STATE OF NEW MEXICO

COUNTY OF BERNALILLO
SECOND JUDICIAL DISTRICT COURT

STELLA PADILLA,

Plaintiff,

v. Case No. D 202 CV 2017-03556

NATALIE HOWARD,
In her capacity as City Clerk,

Defendant.

AFFIDAVIT IN SUPPORT OF MOTION FOR PROTECTIVE ORDER

STATE OF NEW MEXICO )

)ss.
COUNT OF BERNALILLO )

I, Natalie Y. Howard, being first duly sworn, in my capacity as the City Clerk for the City

of Albuquerque, state under oath that I am over the age of 18 and state the following:

1. I am the duly appointed City Clerk of Albuquerque, and the Defendant in the

above entitled action.

2. I make this affidavit in support of a motion for a protective order prohibiting

harassment or intimidation against me as a party and a witness by any volunteer or other persons

associated with Plaintiffs campaign organization.

3. The Plaintiff, Stella Padilla, has announced her intention to be a candidate for

mayor in the 2017 city election and filed a petition which I as the City Clerk have determined to

be invalid for lack of the required number of valid signatures of registered city voters.
 4. Upon information and belief, Vanessa Padilla is the daughter of Stella Padilla. I

know Vanessa Padilla through her interactions with me in the course of my duties as City Clerk

in the administration of the 2017 city elections and in this case.

5. Vanessa Padilla (hereinafter sometimes Padilla) has engaged in conduct which I

perceive to be meant to harass and intimidate me, a description of which follows.

6. On May 19, 2017, Padilla came to the City Clerks Office on the 7th floor of the

Plaza del Sol building located at 600 2nd Street NW for the purpose of serving me as City Clerk

with the Complaint in this case.

7. The City Clerks Office has a public waiting/reception area as well as secured

areas where only employees have access through secured doors.

8. I came out into the public reception area to be served with the Complaint. Padilla

asked me if I was Natalie Y. Howard, which I acknowledged. Padilla then served me with a

copy of the complaint.

9. Padilla then began to insist that I sign the affidavit of service. I declined to do so

since that is the responsibility of the person serving, but advised her that I would call the

Assistant City Attorney for clarification. As I began to walk through the door into the non-

public secured area of the City Clerks office to call the Assistant City Attorney, Padilla yelled at

me telling me that I could not go back there until I signed affidavit of service.

10. I continued to the secured area, and, as the door was closing, Padilla pushed the

door open and entered into the non-public area of the Clerks office. She followed me into the

secured area, stood approximately 12 inches away from me and continued to insist that I sign the

affidavit.
 11. I then directed staff to contact security, at which time Padilla left the secured area

into the public reception area.

12. Padilla remained in the public area outside of the glass partition insisting that she

needed my signature so that she would not have to pay for parking even though there is no fee

charged for parking at Plaza del Sol.

13. Approximately 5 minutes later, I left my office to go to a meeting outside of the

building. I was with a member of my staff and escorted by a security officer. Padilla was not in

the waiting area.

14. We went to the elevators in the hallway and pressed the call button for an elevator

to come to the 7th floor to descend. When the elevator that was called reached the 7th floor and

the door opened, Vanessa Padilla was alone in that elevator.

15. I entered the elevator together with the member of my staff and the security

officer, and rode directly down to the basement floor. Padilla remained on the elevator as it

descended and exited on the ground floor, which is the first floor above the basement floor, while

staring at me.

16. Subsequently, on June 5, 2017 as I was outside of the Bernalillo County

Courthouse walking on my way into the courthouse to attend a hearing on this case, Padilla made

a point of approaching me just as I finished walking up the steps of the courthouse. Padilla was

carrying a Stella for Mayor sign and positioned herself approximately six inches away from

me while yelling at me about the case. She proceeded to walk backward directly in front of me,

with the Stella for Mayor sign in front of my face, blocking my path. I felt that Padilla was

attempting to intimidate me. I then told Padilla to stop the harassment, to which she replied:

You dont know what harassment is.

 17. Padilla has on two occasions engaged in aggressive behavior toward me during

the course of this lawsuit. In the second instance, Padilla deliberately came very close to me

physically in an attempt to harass and intimidate me, also telling me on that date that: You dont

know what harassment is.

18. This pattern of conduct on Padillas part is hostile and serves no legitimate

purpose, and is being done for the purpose of harassing and intimidating me. Based on this

pattern of conduct, I have become reasonably concerned for my physical safety from Vanessa

Padilla.

_____________________________
Natalie Y. Howard
City Clerk for the City of Albuquerque
Office of the City Clerk
Plaza del Sol, Building
600 2nd Street NW, 7th Floor
Albuquerque, NM 87102

SUBSCRIBED AND SWORN this ___ day of June, 2017, by Natalie Y. Howard, City
Clerk for the City of Albuquerque.

__________________________________
NOTARY PUBLIC

My Commission Expires: