i~ Revised July 2012 ~~

RESPONDENT'S NAME (if known; otherwise write "unknown U)

First Name

AFFIDAVIT OF COMPLAINT (l~;1~1-;"~Z$

ST A TE ELECTIONS ENFORCEMENT COMMISSION ~i:~,!~f~;)

Page

2 of6

II. IDENTITY OF RESPONDENT(S)

ied
11~ B ("0 a. rl
Gv. \ \ to (' d

MI

Last Name

Suffx

2 LL-;e

RESPONDENT'S STREET ADDRESS (Ifknown)

Address

~t-.
State

City

RESPONDENT'S TELEPHONE NUMBER (Ifknown)

Home

tr

Zip Code

Orili 3'1

a03" t15~. ' 3 IGl

r Work

I Cen

:20"3 - '1~- ~~SO

STATUTE(S) VIOLATED (lfknown)

RESPONDENT'S EMAIL ADDRESS (Ifknown)

q..3Gtic. i
RESPONDENT'S NAME (lfknown, otherwise write "unknown U)
First Name
MI

~- i.ho
Suffx

Last Name

RESPONDENT'S STREET ADDRESS (Ifknown)

Address

City

State

Zip Code

RESPONDENT'S TELEPHONE NUMBER (Ifknown)

Home
1 Work

,cen
STATUTE(S) VIOLATED (ifknown)

RESPONDENT'S EMAIL ADDRESS (ifknown)

RESPONDENT'S NAME (frknown, otherwise write "unknown 'J

First Name

MI

Last Name

Sufix

RESPONDENT'S STREET ADDRESS (ifknown)

Address

City

State

Zip Code

RESPONDENT'S TELEPHONE NUMBER (lfknown)

Home
I Work

I Cell

RESPONDENT'S EMAI ADDRESS (Ifknown)

STATUTE(S) VIOLATED (Ifknown)

Copy and attach pagers) for additional respondents if necessary.

Please check "See attached Additional Respondent List" and list the number of pages.

D See attached
Nmnbe of Page,

Additional Respondent List pages

AFFIDAVIT OF COMPLAINT ~,:s;r~;'~\

~"

Page 3 of6

~\'" "-../ -,'2 Revised July 2012 ~~~~;,i~"'~

STATE ELECTIONS ENFORCEMENT COMMISSION l~t"Uf~'d:

III. VIOLATION(S) ALLEGED

DATE(S) OF ALLEGEDVIOLATION(S) (ifknown)

CONCISE STATEMENT OF FACTS

Please be as specific as possible with regard to time, place, and the individual(s) takng actions or failing to act, and in describing their actions as well as other witnesses or persons involved. If applicable, please clearly refer to the names of identified respondents, witnesses, and attached evidence (e.g., See Evidentiary Attachment B.). If you have identified more than one respondent, please identify which respondent is alleged to have commtted which action and which specific alleged violation of the statutes.
If you are unable to provide the specific identity of any witnesses in the following "Witnesses" section, please provide as
much identifying information as possible in the below "Concise Statement of Facts."

The respondent(s) allegedly violated the law as follows:

'5 et.

Use attached pagers) for additional statement of facts if necessary. Please check "See attached Additional Statement of Facts" and list the number of pages.
see attached -- Additional Statement of Number orPagcs

Facts pages

Louise G Graver
124 Tuttles Point Road Guilford, CT 06437 (203) 453-4773 (203) 453-9876 (fax)
ha n klou ise(comcast. net

CONCISE STATEMENT OF FACTS

Complainant is the Democratic Registrar of Voters in Guilford, CT. The respondent, Ted Zuse, appeared in my offce late in the afternoon on Monday,

August 4, 2013 with thirteen pages of primary petitioning papers containing 253
signatures in support of his effort to become the Democratic candidate for First Selectman. The packet also contained one 'Circulator's Statement of Authenticity of Signatures' signed by Mr. Zuse and certified by the Town Clerk.

While the respondent was still in her offce, the complainant did a quick manual scan of the petitioning papers to make sure, on a macro level, that everyhing
was in order. While doing so, the complainant noticed her husband's 'signature' (which she did not recognize) and also an inaccurate date-of-birth. Complainant asked respondent if he had witnessed, as he had attested to in the Circulator's

Statement of Authenticity of Signatures, my husband's signing the paper.

Respondent replied that he had probably been in the car while his helper collected the signature. Complainant replied the she suspected an irregularity and respondent replied that he would look into the situation and get back to me in the morning and left the offce.

Upon further inspection of the petitioning papers the complainant noticed six
other signatures, immediately before her husband's, for people living in the same neighborhood as she and her husband. Complainant called five of those people, all of whom stated that they had definitely not signed the petition.

When the respondent came into the Offce of the Registrar of Voters the following morning, August 5, he stated that he was withdrawing his attempt to petition and signed a statement, drafted by the complainant, to that effect.

AFFIDAVIT OF COMPLAINT ~~'J~

STATE ELECTIONS ENFORCEMENT COMMISSION
Revised July 2012

Page 4 of 6

(j i ~"'I ~ 'C~\~~ ;S~:L ~';~"~-)~t ~,;.,,~:,,-~.::-s ll;j:;':;:~'""",x

IV. WITNESSES
WITNESS'S NAME (ifknown)
First Name
MI
Lat Name

Sufx

WITNSS'S STREET ADDRESS (Ifknown)

Address

City

State

Zip Code

WITNESS'S TELEPHONE NUMBER (ifknown)

Home
I Work

I Cell

WITNSS'S EMAI ADDRESS (Ifknown)

WITNESS'S NAME (Ifknown)

First Name
MI
Last Name

Suffx

WIESS'S STREET ADDRESS (Ifknown)

Address

City I

WITNESS'S TELEPHONE NUMBER (Ifknown)

Home
I Work

IEJ
I Cell

rp Code

WITNESS'S EMAIL ADDRESS (Ifknown)

WINESS'S NAME (ifknown)

First Name
MI

Last Name

Suffx

WITNESS'S STREET ADDRESS (Ifknown)

Address

City

State

Zip Code

WITNSS'S TELEPHONE NUMBER (ifknown)

Home
Work
I Cell

WITNESS'S EMAIL ADDRESS (Ifknown)

Copy and attach page(s) for additional witnesses if necessary.

Please check "See attached Additional Witness List" and list the number of pages.

D See attached
NumbL"r fJfPages

Additional Witness List pages

AFFIDAVIT OF COMPLAINT l/fdf~,

Page 5 of 6

Revised July 2012 ~~;~;~i~;;~;~

lr(N''-o~

STATE ELECTIONS ENFORCEMENT COMMISSION I~Y11-!':\- JJ:

V. EVIDENCE
ATTACHED DOCUMENTARY OR RE EVIENCE

Please identify each attachment by number of pages, title, author and date if applicable. Records not identified as attachments shall not be considered a par of the complaint. Please do not provide a website listing as evidence, as this information is subject to change. If you wish to provide Internet or other video or audio communications as evidence, please provide a printed or electronic copy, as appropriate, and list it as an exhibit.
public flyer location). Ifthe source is an individual, please identify the individual in the witness list. If

Under "How Acquired" please identify your source for the evidence (e.g., delivery from an individual, Internet website, the source is a publication, such as a newspaper, please identify the publication's name and date ofthe publication.

EVIENTIAY ATTACHMENT
Title
Number of

Pages

Author

c,
Date of Pub lie at ion

50T
How AequireJ

Vi
EVIDENTIARY ATTACHMENT

lg ~ 1.:
Number of

Pages

Author Date of

How Aequired Date Aequired

7cO -5

Publication

t'
EVIENTIARY ATTACHMENT
Title

~l

,~
Number of

Pages

Author

Date ofPubJiealIon

How Aequired

Date Aequired

EVIENTIAY ATTACHMENT
Title
Number of

Pages

Author

Date of Publication

How Aequired

Date Aequired

Copy and attach page(s) for additonal evidence if necessary.

Please check "See attached Additional Evidence List" and list the number of

pages.

o See attached
Number of Pages

Additional Evidence List pages

AFFIDAVIT OF COMPLAINT l:~f~'r~~~~

Page 6 of 6

Revised July 201 2 "\~::~;;~W

-"Glvif

STATE ELECTIONS ENFORCEMENT COMMISSION ~(~tL~-H~

VI. CERTIFICATION
1) Each Complainant must sign a separate page and each signature must be separately certified. This
complaint will not be considered fied without the name, address, and original certified signatue of

at least one Complainant. Mail or hand-deliver this complaint to:

State Elections Enforcement Commission
20 Trinity Street, Suite 101

Harford, CT 06106
2) Once filed, this complaint may not be withdrawn by the Complainant(s) except by a vote of

the State

Elections Enforcement Commission.

3) I am aware that criminal penalties may be imposed upon any Complainant who, under penalty of

false statement, knowingly files a false complaint.

4) The State Elections Enforcement Commission's investigation of a complaint is confidential unless and until the State Elections Enforcement Commission votes to authorize an investigation of a complaint. Until such a vote, neither the Commission nor its staff wil release or confirm any information about the complaint except upon wrtten request of a treasurer, deputy treasurer, chairperson or candidate affiliated with a committee that is the subject of the complaint or
preliminary investigation.
Guides to the elections laws are available at http://wWW.ct.2ov/seec

Connecticut General Statutes are available at http://www.c2a.ct.2ov

CERTIFICATION

i solemnly swear (or affrm) that the above statement is true and accurate
to the best of my knowledge and belief.

LllLL/le. Gmvt.
COMPLAINANT'S SIGNATURE

~
day of

l)~J,,~ J fll1 13

Sworn and subscribed before me on this

,20

Seal

SIGNATURE OF PERSON ADMINISTERIG THE OATH

NAME OF PERSON ADMINISTERING THE OATH (PleasePrinl)

TITLE OF PERSON ADMINISTERING THE OATH

Note: This oath may be administered by anyone authorized by Section 1-24 of the Connecticut General Statutes, which includes: notares public; justices of the peace; town clerks and assistant town clerks; judges and clerks of any cour; and attorneys who are Commissioners of the Superior Court of Connecticut.

(ED-6 i 9) Rev. 5/03(Circulator: Read separate Instruction Sheet before circulating) (3)

PRIMARY PETITION FOR MUNICIPAL OFFICE(S) AT-LARGE

W ARNNG: IT IS A CRIME TO SIGN THIS PETITION IN THE NAME OF ANOTHER PERSON WITHOUT LEGAL AUTHORITY TO DO SO AND YOU MAY NOT SIGN THIS PETITION IF YOU ARE NOT AN ELECTOR
A. REGISTRAR MUST FILL OUT THIS PART (A) BEFORE GIVING OUT THIS FORM
City

Town of
Borough

Gu .i ~'" d
(Part)

(Name of Municipality)

l p/WU r.al "I

September 10,2013
(Date of

Primary)

NAME(S) OF CANDIDA TE(S) ADDRESS

OFFICE(S) SOUGHT TERM

h"",-t 5t.tct~n 11,14 ~
t:2 , '1

d Z ~~~m'ihflki'~ ;"&-Cld- S-r

THIS PETITION MUST BE FILED WITH ~lA/' Se. G~t-lr

lee )

, ~_..

'3, V"- t l1t , ot later than 4:00 p.m. on August 7. 2013.

(Address of said Registrar)

~ \. S G ti.J (Nam, of Registmr of V o

B. We, the undersigned, being enrolled members of the above party in the above municipality, do

hereby petition that there be printed on the voting machine ballot labels to be used in the primary of said party in said municipality to be held on the date above specified the names of the above
individuals as candidates for nomination to the offces s ecified:

~ ltc.-i.~ l'o-~lm ,:ckl- t-dt

SIGNATURE OF ENROLLED PRINTED NAME OF BIRTH

ELECTO ELECTOR DATE

Dd

//A 14 --/%,'-4. xt.:

15

(./Yi;l;:~rfAr- '-

16 17
18

V =: V ~r, ~.e.d ~~ ~M drd Vlt5t9(L

pt2h haT'

19

20

(ED-619 - Rev. 5/03, Prim. PetT. Mun. Off. At-Lge.) -- (G\fonns\ed-600's\ed-619.doc)

(4)

STATEMENT BY REGISTRA OF VOTERS AS TO CIRCULATOR'S STATUS AS ENROLLED PARTY MEMBER

C. Circulator must have Part C filled in by part's Registrar in town in which circulator is enrolled before

submitting it to part's Registrar in town in which the signers are enrolled.

CIRCULATOR'S NAME
CIRCULA TOR'S RESIDENCE ADDRESS (no., street, town)

I, Registrar of V oters of the part named in Part A of this petition, in the town of CT do hereby attest that the above circulator is an enrolled member of said part in said town.

Date

Signature of Registrar of Voters

CIRCULATOR'S STATEMENT OF AUTHENTICITY OF SIGNATURS

D. Part D must be completed, by Circulator and by Acknowledging Officer, after obtaining all signatures on this page 2nd before filing it with part's Registrar in municipality in which the signers of the page are enrolled.
I am the Circulator of

this petition page and I make this statement pursuant to e pr~vi ions olhaPter 153 of the General Stitesp Connecticut. My address is .s ). C! '- , in the
town of C-i '- ,./ - t- . t T. i am an enrolled member of the political part designated on this petition

in said town. Each person whose name appears on this petition signatures page signed the same in person in my presence. I either know each such signer or such signer satisfactorily identified himself or herself to me. The spaces for candidates supported, offces sought and the political part involved were filled in prior to my obtaining the signatures. The number of signatures on this petition signatures page is ,. 3~ 3.

I hereby declare under the PENALTIES OF FALSE STATEMENT, that the statements made II the
foregoing Circulator's Statement of Authenticity of Signatures are tre.

CERTIFICATION OF ACKNOWLEDGING OFFICER

State of Connecticut 1

1 ss:
County of NE!V \-~ve

Gv~\~
(city or town)

-L On this the b day of AVi

appeared --~ ZL .si:
(N ame of Circulator)

, 20 ) ~ before me, the undersigned officer, personally , known to me (or satisfactorily proven) to be the person whose

name is subscribed to the foregoing Statement of Circulator and acknowledged that he executed the same for the purpose contained therein.
In witness whereof, I have hereunto set my hand.
family ppon

My commission expires: (Date)

(Notary Public only)

magistrate; clerk or deputy rk of a court having a seal; commissioner of deeds or ~

clerk; notary public; justice of the peace;
or attorney admitted to the Connecticut Bar

* * * ** * * * * ** * * * * * * * ** * ** * * *** * * ** * * * ** * * * ** * * ** * * * * * * * ** * * * ** * * * ** *** * * ** * ** * ** * * ** ** * **

CERTIFICATION BY REGISTRAR OF VOTERS OF NUBER OF SIGNERS WHO ARE ON ENROLLMENT LIST

E. The following is to be filled in by the Registrar of Voters in the town in which the signers of

signatures page are enrolled, before Registrar files with the Clerk of such municipality:
I, Registrar of

this petition

Voters of the part named in Part A of this petition in the municipality also named in Part A, hereby certify that the number of signers on this primary petition page who are enrolled members of such

part in the municipality named in Part A is

(Niuber)
Dated at
, Connecticut, this
day of

,20_.

Signature of Registrar of Voters

r ~~ ~,~ ~ ~ ~~J' r::~,'.iJ~ ;,_ ~l it,'! it\:~~.::." ,~1 j il, \i",; r~~~1 '!' '~

.. '~f,

t~':' ~~~, j" :~'t ~,; , ','il-. n i.: . I~ ':~11" .

~.': 't1f~~~~.. ..'.. .. :";!'

1111,1"",; I i .11,1 ~111' P 1,11,11 i11 i 11'1111,1.11,1/11/1/

;l~ r.!1J

, f~il.~tte:si~~~tj.. ."

t~, ~;G:ij!.frdM.c;r~9fM370~;t
~:i t~ ~'~ t,' ..~

I':t~l' ~ -""
i'" '\
/,~ .;:::

~, jt' $2~07Q " .. _::,,!,it:':,.... i~~ i,i ~..,-USPQ.~TAr.i:.-, ~..."".-:..~, ""':;..:~~""~d~'E" .~~SS .::-".

"

iE b. .:~"' ..:'

~!t'~", :;'il'

K ~f'l ir; ~, . ~~~;~"~;r;~~.,,... -~'. ~~:: ...~I~;1tl;!.., _ L'~~. ?'~"~ '~~'t:':: ~.-" , ~.., ..-... v

, ,~,' ~..____ !~;~,~~.i,"r,_,::n_:,i.,)~. :..'"-. ~ -

~ ~it';" 'j
~~. r, i:i1

,,,, ;,,~~.. ~ ~.~' ....... .'...'~ .,.~..'.. :.~ ~. "''I' :."' ..~=.~.....~." . ..J,;FltS9QJ~.." ~,' ~ ,_.L~~~_~,-,:'~t.0647.:. .

!l
~~~ ni

..

..~

;J ,r.

".;::~E:~~:.:;:,~~~~~
. .,"~.,~d:,.t,~'"....."l":i ~~~ ~-~._--.."'~~".~,

;;
-r;

~
i! 'f, ..

/~' i: ''T~ " i.,

STATE!ELECTIONS.
;1.. ~.UG l2'''Z013
;t;~ ~ :"1iI;'" ".

RECEIVEDi

..~..,.~~~-- '" --- ,--~,."-'~'-t"

~-ii~.._~~_~-: ...;"1:t-:~-;= -?.-.~r~.,L;, /::,-~::::~;--~.;~;'~

'. ~,1 ,~ ,~

". ',..~' ",~::~:~:. ...~.'~..~~.,.~~..~,.'.~.~~i

ii r~ ~ \il *' -,I ili ~.."'. ... ::'~ ~.'.l ',:~i .~~ ~~ 1"l_ 'J"h~' II
i"i"" i~~'., ~ Wi' '\1C~\f ~ ii ., ~ ~~~i ,l!,;;' ".." _. a

:I:niii
,f ..'

e, ~ -; :ENFORCEMNT COMMISSI.OW

"'~. Yl ,'. . ,.
~
\~i ';" ,'4"r~ "~ i~'

",j1l=, /:", . ':~' . . .,' .,:t,~ ;'): ,I' II '~.;: ":, il' d~' reJe:~T~' Of\i 'i~;,' ~~"'(U~i.~.': iS, ' ,..I,, ~ i.i..._,,' Ifl.:',""l!.-ei, ,,'.,,,.,. .,.,"". il, r: .. , .;~ j,ft~;i" l'i-. H
Il Cl'il' ,,\ ~~ ","., I .... ,...' ~.i . . ,tl,

"~. ~
'"
':')1 rP 'JO. ~:

!\ "., . .~~ ., .; "~,l-' +~ ..~\i"i k'~;", i' ~O. 'l'Y, '", ~ ; ".. "ll '1

~"A ~r I..". il "'!f" ...~''' '.,;\~'. ~ IcX,,~TI~'." 'I," .'-". . ""if .."

:i:,"~ ;l.; :i~ ~i ~'I

'"

'"

~~. ~

jt
p

"
:.I ,;i ~i
~,

W~

''i 'I -f :i il ~ '~h' ~"~~':i:-_~""~~'".:~\ dl'~~7"l~ ",~,/".,M:;bl,I',,;: j ""~ ~. ~t) ~pSJf ~ti ;\,l;I'~ .l. li; "~:11 ~ ~.~" ~t' ;IJ~' .~

~ ~

:;~ ~t111'~ ~ ~~., ~:b. 1l.i lj :! j!:i. ~ "ti rh , M "l ~l'a ti'iG~ ii:i! ~.;, .:~ ; ,l; lf~ li! ii, lrt
~ IJ,~,~ ""~:!' ',.'.,II.!... It,'ti, :r)I;j l! :(~: IiI ""..j~: r "i.r

'~1 ~\i'"; "''.1 .J .... ~~~"~!~ .~...~Ji:,

~ :i . M ~,~. ~~ :i;,.,. I~ l':~ ~'..l';: '~(' " 'it . l! i5

~.~1dri..~it:,~(; I'r~~'\c%t''lh :: "',,, . ~,. .,,~' e"'I, "",.,.. ~J """"" ,~c,:;i~.~~'

~li

~:l~\" ...~ 1'"i

"' ,.lf:" &, ,. '11 :'~'h ~!~j1

~~ ~ ~ ~ l
~!i:ii' ~f'~.! '~l~~~
.~a ;iJf;'

~
",1

ll

r, 1,1"~t~ II

I't;
fA

ri: '~t.i ~ ':' ifii1i: ::;i '~;l t..,~.

i~~.',..i, 1t ~L~.,,' ":' !!; ~ iil ~:I .,~ 1l~.

rn

.l

't\" :!~

'v it~i'm 'ii

: .II"

~
:~,

"

1:~ ~:

11'"

.,' .t'

~t': /f

i;:1

~:i.
,~

:~i'. j) ~~; " .,

~""l r~ ~ ,~- 'Wt

ilij,' ,.; ';i'