker of the English language would." Id. at 172-173 (1) (a)
(punctuation omitted). When, as here, statutory text is "clear and unambiguous," our
interpretive task begins and ends with the text itself. Id. at 173(punctuation omitted).
Bell v. Hargrove, (Ga. Dec. 14, 2021) S21G0459 at 6
The word signature(s) in its ordinary meaning is defined by Merriam-Webster’s Online
Dictionary as:
1(a): the act of signing one's name to something
(b): the name of a person written with his or her own hand (Emphasis supplied)
(https://www.merriam-webster.com/dictionary/signature)
Petitioners also urge the Court to consider an application of the Georgia Evidence Code
citing to the following:
-1-
“A duplicate shall be admissible to the same extent as an original unless: (1) A
genuine question is raised as to the authenticity of the original; or
(2) A circumstance exists where it would be unfair to admit the duplicate in lieu
of the original.”
O.C.G.A. §24-10-1003 (Emphasis supplied)
Respondent attaches hereto Composite Exhibit A bearing numerous duplicate signatures to
the petition by purported electors. Of the 44 purported electors' signatures in Exhibit A, there are
41 duplicate signatures, bearing various names and dates and inconsistent signatures on
inconsistent formats of the petition which leaves a total of only 2 presumably original signatures
of purported electors. Said duplicates were found in the first sample of signed petitions which sample
represents less than one-fourth of the purported signatures.
Respondent asserts that the willful and knowing inclusion of duplicate signatures and
multiple petition formats is a deliberate attempt to mislead the Court as to the accuracy and
sufficiency of the propounded signatures and is a fraud upon the Court. This then triggers both
statutory trip wires of “a genuine question raised as to the authenticity of the original; or a
circumstance exists where it would be unfair to admit the duplicate in lieu of the original.”
Specifically, Respondent shows the Court from Exhibit A that a Debra Fanaro's name and
signature appear six times in the Petitioners' filing with two signatures on the same date (9-12-19)
that appear to be on different formats as to call into question the validity of both. Jennifer Fabricks'
signature appears three times with two different dates attached (8-19-19 & 12-10-21). Carl Erk
appears four times on 3 different petitions, one undated and two dated variously 8-26-19 &
10-11-20. M. Jacqueline Eichorn (or Mary Jacqueline Eichorn) appears three times with two
different dates attached (8-22-19 & 12-9-21). Michael Kornas appears three times (8-31-19, 8-5-21
& 11-27-21). Alexandria Kornas appears three times (8-31-19, 8-5-21 & 11-27-21). George
Zeilenbach appears two times (8-5-21 & 11-27-21). Joanne Kuvey appears three times on the
same date (9-13-19) but uses one street address and two lot numbers on three different petition
forms. Louise Gaskins appears four times on three different dates (8-?-19, 9-1-19 & 12-1-21).
Janice Oberg signed three different petitions (10-5-19, 1-20-21 & 5-10-21). Colleen Weinkle
appears three times on two different dates (8-15-19 & 9-27-20). Marc Yarbrough signed two times
-2-
(5-9-21 & 11-30-21). An Alexandra Yarbrough and a "Lexie" Yarbrough using the same address
(124 Oarsman Xing, St. Marys, GA) signed on the same petition forms as Marc Yarbrough on the
same two dates although using two different phone numbers.
Petitioners want the Court to apply the Georgia Evidence Code in the Constitutional
provision’s absence of qualification of the word “signatures”. The definitions provision of O.C.G.A.
§1-3-3(19) is the closest the Code comes to defining the terms as follows: 'Signature' or
'subscription' includes the mark of an illiterate or infirm person." A “mark” (otherwise undefined
in the Georgia Code) is an original act requiring that the illiterate or infirm person perform some
physical act making an impression upon a document or writing which is then acknowledged as his
or her signature. The word mark is defined by Merriam-Webster’s Online Dictionary as:
3a(2): an impression (such as a scratch, scar, or stain) made on something
...
c: a cross made in place of a signature
https://www.merriam-webster.com/dictionary/mark
Neither a photocopy nor a photographic or electronic rendering could ever suffice as a signature or
mark under the plain meaning of the term.
Petitioners also mention but discount the requirements of the Georgia Elections Code, Title
21. Specifically, O.C.G.A. §21-4-8 concerning Recall Petitions is the closest analogue to the
Constitutional referendum petition rule. It provides explicit instruction concerning original signatures
and the procedures to be used in obtaining and verifying the same.
...
(b) Every elector signing a recall petition shall do so in the presence of the
person circulating the petition, who is to execute the affidavit of verification on the
reverse side of the petition form. At the time of signing, the elector shall sign his
name, and such elector or the person circulating the petition shall print the name of
the elector below the elector's signature and shall print or write in the appropriate
spaces following the signature the elector's residence address, giving number and
street or route and city, the name of the county, and the date on which the elector
signed the petition. No notary public may sign the petition as an elector or serve as
-3-
a circulator of any petition which he or she notarized. Any and all sheets of a recall
petition that have the circulator's affidavit notarized by a notary public who also
served as a circulator of one or more sheets of the recall petition or who signed one
of the sheets of the petition as an elector shall be disqualified and rejected.
(c) If an elector is incapable of signing his or her own name, he or she may
specifically request the circulator of the petition to sign and print his or her
name and complete the information required on the petition sheet to accompany the
signature; provided, however, that the circulator shall also sign his or her full
name beside the printed name of such elector.
(d) The person before whom the electors signed the recall petition shall verify,
in an affidavit subscribed and sworn to by him or her before a notary public,
that each of the names on the petition form was signed in his or her presence on
the date indicated and that in his or her belief each signer was an elector of the
electoral district of the officer sought to be recalled.
...
(f) An elector may change the way his or her signature and residence address
appear on the recall petition at any time prior to the filing of the petition for
verification by striking through his or her name and initialing the strike-through
and re-signing the petition with his or her printed name corrected accordingly.
This Code sections outlines a very specific method of ensuring the authenticity and orginality
of the signers’ marks. Petitioners argue that “No substantive law compels any different result” than
their assertions of admissibility of photocopied signatures, all while urging the Court to also
recognize O.C.G.A. § 21-2-215, the Georgia Elections Code, in which registrars are explicitly
authorized to verify petitions using electronic images of voters’ signatures.(“The electronic image
of the voter's signature may be used by the registrars in the same manner as the original
signature on the voter registration card to verify absentee ballot applications, absentee ballots,
petitions, and other documents which require the registrars to compare the signature of the
voter on the document to the signature on the voter's registration card.”). Petitioners argue that
-4-
“If copies of voter’s signatures are sufficient in the same manner as an original signature on a voter
registration card for registrars to verify petitions, they should be sufficient for this Court in
determining the validity of this petition.” This is a specious argument. Registrars are in possession
of at least one original signed document, i.e. the voter registration card.
“However, in counties in which a computer system for the electronic imaging of the
entire voter registration card or the signature of the voter is operational and permits
the registrars to view the signature of the voter electronically, the completed
registration cards may be stored in a secure area outside of the main office of
the board of registrars, provided that such cards may be retrieved within a
reasonable time in the event that the actual card is needed.”
Petitioners seek to tender copies of signatures and have those compared to copies of signatures on
electronic images of a voter registration card. There is no original needed on either side (petitioner
or registrar) in their argument. This assertion defies logic. Photoshop or other digital manipulation
of images makes the absence of an original physically marked petition more than suspect. There must
be an original signature available for authentication.
It is interesting to note that the formats of the petition vary as well with the propounders or
authors of the petition (identity unknown) seeming to acknowledge the need for original signatures.
Jennifer Fabricks' signature of 8-19-19 appears on a photocopied petition bearing the legend
“Return Petition with Original Signature...”. Her signature of 12-10-21 (also an electronic
duplication) bears the legend “Please return your signed petitions by email. Upload a .pdf copy
or a good quality photo of the complete petition to: info@spaceportpetition.org ”
(Respondent’s Composite Exhibit A pp. 6-7).
CONCLUSION
Respondent asserts that the willful and knowing inclusion of duplicate signatures and
multiple petition formats as shown is a deliberate attempt to cause confusion and delay in the
accurate tabulation and verification of the signatures needed and is intended to mislead the Court as
to the accuracy and numerical sufficiency of the propounded signatures and thus is a fraud upon the
Court.
-5-
Respondent concedes that Ga. Const., Article IX, Section II, Paragraph I(b)(2) does not state
anything more than “signatures” without qualification or definition. The plain meaning doctrine of
statutory construction as most recently stated in the Bell decision, supra, must thus be applied and
original physically marked signatures should be required in lieu of photocopied or electronically
reproduced images. A referendum petition under the Home Rule provision is no less momentous and
is, indeed, equally important to a recall election petition and should operate under the same high
standard of originality of signature. Respondent respectfully requests that only original physically
marked signatures be allowed in support of the instant petition.
This ___ January

3d day of _______________, 22
20___.
______________________________
JOHN S. MYERS, P.C. JOHN S. MYERS
P.O.Box 99 Georgia Bar No. 533150
200 East Fourth Street Attorney for Camden County
Woodbine, Georgia 31569
Phone (912) 510-8400
countyattorney@co.camden.ga.us
-6-
CERTIFICATE OF SERVICE
I hereby certify that I have this day served a true copy of the foregoing by electronic
transmission/depositing the same in the United States Mail with sufficient postage attached thereto
to guaranty delivery to the following:
Dana F. Braun
Georgia Bar No. 078512
dbraun@ellispainter.com
Kimberly Cofer Butler
kbutler@ellispainter.com
Philip M. Thompson
pthompson@ellispainter.com
Ellis Painter Counsel for Plaintiffs
P.O. Box 9946
Savannah, GA 31412
(912) 233-9700
This ___ January

3d day of _______________, 22
20___.
______________________________
JOHN S. MYERS, P.C. JOHN S. MYERS
P.O.Box 99 Georgia Bar No. 533150
200 East Fourth Street Attorney for Camden County
Woodbine, Georgia 31569
Phone (912) 510-8400
countyattorney@co.camden.ga.us
-7-
EXHIBIT A
PETITION TO REPEAL RESOLUTIONS OF CAMDEN COUNTY BOARD OF COMMISSIONERS PETITION TO REPEAL RESOLUTIONS OF CAMDEN COUNTY BOARD OF COMMISSION!
WHEREAS, the Camden County Board of Commissioners have adopted resolutions autho WHEREAS, the Camden County Board of Commissioners have adopted resolutions ay
ring Camden County to enter into and extend the term of that certain Option Contract
by and be- rizing Camden County to enter into and extend the term of that certain Option Contract by and
ween Camden County and Union Carbide Corporation (the "Union Carbide Option Contract"),
whereby tween Camden County and Union Carbide Corporation (the "Union Carbide Option Contract"), whe
Jnion Carbide Corporation has granted Camden County the right to purchase a substantial portion of Union Carbide Corporation has granted Camden County the right to purchase a substantial portic
1, 01 1.54 acres in Camden County, Georgia (the "Union Carbide Property"); 4,011.54 acres in Camden County, Georgia (the "Union Carbide Property");
WHEREAS, the registered electors signing this petition desire to compel the Probate Court WHEREAS, the registered electors signing this petition desire to compel the Probate (
Df Camden County to call a special election for the purpose of submitting the repeal of the resolutions of Camden County to call a special election for the purpose of submitting the repeal of the resolu
authorizing the Union Carbide Option Contract and its renewal or extension to the registered electors
of authorizing the Union Carbide Option Contract and its renewal or extension to the registered electc
Camden County for approval or rejection in accordance with Article IX, Section II, Paragraph 1(b)(2)
of l Camden County for approval or rejection in accordance with Article IX, Section II, Paragraph 1(b)(
the Constitution of the State of Georgia; J the Constitution of the State of Georgia;
NOW, THEREFORE, the undersigned elector hereby petitions the Probate Court of Camden I NOW, THEREFORE, the undersigned elector hereby petitions the Probate Court of Car
County to submit the following question concerning the repeal of the resolutions authorizing the
Union l County to submit the following question concerning the repeal of the resolutions authorizing the I
Carbide Option Contract to a special election of the registered electors of Camden County, Georgia for i Carbide Option Contract to a special election of the registered electors of Camden County, Georgi
approval or rejection: J approval or rejection:
"Shall the resolutions of the Board of Commissioners of Camden County, Georgia authorizing i "Shall the resolutions of the Board of Commissioners of Camden County, Georgia author
the Option Contract with Union Carbide Corporation and Camden County's right and option
to l the Option Contract with Union Carbide Corporation and Camden County's right and optii
purchase the property described therein be repealed." I purchase the property described therein be repealed."
I
IN WITNESS WHEREOF, the undersigned registered elector in Camden County, Georgia has j IN WITNESS WHEREOF, the undersigned registered elector in Camden County, Georgi:
executed this Petition as gf the date written below. I executed this Petitions of the date written below.
Signature: _
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Signature: _
Print Name: Print Name:
Date: I Date:.
Address: 4 ^S>*7 lAJfl Address:4 ^>-5 7 &>

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Citv: ^/ A)fesLf3/OTiY GrA i City: &A-I ('SLA M Gi\
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Zip: Zip:
Telephone: ^ Telephone:
Email (optional) Email (optional)
2Q21 DEC 21 am9:20

REC'D CAMDEN ELECTIONS
DEC 1 4 2021
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PETITION TO REPEAL RESOLUTIONS OF CAMDEN COUNTY BOARD OF COMMISSIONERS

WHEREAS, the Camden County Board of Commissioners have adopted resolutions autho
rizing Camden County to enter into and extend the term of that certain Option Contract by
and be
tween Camden County and Union Carbide Corporation (the "Union Carbide Option Contract"),
whereby
Union Carbide Corporation has granted Camden County the right to purchase a substantial
portion of
4,01 1 .54 acres in Camden County, Georgia (the "Union Carbide Property");
WHEREAS, the registered electors signing this petition desire to compel the Probate Court
of Camden County to call a special election for the purpose of submitting the repeal of the resolutions
authorizing the Union Carbide Option Contract and its renewal or extension to the registered
electors of
Camden County for approval or rejection in accordance with Article IX, Section II, Paragraph
1(b)(2) of
the Constitution of the State of Georgia;
NOW, THEREFORE, the undersigned elector hereby petitions the Probate Court of Camden
County to submit the following question concerning the repeal of the resolutions authorizing the Union
Carbide Option Contract to a special election of the registered electors of Camden County, Georgia
for
approval or rejection:
"Shall the resolutions of the Board of Commissioners of Camden County, Georgia

authorizing
the Option Contract with Union Carbide Corporation and Camden County's right and
option to
purchase the property described therein be repealed."
IN WITNESS WHEREOF, the undersigned registered elector in Camden County, Georgia has
executed this Petitiomas of the date written below.
Signature: * 'Vt{ HajJ

Print Name: PAPAdZj
Date:
Address:
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PETITION TO REPEAL RESOLUTIONS OF CAMDEN COUNTY BOARD OF

COMMISSIONERS
WHEREAS, the Camden County Board of Commissioners have adopted
resolutions autho
rizing Camden County to enter into and extend the term of that certain
Option Contract by and be
tween Camden County and Union Carbide Corporation (the "Union Carbide
Option Contract"), whereby
Union Carbide Corporation has granted Camden County the right to
purchase a substantial portion of
4,01 1.54 acres in Camden County, Georgia (the "Union Carbide Property
");
WHEREAS, the registered electors signing this petition desire to compel
the Probate Court
of Camden County to call a special election for the purpose of submitti
ng the repeal of the resolutions
authorizing the Union Carbide Option Contract and its renewal or extensio
n to the registered electors of
Camden County for approval or rejection in accordance with Article
IX, Section II, Paragraph 1(b)(2) of
NOW, THEREFORE, the undersigned elector hereby petitions the

Probate Court of Camden
County to submit the following question concerning the repeal of the resolutio
ns authorizing the Union
Carbide Option Contract to a special election of the registered electors
of Camden County, Georgia for
"Shall the resolutions of the Board of Commissioners of Camden

County, Georgia authorizing
the Option Contract with Union Carbide Corporation and Camden
County's right and option to
IN WITNESS WHEREOF, the undersigned registered elector in Camden

County, Georgia has
executed this Petition as of the date written below.
Signature: _ KL<\ ^Zt)^ i ^

Print Name:
Date:
Address: 1 £-£>
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rizing Camden County to enter into and extend the term of that certain Option Contract by and be
tween Camden County and Union Carbide Corporation (the "Union Carbide Option Contract"), whereby
Union Carbide Corporation has granted Camden County the right to purchase a substantial portion of
of Camden County to call a special election for the purpose of submitting the repeal of the resolutions
authorizing the Union Carbide Option Contract and its renewal or extension to the registered electors of
Camden County for approval or rejection in accordance with Article IX, Section II, Paragraph 1(b)(2) of
Carbide Option Contract to a special election of the registered electors of Camden County, Georgia for
"Shall the resolutions of the Board of Commissioners of Camden County, Georgia authorizing
the Option Contract with Union Carbide Corporation and Camden County's right and option to
Signature: _
Print Name: L>e6fLA aJa £o

Date: I I
Address: VacmiJ a £6
City: QflGsLAtAb-j &A
Zip: 3-i &
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PETITION TO REPEAL RESOLUTIONS OF CAMDEN COUNTY BOARD OF COMMISSION
ERS
PETITION TO REPEAL RESOLUTIONS OF CAMDEN COUNTY BOARD
WHEREAS, the Camden County Board of Commissioners have adopted resolutions autho- OF fflMMlSSlflHH
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rizing Camden County to enter into and extend the term of that certain Option Contrac WHEREAS, the Camden County Board of Commissioners have adopted
resolutions au
t by and be- 1
tween Camden County and Union Carbide Corporation (the "Union Carbide Option Contrac rizing Camden County to enter into and extend the term of that
certain Option Contract by and
t"), whereby i
Union Carbide Corporation has granted Camden County the right to purchase a substan tween Camden County and Union Carbide Corporation (the "Union
Carbide Option Contract"), whei
tial portion of I
4,01 1 .54 acres in Camden County, Georgia (the "Union Carbide Property"); Union Carbide Corporation has granted Camden Count* the right
to purchase a substantial portio
I 4,01 1.54 acres in Camden County, Georgia (the "Union CarD:ce
l Property");
WHEREAS, the registered electors signing this petition desire to compel the Probate
Court \
of Camden County to call a special election for the purpose of submitting the repeal WHEREAS, the registered electors signing this petition ces re tc compel
the Probate C<
of the resolutions i
authorizing the Union Carbide Option Contract and its renewal or extension to the registere of Camden County to call a special election for the purpose of submitti
ng r e -eoeal of the resoluti
d electors of I
Camden County for approval or rejection in accordance with Article IX, Section II, Paragra authorizing the Union Carbide Option Contract and its renews or extensio
n to re -eg stered elector
ph 1(b)(2) of '
the Constitution of the State of Georgia; Camden County for approval or rejection in accordance with Article
i 1 Sector Paragraph. 1 'b)(2
NOW, THEREFORE, the undersigned elector hereby petitions the Probate Court
of Camden i
County to submit the following question concerning the repeal of the resolutions authoriz NOW, THEREFORE, the undersigned elector hereby petitions the Probate
ing the Union lQ Court of Came
Carbide Option Contract to a special election of the registered electors of Camden County, Georgia County to submit the following question concerning the repeal of the
resolutions authorizing the Un
for * Carbide Option Contract to a special election of the registered electors
approval or rejection: of Camden County, Georgia
authorizing i
the Option Contract with Union Carbide Corporation and Camden County's "Shall the resolutions of the Board of Commissioners of Camden
County, Georgia authorizi
right and option to I
purchase the property described therein be repealed." the Option Contract with Union Carbide Corporation and Camden
County's right and option
lit purchase the property described therein be repealed."
IN WITNESS WHEREOF, the undersigned registered elector in Camden County, Georgia
has |
executed this Petition as of the date written below. IN WITNESS WHEREOF, the undersigned registered elector in Camden
County. Georgia h
I
Signature: _
Signature:
Print Name: _Eb6M aJa_£o Print Name: J
-
Date:
Fftfo/Agfc. 1
Date:
Address:
City: (yA
Address: 70\ W. CMurrA *7t~. t
Zip: •g
City: iff: 1A&J/U6
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Zip:
Telephone: Î - kl t-j- Q(ol cK
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Return Petition with Original Signature To:
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DEC I 4 202! 3° Repeal Petition - P.O. Box 867 - Kingsland, Georgia 31548
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PETITION TO REPEAL RESOLUTIONS OF CAMDEN COUNTY BOARD OF COMMISSIONERS i
I
WHEREAS, the Camden County Board of Commissioners have adopted resolutions autho- I
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tween Camden County and Union Carbide Corporation (the "Union Carbide Option Contract") S
, whereby i
Union Carbide Corporation has granted Camden County the right to purchase a substantia
l portion of l
I
I WHEREAS, the registered electors signing this petition desire to compel the Probate
Court |
I of Camden County to call a special election for the purpose of submitting re repeal of the
resolutions i
ftide I authorizing the Union Carbide Option Contract and its renewal or extension to the registered
electors of I
County 1 Camden County for approval or rejection in accordance with Article IX. Section I. Paraph 1(b)(2) of I
" the Constitution of the State of Georgia;
ination. NOW, THEREFORE, the undersigned elector hereby petitions the Probate Court of Camden
i
ayable to County to submit the following question concerning the repeal of the resolutions authorizin
g the Union I
'operty. Carbide Option Contract to a special election of the registered electors of Camden County, Georgia for
approval or rejection: I
"Shall the resolutions of the Board of Commissioners of Camden County, Georgia authorizin
•king up gi
to I
ie FAA it ' Purchase the property described therein be repealed." l
S
xean IN WITNESS WHEREOF, the undersigned registered elector in Camden County, Georgia has i
Signature: I
Print Name:
Date: I^
Address: 70\ IU. CJMJLYCk Crt".
Citv: Vf". tA0J/U4
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Zip: 3
Telephone: 4(>4r 7'
Email (optional)
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Q M Return Petition with Original Signature To:
so Repeal Petition - P.O. Box 867 - Kingsland, Georgia 31548
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WHEREAS, the Camden County Board of Commissioners have adopted resolutions authorizing
Camden County to enter into and extend the term of that certain Option Contract by and
between Camden County and Union Carbide Corporation (the "Union Carbide Option
Contract"), whereby Union Carbide Corporation has granted Camden County the right to
purchase a substantial portion of 4,011.54 acres in Camden County, Georgia (the "U nion
Carbide Property");
WHEREAS, the registered electors signing this petition desire to compel the Probate Court of
Camden County to call a special election for the purpose of submitting the repeal of the
resolutions authorizing the Union Carbide Option Contract and its renewal or extension to the
registered electors of Camden County for approval or rejection in accordance with Article IX,
Section II, Paragraph 1(b)(2) of the Constitution of the State of Georgia;
County to submit the following question concerning the repeal of the resolutions authorizing
the Union Carbide Option Contract to a special election of the registered electors of Camden
County, Georgia for approval or rejection:
to purchase the property described therein be repealed."
Signature: Signature:
Print Name: v Win i fey fabricM- Print Name:
Date: \0~l 1° / 1Dt\ Date:
Address: 11 3 C&Je, Address:
Telephone: Telephone:
Email: j/to . fevb emo n/), Email:
Please return your signed petitions by email. m

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Upload a .pdf copy or a good quality photo of the complete petition to: Q m
info@sDaceportpetition.org
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WHEREAS, the Camden County Board of Commissioners have adopted resolutions

authorizing Camden County to enter into and extend the term of that certain Option Contract
by and between Camden County and Union Carbide Corporation (the "Union Carbide Option
purchase a substantial portion of 4,011.54 acres in Camden County, Georgia (the "Union
Carbide Property");
Court of Camden County to call a special election for the purpose of submitting the repeal of
the resolutions authorizing the Union Carbide Option Contract and its renewal or extension to
the registered electors of Camden County for approval or rejection in accordance with Article
IX, Section II, Paragraph 1(b)(2) of the Constitution of the State of Georgia;
NOW, THEREFORE, the undersigned elector hereby petitions the Probate Court of
Camden County to submit the following question concerning the repeal of the resolutions
authorizing the Union Carbide Option Contract to a special election of the registered electors of
Camden County, Georgia for approval or rejection:
"Shall the resolutions of the Board of Commissioners of Camden County,

Georgia authorizing the Option Contract with Union Carbide Corporation and
Camden County's right and option to purchase the property described therein
be repealed."

has executed this Petition as of the date written below.
Signature: CaJI a* e&

Print Name: Oxr) I Erk-
Date: Zip /4ao 2oj?
Address: 45 Dude
r
City: u)cru>c\
Zip: 3 i 6 b <7 Telephone: 7 /SI 7^ c( £?/olU
Email (optional) mrr. IP < r-/.s. nr.f-
Return This Petition with Your Original Signature To:

Petition - P.O. Box 867 - Kingsland, Georgia 31548 <->
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2021 DEC 21 amS: 11


Carbide Property");

be repealed."

Signature:
Print Name:
Date: /\ug, 2-0 11

Address: 45 cJood Duxic
City: u.)en>c\ b
Zip: •C? I 6? (? *7 Telephone: 9/«2 C?/d Q
70
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PETITION TO REPEAL RESOLUTIONS OF CAMDEN COUNTY
BOARD OF COMMISSIONERS

authorizing Camden County to enter into and extend the term of that certain Option Contract by
and between Camden County and Union Carbide Corporation (the "Union Carbide Option
purchase 4,011.54 acres in Camden County, Georgia (the "Union Carbide Property");
of Camden County to call a special election for the purpose of submitting the repeal of the

authorizing the Option Contract with Union Carbide Corporation and Camden County's right and
option to purchase the property described therein be repealed."

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Print Name:
C.O. f ( L Print Name: Sav^hi J~~. (=rk
Date: /O - //" Z O Date: /O V/ - SC O
Address: Lf<T~ Ducfc ft- Address: HS IaJooO Ductf D&.

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resolutions
authorizing Camden County to enter into and extend the term of that
certain Option Contract by
and between Camden County and Union Carbide Corporation (the
"Union Carbide Option
Contract"), whereby Union Carbide Corporation has granted Camden County
the right to
purchase 4,011.54 acres in Camden County, Georgia (the "Union Carbide
Property");
WHEREAS, the registered electors signing this petition desire to compel the
Probate Court
of Camden County to call a special election for the purpose of submittin
g the repeal of the
resolutions authorizing the Union Carbide Option Contract and its renewal
or extension to the
registered electors of Camden County for approval or rejection in accordanc
e with Article IX,

Probate Court of
Camden County to submit the following question concerning the
repeal of the resolutions
authorizing the Union Carbide Option Contract to a special election of
the registered electors of
"Shall the resolutions of the Board of Commissioners of Camden

County, Georgia
authorizing the Option Contract with Union Carbide Corporation and Camden
County's right and

County, Georgia
f
Print Name: (C.fl L/l< Print Name:
Date: </g u)pdJ Dur-k Date:
Address: Address:
3\SC&
Date: Date:
CNl
Address: Address:
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Telephone: Telephone: UJ
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Carbide Property");

be repealed."

Signature:
Print Name: AiL c^k r ItVlC L rv\ -V~>

Date:
Address: H £L.) lOr^ *

City: 1 /If* 7*y (j; ^
Zip: T( ec1 Telephone:
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Carbide Property");

be repealed."

Signature:
Print Name: AJV, ^f <jr \ iiAC°

Date:
Address:
City: V?/ } (s. ?

Zip: I Telephone: ST"
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o © Petition - P.O. Box 867 - Kingsland, Georgia 31548

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Signature:
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Print Name: f\s ( r -i r /. J & C c/ c?" ' c Ll h
Date: 1 <2- /-2-OÎ
Address: _I2 C. Lc *>-"( 10 r-

City:
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Petition - P.O. Box 867 - Kingsland, Georgia 31548
2021 DEC 21 am9: £6

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PETITION TO REPEAL RESOLUTIONS OF CAM '

DEN COUNTY BOARD OF COMMISSIONERS
i
WHEREAS, the Camden County Board of Com i
missioners have adopted resolutions autho
rizing Camden County to enter into and exten I
d the term of that certain Option Contract
tween Camden County and Union Carbide
by and be- j
Corporation (the "Union Carbide Option Cont
ract"), whereby i
Union Carbi de Corporation has granted Camden Coun
ty the right to purchase a substantial portio
4,011.54 acres in Camden County, Georgia n of l
(the "Union Carbide Property");
l
WHEREAS, the registered electors signing
this petition desire to compel the Probate Coutt I
of Camden County to call a special election 4
for the purpose of submitting the repeal of
the resolutions i
authorizing the Union Carbide Option Cont
ract and its renewal or extension to the regis
tered electors of i
Camden County for approval or rejection in acco
rdance with Article IX, Section II, Paragraph 1(b)(2
the Constitutio ) of
n of the State of Georgia;
I
NOW, THEREFORE, the undersigned elect I
or hereby petitions the Probate Court of
Camden |
County to submit the following question conc
ernin g the repeal of the resolutions authorizing the
Carbide Option Contract to a special election of Union I
the registered electors of Camden County, Geor
approval gia for I
or rejection:
"Shall the resolutions of the Board of Com I

missioners of Camden County, Georgia auth
the Option Contract with Union Carbide orizin g i
Corporation and Camden County's right
and option to I
purchase the prop erty described therein be repealed."
l
IN WITNESS WHEREOF, the undersigned i
registered elector in Camden County, Geor
executed this Petition as of the date writte gia has |
n below.
I
Signature^. I
i
Print Name:
'
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Date: m
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Address: /6 2- Qt/zctgr- 4^
City: ^ T- M/h&yS r-o
Zip:__3iZ5&
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Telephone: 6>'37&
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and between Camden County and Union Carbide Corporation (the ''Union Carbide Option


7
Signature: mW ^ ftMAL&4 Signature:
Print Name: A I?Xua] dri 1/0 CMG (' Print Name: /U/zV/yfe:t P <.
Date: zjshoji Date: 6/5/g^g I
Address: /Qo? /7)()C& /Y!t U- Address: \bZ Moc^/i
># WMf. 04 3/S5?
Telephone: -v/j -=*/£•</ Telephone: 7^ 2 - (&7B
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Signature: . (1 Signature: r-i-
Print Name: Ge0ft<fe ft ,-Zj^ UtJbacb Print Name:

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Date: <5j 1/ Date:
m j^d dress: JriZ Mr> Cfim* Address:

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WHEREAS, the Camden County Board of Commissioners have adopted resolutions authorizing Camden County to
enter into and extend the term of that certain Option Contract by and between Camden County and Union Carbide
Corporation (the "Union Carbide Option Contract"), whereby Union Carbide Corporation has granted Camden
County the right to purchase a substantial portion of 4,011.54 acres in Camden County, Georgia (the "Union
Carbide Property");
WHEREAS, the registered electors signing this petition desire to compel the Probate Court of Camden County to
call a special election for the purpose of submitting the repeal of the resolutions authorizing the Union Carbide
Option Contract and its renewal or extension to the registered electors of Camden County for approval or rejection
in accordance with Article IX, Section II, Paragraph 1(b)(2) of the Constitution of the State of Georgia;
NOW, THEREFORE, the undersigned elector hereby petitions the Probate Court of Camden County to submit the
following question concerning the repeal of the resolutions authorizing the Union Carbide Option Contract to a
special election of the registered electors of Camden County, Georgia for approval or rejection:
IN WITNESS WHEREOF, the undersigned registered elector in Camden County, Georgia has executed this Petition
as of the date written below.
Print Name:
flAlC-Ufrei. Print Name: A kxat/t/nA //() (Nit?
Date: Date: ll IJl/ 76)-/
Address: / 02 Moc-iAms <^y Address: IDA ft) MS/MO- Ch-
/hew. 6.A- 3 issd
Telephone: 137- £22 -&-37H Telephone: " cJ / 0
Email: Mil U&l/. QKitej ^ Email: t(orMs, 0 ^0 mSN-co/n
Signature: la. O Signature:
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Print Name: CsCnf-Jfr A £ L-tb Ifrcit Print Name: m
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Date: nf *-i /n Date:

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Address: fG 0- /W Q . Address:
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Telephone: 3'' - got-lS 0/ Telephone:
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I
PETITION TO REPEAL RESOLUTIONS OF CAMDEN COUNTY BOARD OF COMMISSIONERS i
i
I
rizing Camden County to enter into and extend the term of that certain Option Contract by and be- 1
tween Camden County and Union Carbide Corporation (the "Union Carbide Option Contract"), whereby i
Union Carbide Corporation has granted Camden County the right to purchase a substantial portion of I
4,011.54 acres in Camden County, Georgia (the "Union Carbide Property"); l
WHEREAS, the registered electors signing this petition desire to compel the Probate Court |
of Camden County to call a special election for the purpose of submitting the repeal of the resolutions i
Camden County for approval or rejection in accordance with Article IX, Section II, Paragraph 1 (b)(2) of
I NOW, THEREFORE, the undersigned elector hereby petitions the Probate Court of Camden i
I County to submit the following question concerning the repeal of the resolutions authorizing the Union I
Carbide Option Contract to a special election of the registered electors of Camden County, Georgia for •
Signature: / #7 ijy/loWV&. \ A. (M I
i
Print Name: /f I > (/ f\Of4/^-T ' r.
Date: iMa.
Address: J bJ A VCf FfOt/f (Lrdc
City: -Sf Ifl&lf/S o
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Zip: Z/SS%
Telephone: ~ct/OV
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PETITION TO REPEAL RESOLUTIONS OF CAMDEN COUNTY BOARD OF COMMISSIONERS I
WHEREAS, the Camden County Board of Commissioners have adopted resolutions autho- ,
rizing Camden County to enter into and extend the term of that certain Option Contract by and be- 1
tween Camden County and Union Carbide Corporation (the "Union Carbide Option Contract"), whereby i
Union Carbide Corporation has granted Camden County the right to purchase a substantial portion of I
c
WHEREAS, the registered electors signing this petition desire to compel the Probate Court |
3f Camden County to call a special election for the purpose of submitting the repeal of the resolutions i
authorizing the Union Carbide Option Contract and its renewal or extension to the registered electors of I
Gamden County for approval or rejection in accordance with Article IX, Section II, Paragraph 1(b)(2) of |
I
NOW, THEREFORE, the undersigned elector hereby petitions the Probate Court of Camden i
bounty to submit the following Cjuestion concerning the repeal of the resolutions authorizing the Union I
Uarbide Option Contract to a special election of the registered electors of Camden County, Georgia for J
I
"Shall the resolutions of the Board of Commissioners of Camden County, Georgia authorizing i
the Option Contract with Union Carbide Corporation and Camden County's right and option to I
IN WITNESS WHEREOF, the undersigned registered elector in Camden County, Georgia has |
executed this Petition as of the date written below. i
Signature:
Print Name: / Td/lrfu (A y ofy

Date:. 9f10/11
Address: IJAH't) 7 o
m
City: Haiys. CA C-.
Zip: fcTfr-
Telephone: frH 3 SHjO 2a
rn Email (optional)
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3f Camden County to call a special election for the purpose of submitting the repeal of the resolutions
3amden County for approval or rejection in accordance with Article IX, Section II, Paragraph 1(b)(2) of
bounty to submit the following question concerning the repeal of the resolutions authorizing the Union
3arbide Option Contract to a special election of the registered electors of Camden County, Georgia for
axecuted this Petition as of the date written below.
Signature:
Print Name:/ Uuo# Y

Date:
city:
?// 1!/q
Address: U* T # 32
HkW ,r
S&a LAvV UaH&uuIL 3 CD
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Zip: 7/^r ; ff*o
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Telephone: ^ 3 bL)Q 2 \ 5
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4,011.54 acres in Camden County, Georgia (the "Union Carbide Property");
3f Camden County to call a special election for the purpose of submitting the repeal of the resolutions
Camden County for approval or rejection in accordance with Article IX, Section II, Paragraph 1(b)(2) of
Carbide Option Contract to a special election of the registered electors of Camden County, Georgia for
Signature:
o
Print Name: f\ u fJ
Date: ZD
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Address: L cAr W32
City: tiu/s, ^ A 4^
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Zip:
Telephone: 3 2/b"2-
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01
1 1 PETITION TO REPEAL RESOLUTIONS OF CAMDEN COUNTY BOARD OF COMMI
PETITION TO REPEAL RESOLUTIONS OF CAMDEN COUNTY BOARD OF COMMISSIONE SSIONS
RS 1! 1
| WHEREAS, the Camden County Board of Commissioners have adopted resolutions aut
WHEREAS, the Camden County Board of Commissioners have adopted resolutio
ns autho- ( | rizing Camden County to enter into and extend the term of that certain
rizing Camden County to enter into and extend the term of that certain Option Option Contract by and
Contract by and be- 1 1 tween Camden County and Union Carbide Corporation
tween Camden County and Union Carbide Corporation (the "Union Carbide Option (the "Union Carbide Option Contract"), when
Contract"), whereby n Union Carbide Corporation has granted Camden County the
Union Carbide Corporation has granted Camden County the right to purchase a substant right to purchase a substantial portior
ial portion of 1 1 4,01 1 .54 acres in Camden County, Georgia (the "Union Carbide Property
4,01 1 .54 acres in Camden County, Georgia (the "Union Carbide Property"); ");
II
ll WHEREAS, the registered electors signing this
petition desire to compel the Probate Co
Court n of Camden County to call a special election for the purpose of submitting
of Camden County to call a special election for the purpose of submitting the repeal the repeal of the resolutic
of the resolutions n authorizing the Union Carbide Option Contract and its renewal
authorizing the Union Carbide Option Contract and its renewal or extension to the registere or extension to the registered electors
d electors of ll Camden County for approval or rejection in accordance with Article IX,
Camden County for approval or rejection in accordance with Article IX, Section II, Paragraph 1(b)(2) Section II, Paragraph 1 (b)(2)
of I1 the Constitution of the State of Georgia;
the Constitution of the State of Georgia; 11
H NOW, THEREFORE, the undersigned elector hereby petitions the Probate Court of Camd
Camden n County to submit the following question concerning the repeal of the resolutio
County to submit the following question concerning the repeal of the resolutions authorizi ns authorizing the Uni
ng the Union (I Carbide Option Contract to a special election of the registered electors
Carbide Option Contract to a special election of the registered electors of Camden County, Georgia for I1 approval of Camden County, Georgia :
or rejection:
approval or rejection: 11
ll "Shall the resolutions of the Board of Commissioners
of Camden County, Georgia authorizii
authorizing |l the Option Contract with Union Carbide Corporation and Camden
the Option Contract with Union Carbide Corporation and Camden County's right County's right and option
and option to l| purchase the property described therein be repealed."
purchase the property described therein be repealed." li
ll IN WITNESS WHEREOF, the undersigned registered elector in Camden
IN WITNESS WHEREOF, the undersigned registered elector in Camden County, County, Georgia h;
Georgia has n executed this Petition as of the date written bel#w.
ll
I Signature; _
Signature: _ ll —
Print Name:
Print Name: < I j, # J? J ;
Date: ^7- /-" Xd/tf
Date:
Address: Dennis Gagliardi

Address: //O /fye/Zr dnqfc <
City:
Zip:
1 93 Dellwood PL
Saint Marys, GA 31 558
City:
Zip:
/d/
3/S*/-<?- 0/62^
/4At d 'Sr/l )
Telephone: - 7 - 6
Telephone: I ^^ L 7 i ~ "7 7 0 7
Email (optional)
Email (optional) /6 d/Se^/ $ cs.
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"mm A 2021 DEC 21 ah 10: 00

Return Petition with Original Signature To: REC'D CAMDEN ELECTIONS
Repeal Petition - P.O. Box 867 - Kingsland, Georgia 31548
DEC 1 4 2021
UJ

Carbide Property");

be repealed."

Signature: A
Print Name:
Date: _£= -
Address: /hea.! d/ay
City: M/uy* /qm{ 1
Zip: Telephone: fe'-O
Email (optional) /p UfSts/IZR <2- fjs.
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be repealed."

Signature: C,
Print Name: Lou/j-e^ C

Date:
Address: //a /??£&! ~1)/pav*>S

City: M/Ktj* A-mI t
Zip: J/ry/ Telephone: fe'-O 7^1- 0^!^^
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Print Name1: Print Name:
Date: /«£- C>/ - o2 Date:
Address: /I) cl/ I Address:
3/5^p
Telephone: 0*/ Telephone:
Email: /#o/Se- J-Js. Email:
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Date: Date:
Address: Address:
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Carbide Property");

be repealed."

Signature:
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Print Name: ! / 7T Z- . Q> 4^
Date: /o r-o
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Address:
City:
70
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Date: / ~. O Date:
Address: Sn'n Address:
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Date: Date:
Address: i if rxhvcndt- Ct Address: )| CcA/lUO iMLs/' CV

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Signature: {ijlu'/rdhuy
Print Name: Cai\ I cm l/iA-j'n/de
Date:
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Address: Schooner (U
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resolutions
authorizing Camden County to enter into and extend the term of that
certain Option Contract by
and between Camden County and Union Carbide Corporation (the
"Union Carbide Option
Contract"), whereby Union Carbide Corporation has granted Camden
County the right to
purchase 4,011.54 acres in Camden County, Georgia (the "Union Carbide
Property");
WHEREAS, the registered electors signing this petition desire to compel

the Probate Court
of Camden County to call a special election for the purpose of submittin
g the repeal of the
resolutions authorizing the Union Carbide Option Contract and its renewal
or extension to the
registered electors of Camden County for approval or rejection in accordan
ce with Article IX,

Probate Court of
Camden County to submit the following question concerning the repeal
of the resolutions
authorizing the Union Carbide Option Contract to a special election of
the registered electors of

Georgia
authorizing the Option Contract with Union Carbide Corporation and Camden
County's right and

County, Georgia
Signature: ' -7W Ua.

J. Signature:
Print Name: AUKC Print Name:

3
Date: Date:
Address: Address:
> f t/n& i- i. /OA ?!& st ga 3/^r

Telephone: V2 - aa/7 Telephone:

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WHEREAS, the Camden County Board of Commissioners have adopted resolutions authorizin
g
Camden County to enter into and extend the term of that certain Option Contract by and
between Camden County and Union Carbide Corporation (the "Union Carbide Option
Contract"), whereby Union Carbide Corporation has granted Camden County the rig ht to
purchase a substantial portion of 4,011.54 acres in Camden County, Georgia (the "U nion
Carbide Property");
WHEREAS, the registered electors signing this petition desjre to compel
the Probate Court of
Camden County
resolutions autnorizin g the Union Carbide Option Contract and its renewal or extension
to the
registered electors of Camden County for approval or rejection in accordance with
Article IX,
County to submit the following question concerning the repeal of the resolutions authorizin
g
the Union Carbide Option Contract to a special election of the registered electors of Camden
County, Georgia for approval or rejection:
authorizing
the Option Contract with Union Carbide Corporation and Camden County's right
and option
IN WITNESS WHEREOF, the undersigned registered elector in Camden County,
Georgia has
Print Name: Print Name: VAR-6f^l7if> K.

Date: Date:
Address: / pAJ^>rh&s\ Address: f C>AJr%yVMsf\
S r /1AR.V5 ; C.A 3c?5g

Telephone:
Telephone: HOH-
Email: lyiarc^ (Z> t k co^\ Email: le-xle. a-a^@> bg ( I'Sou^k,
C-^J
please return your signed petitions by email.

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Carbide Property");
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Signature: /£• / Signature^! ZL
Print Name: Mafia VA(ze>fioU&t\ Print Name: A Id. UlrtA, Va J,

Date: / Date: I
Address: /aY D#-r$Wyr\ Y/,/4 Address: /^ 7 O Y/ ^
3j 7 t^rys / I 37 GA 3t&#
Telephone: i/3. - -£<2/7 Telephone: 4!
Date: Date:
^ Address: Address:
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IN THE PROBATE COURT OF CAMDEN COUNTY

IN RE: PETITION PURSUANT TO GEORGIA )

CAVEATOR’S BRIEF REGARDING THE

This ___ January

This ___ January

Print Name: Print Name:

Address: 4 ^S>*7 lAJfl Address:4 ^>-5 7 &>

Email (optional) Email (optional)

2Q21 DEC 21 am9:20

PETITION TO REPEAL RESOLUTIONS OF CAMDEN COUNTY BOARD OF COMMISSIONERS

"Shall the resolutions of the Board of Commissioners of Camden County, Georgia

Signature: * 'Vt{ HajJ

PETITION TO REPEAL RESOLUTIONS OF CAMDEN COUNTY BOARD OF

NOW, THEREFORE, the undersigned elector hereby petitions the

"Shall the resolutions of the Board of Commissioners of Camden

IN WITNESS WHEREOF, the undersigned registered elector in Camden

Signature: _ KL<\ ^Zt)^ i ^

PETITION TO REPEAL RESOLUTIONS OF CAMDEN COUNTY BOARD OF COMMISSIONERS

Print Name: L>e6fLA aJa £o

Print Name: v Win i fey fabricM- Print Name:

Date: \0~l 1° / 1Dt\ Date:

Address: 11 3 C&Je, Address:

Email: j/to . fevb emo n/), Email:

Please return your signed petitions by email. m

WHEREAS, the Camden County Board of Commissioners have adopted resolutions

"Shall the resolutions of the Board of Commissioners of Camden County,

IN WITNESS WHEREOF, the undersigned registered elector in Camden County, Georgia

Signature: CaJI a* e&

Return This Petition with Your Original Signature To:

2021 DEC 21 amS: 11

WHEREAS, the Camden County Board of Commissioners have adopted resolutions

"Shall the resolutions of the Board of Commissioners of Camden County,

IN WITNESS WHEREOF, the undersigned registered elector in Camden County, Georgia

Date: /\ug, 2-0 11

O M Return This Petition with Your Original Signature To:

WHEREAS, the Camden County Board of Commissioners have adopted resolutions

"Shall the resolutions of the Board of Commissioners of Camden County, Georgia

IN WITNESS WHEREOF, the undersigned registered elector in Camden County, Georgia

Address: Lf<T~ Ducfc ft- Address: HS IaJooO Ductf D&.

Print Name: Print Name:

WHEREAS, the Camden County Board of Commissioners have adopted

NOW, THEREFORE, the undersigned elector hereby petitions the

"Shall the resolutions of the Board of Commissioners of Camden

IN WITNESS WHEREOF, the undersigned registered elector in Camden

Print Name: (C.fl L/l< Print Name:

Date: </g u)pdJ Dur-k Date:

Print Name: Print Name:

2021 DEC 21 am9: 10

WHEREAS, the Camden County Board of Commissioners have adopted resolutions

"Shall the resolutions of the Board of Commissioners of Camden County,

IN WITNESS WHEREOF, the undersigned registered elector in Camden County, Georgia

Print Name: AiL c^k r ItVlC L rv\ -V~>

Address: H £L.) lOr^ *

WHEREAS, the Camden County Board of Commissioners have adopted resolutions

"Shall the resolutions of the Board of Commissioners of Camden County,

IN WITNESS WHEREOF, the undersigned registered elector in Camden County, Georgia

Print Name: AJV, ^f <jr \ iiAC°

City: V?/ } (s. ?

o © Petition - P.O. Box 867 - Kingsland, Georgia 31548

WHEREAS, the Camden County Board of Commissioners have adopted resolutions

"Shall the resolutions of the Board of Commissioners of Camden County,

IN WITNESS WHEREOF, the undersigned registered elector in Camden County, Georgia

Address: _I2 C. Lc *>-"( 10 r-