Meroni V ISBE - Meroni Responds To Reese 10-09-20

IN THE CIRCUIT COURT FOR THE SEVENTH JUDICIAL CIRCUIT OF ILLINOIS SANGAMON
COUNTY, SPRINGFIELD ILLINOIS
IN THE MATTER OF: )

SHARON Al\TN MERONI - )
)
OBJECTOR AND PETmONER )
)
VS. )
) 2010 MR501
ILLINOIS STATE BOARD OF ELECTIONS )
SITTING AS THE DULY CONSTITUTED )
STATE OFFICERS ELECTORAL BOARD )
BRYAN A. SCHEIDER )
"VANDAL. REDNOUR )
ALBERT S. PORTER )
JOHN R. KEITH )
~LL~lF.MCGRUFFAGE )
JESSE R. SMART )
PATRICK A. BRADY )
ROBERTJ WALTERS )
)
CANDIDATES )
CONSTITUTION PARTY }
JEFF TREXLER ) 10 SOEB GE 524-
MICHAEL L. "VHITE ) 10 SOEB GE 532
GARY DUNLAP } 10 SOEB GE 533
LOUIS COTTON ) 10 SOEB GE 534
TIMOTHY BECKER ) 10 SOEB GE 535
DAWN CZARNY } 10 SOEB GE 541
)
LIBETERIAN PAHTY }
BILL MALAN } 10 SOEB GE 526
JAMES PAULY ) 10 SOEB GE 527
JOSH HANSON } 10 SOEB GE 528
JUILEFOX ) 10 SOEB GE 529
MIKELABNO ) 10 SOEB GE 530
ED RUTLEDGE } 10 SOEB GE 543
LE.,XGREE J ) 10 SOEB GE 544
)
GREGG MOORE } 10 SOEB GE 525
CAHLE.OFFICEH ) 10 SOEB GE 537
WILLIE BOYD,jR. ) 10 SOEB GE 553
COREY DABNEY } 10 SOEB GE 539
EDWARD]. SCANLON ) 10 SOEB GE 540
CHRISTOPHER PEDERSEN ) 10 SOEB GE 542, 545, 546, 547,548,551, 552
}
RESPONSE TO DEFENSE AND OPPOSING THE ADMINISTRATIVE DECISIONS
llPage
All men are by nature free and independent and have certain inherent and inalienable rights among them are life, liberty and the pursuit of
happiness. To secure these rights and the protection of property, governments are instituted among men, deriving their just powers from the
consent of the governed. No person shall be deprived of life, liberty or protection without due process of law nor be denied the equal
protection of laws. (II Constitution Ar lSec 1 AND 11- Bill of rights
RESPONSE TO DEFENSE AND OPPOSING THE ADMINISTRATIVE DECISIONS
I - Introduction - Personal Statements
I, Sharon Ann Meroni (One Surrey Lane, Barrington Hills, Illinois, 60010) testifies to these
statements contained in this introduction:
I have been seeking resolution to what is a profound question related to the most basic right of our
Constitution. The Right to be represented by constitutionally eligible representatives, regardless at what
party they are from, the level they preside, or specifically in what capacity they govern.
Constitutionally qualified to govern ....According to the US and Illinois Constitutions means to be
a USA Citizen. Age restrictions apply. Other specifications include voter registration; address and
license requirements, etc. Courts have long held states can place specifications on candidates for
participation in the election process. It is in these specifications that many ballot access issues arise for
the courts to review. It is how the game is shaped. Still, age and citizenship requirements are mandated
by both Constitutions. Thus as an undisputed FACT;the laws must support the fulfillment of these
requirements.
Before I briefly outline the journey that got me here, let me explain what I learned has stunned
me. Nowhere in the election process in Illinois does the law support the constitutional mandates such
that the Administrators of the election can certify that candidates for office meet the constitutional
mandates. Furthermore, the law is so eschewed such that even when a citizen seeks to discern the
same, there is no ability to do so. There is a luck ofthe draw approach to citizenship requirements for
ballot placement with no remedy or relief in the law available.
I began the journey into this controversy at hand about a year ago ... Seeking to determine how
the ISBEassured the constitutional integrity ofthe ballot in February 2010; I sought relief twice in
McHenry County Court.
The first time seeking to speak to the Local Grand Jury to testify to how there was no integrity in
the ballot served to me in the 2008 election. (Patriot's Heart V McHenry County Grand Jury) I learned,
after the 5 day qualifying period, it is the discretion of the State's Attorney and the Attorney General to
investigate if a candidate was eligible to serve and they could only bring a cause of action if there were
facts in the record from which they could apply the Law. Assistant State's Attorney Bianchi, both in
court and in meetings between the interested parties, communicated that this was a bar he needed to
see in order to use his discretion to bring this matter before the Grand Jury. He stated that the County
Grand Jury is not financed specifically as an investigative body. Summarizing, that generally the County
21Page
All men are by nature free and independent and have certain inherent and inalienable rights amongthem are life, liberty and the pursuit of
protection of laws. {II Constitution Ar lSec 1 AND 11 - Bill of rights
Grand Jury hears evidence investigated by other bodies. I discerned that this case had fatal flaws as filed
and determined my next step was to go to the body legally empowered by the General Assembly to
administer the election statutes.
February 2010, the timing was such - in my growing evolution of understanding of election law
and procedures - that the Primary for 2010 was in its final phase. I elected to file a TRO in the McHenry
County Court asking to prevent the certification of the Primary results until after the candidates had
established they were constitutionally eligible. (Meroni v ISBE- McHenry County) McHenry County
Judge Caldwell ruled that I had timeliness issues, that I had not exhausted procedures of the ISSE, and
that the correct jurisdiction was either Sangamon County or Cook County. He ruled the flaws were fatal
in his court.
While the case was never tried on the merits, In this case, McHenry County Clerk Katherine
Schultz and Lake County Clerk Willard Helander provided certified statements as evidence that affirmed
nowhere in the election process is there verification that voters are US Citizens, nor is there any posting
of factual documents affirming citizenship or age of candidates for office. Furthermore, there is no
authority for, nor resources allocated for the Clerks to check that candidates are constitutionally eligible.
In addition, Mark Sheldon, Champaign County Clerk answered in writing, questions specifically
addressing the fact that in Illinois apparent conformity standards are not equal and that the Illinois State
Board of Elections had permitted Alan Keyes ballot placement even though he had not personally
applied for it and did not sign a Statement of Candidacy (Exhibits page 03-05 SHELDON)
In Meroni v ISSE- McHenry County the Assistant Attorney General argued and prevailed in their
argument, that I had not gone through the Administrative processes of the Illinois Board of Elections.
I was disappointed because once again, I was denied access to redress for my legitimate grievance, (as a
Natural Born Citizen of the United States of America and of the grand State of Illinois, and a qualified
legal voter who had participated in both the 2008 and 2010 Primary and General elections) to know if
the ballot I was given contained only candidates that were 'legally quclified" or if indeed the law is
deficient in ascertaining in the public record as fact, that they were. Still, for a variety of reasons all
unrelated to the merits ofthe controversy, and based on the Judge's ruling, I concurred thatthe case
was likely fatal, now understanding the need to go through the Administrative process, (10 ILCS
5/10-8) before this could come to its natural remedy as questions of law.
III Election Code sets out a 5 day period for which a candidate's application for ballot placement
can be contested by other candidates and qualified voters in the respective districts - or simply for any
31Fage
candidate that applies for my ballot, I can contest during time periods set out in 10 ILCS 5110-8.
This is the only place I can contest a candidate placement on my ballot.
In good faith, I contacted the Assistant Attorney General Mark Ishu, seeking to testify before
the Illinois State Board of Elections about this controversy. (R 133) I was never asked to testify.
ThelSBEofdutiesaredefinedlO ILCS 5/1A-8} (from Ch. 46, par. lA-8)
Section lA -8 defines the duties and include
Review and inspect procedures and records relating to conduct of

elections and registration as may be deemed necessary and to
report violations of election laws to the appropriate State's
Attorney or the Attorney General; (8) Recommend to the General
Assembly legislation to improve the administration of elections
and registration;
When a controversy over the very constitutional integrity of the ballot was filed against the ISBE
in a court of law, even while procedurally they prevailed, they had to argue I should go through
procedure, they have should have provided an opportunity to hear about the vulnerability of the ballot
as it relates to this controversy. They did not respond to my request to testify before them.
This controversy cannot be resolved through facts because it is the lack of facts that is this
controversy. The Law (10 ILCS 5/10-5) does not support the constitutional mandates of
Citizenship.
Nowhere has the State argued that the candidates are constitutionally eligible. They have failed
to affirm that in the record. The State has only argued their own deficiency and then ... Demonstrating
the sheer arrogance of this process, stated I needed to go the Legislature, when in fact the Code
specifically mandates that that is the job of the Illinois State Board of Elections. ( (10 ILCS 5/Art. 1A)
Timmons, 520 u.s. at 358, 1371. Ed. 2d at 598, 117 S. Ct. 1369 affirms that states must
enact reasonable regulations of parties, elections, and ballots to reduce election-and campaign-
related disorder. The State and the ISBE have failed to enact reasonable regulations that secure
in the public record facts asserting constitutional eligibility, thereby denying the petitioner
equal protection rights.
Indeed the law as currently practiced, provides for politicians to be a special class. The federal
government routinely requires proof of citizenship for many federal jobs, including joining the Military
and various other federal jobs posted on http:Uwww.usajobs.opm.gov , USAJOBSis the Federal
41Page
Government's official one-stop source for Federal jobs and employment information. Most positions
require a background check, which includes proof of citizenship.
Indeed this is not a political question, it is a judiciable question.
Lastly, the reason that I chose all of the candidates on my ballot is because it really is a question
that affects all of them. I believe candidates from the major parties should be held to the same standard
of proof. The issue is how and where. That question is part of the issue needing resolution. I do not
attempt to answer it for myself except to say that what is good for the goose is good for the gander ...
and by-golly if our men and women in arms must provide a raised seal birth certificate to serve then why
can't candidates for office? Perhaps passports will work .
I believe the how and where is part ofthesolution needing to be ascertained through judicial
inquiry.
li.,- Res'ponse_to Defenses "Brief in support of administration decision
Response: BRIEFIN SUPPORTOF ADMINISTRATIVE DECISION-This section is a direct response to the
brief filed by the Illinois State Board of election through the Assistant State's Attorney, Jessica L. Reeves.
Comments related to Defense's Introduction
1) Defense" Introduction and Background" stipulates "lllinois Election Code Requires that these
prospective candidates file, among other things, a Statement of Candidacy." (101LCS 5/10-5.)
2) The Board admits it's own legal deficiency in the follow - up sentence If With the exception of
one candidate Christopher Pederson, (discussed later), ....Iegal qualifications of office"

a. According to Druck V ISBEthe board is required to use apparent conformity standards
b. Accordingly, they do this at the time the petitions are accepted.
c. It is a question of ignoring the law and Judicial decisions that the Illinois State Board of
Elections (SBOE) is violating in refusing to impose apparent conformity standards
d. It is a due process violation when the state refuses to make available to the public
apparent conformity standards or the lack there of.
€. Meroni's pleadings from the ISBEHearing process consistently affirm that the Illinois
State Board of Election (SBOE) refuses to do its job in not using apparent conformity
standards
f. This refusal has prejudiced Meroni's ballot choices at least in the 2008 and 2010 Primary
(Alan Keyes) and influenced the current objection process by causing for an inordinate
51Page
number of unqualified candidates application to be placed for ballot position for the
petitioner and others to object to, causing for disarray in the election process.
(Especially Pedersen, but not exciusively- Many candidates did not fulfill apparent
conformity standards -)
g. Just prior to testimony before the SBOE Meroni called Mr. Steve Sandvoss in his capacity
as Counsel for the ISBE(SBOE)and asked at what point does the ISBEassert apparent
conformity standards. Mr Sandvoss stated that the ISBE(SBOE)does not apply any
standards of apparent conformity.
3) The Board asserts "there is no evidence presented to rebut these Statements of Candidacy".
a. This statement argues against the State's later assertion that the correct Standard of
Judicial Review is Law and Fact.
b. State stipulates there are no facts in dispute.
c. State stipulates there were never any facts in question
4) The Petitioner's original petition makes 4 points.
a. Asserting Meroni's standing and clearly stating her interest as a "Citizen desirous of
seeing to it that the Illinois and Us Constitutions are upheld, laws governing the filing of
nomination papers for a candidate for election to the office of __ are properly
complied with and/or that only a qualified candidate would appear on the ballot as a
candidate for said office.
The Defense provides no challenge to Plaintiffs standing or interest
b. Meroni's second point defines the challenge in an affirmative statement of Law, not a
statement of fact. "All candidates for office must meet certain Constitutional
requirements to be qualified for office. " She then affirms the constitutional
requirements in question in the objection petition "All candidates must be a specific
age and be a Citizen of the United States of America to hold office in Illinois"
At no point during this process has the Hearing Office, the ISBE (SBOE) nor in Ms.
Reeves Response do they
i. Dispute this point of Law
ii. Claim any deficiency whatsoever in this statement.
61Page
_______ 0._ .. _._0 _

iii. Indeed the State ignores this statement entirely because it disputes their claim
that the petition lacks specificity. This second point on the objector's petition
affirms with exact specificity what the question is about.
c. Meroni identifies who the candidate she is objecting to is and the office sought.
d. Meroni affirms: That the papers are insufficient because they fail to demonstrate or
provide documentation (fact or evidence) the candidate meets the constitutional

requirements for office.
i. This is not disputed by any fact.
e. "The remedy is that the papers be declared insufficient and not in compliance with the
laws of the State of IlIinois." Meroni affirms, she did not ask that the candidates be
removed from the ballot because the law stipulates that if the papers are not in
compliance the ministerial obligation of the Board is to not award the candidate the
desired ballot position.
i. The Defense offers no fact to substantiate its claim of deficiency. Indeed it
cannot, because to do so would argue its own deficiency. The current practice of
the ISBEis to permit candidates ballot access whose papers are not in apparent
conformity on the ballot

ii. This deficiency is both according to statute and to legal rulings mandating
otherwise. (Druck)
iii. The petitioner seeks permission to write a Mandamus to compel the ISBE
(SOEB)and the General Assembly to do their jobs!
The State's errs in its pleading that what was insufficient about Meroni's statement, claiming
"no further detail to what was insufficient about the candidate papers" (Defense motion - page two line
7-9) as if closing its eyes to the 2nd statement on the petition defining the requirement means it does not
exist.
Indeed on the flip perspective, what fact could the Plaintiff have affirmed was missing? If the
Plaintiff, in the Objection, had stated a lack offactual evidence specifically itemizing a birth certificate,
or naturalization papers, she would have ended up in the same place; the ISBE(SBOE)would have
7lPagf:
consent ofthe governed. No person shall be deprived of life, liberty or protection without due process of law nor be denied the equal
affirmed Meroni was askingfor something not required, and this would fatally prejudice through
erroneousfact, proceedingsin a strike and dismissmotion filed by candidates. Her claim by necessityis
strictly a question of law.
RPage128-130
The Defense incorrectly states Meroni's position that "potential candidates are
constitutionally required to prove to the Board that they are citizens of the United Sates and
eludes to the fact that this procedure somehow caused harm during the 2008 elections" (R 128-
130 and 121)" (Defense motion p3 line 1-4)
The discussion on these pages (R 128-130 - specifically points 81-116) involve the
absence of public document to establish constitutional qualifications. This defect of law
eviscerates the election process, undermining and destroying the natural and intended effect of
her right to object during the 5 day qualifying period and that this presents a due process issue.
Indeed these lapses also violate 1st and 14th amendment rights because it treats one
party favorably during the contest period, and forever prejudices against the voter as objector
or the voter in her ballot access; and through painful violations of the most grievous sort of her
equal protections afforded under the law. The only party that has factual evidence of
compliance with Constitutional mandates is the candidates.
In addition, these points argue that through apparent conformity and other statute
provisions various other constitutional requirements are proven in the public record! ( for
instance: statement of economic interest, voter registration) and as such can then be used as
evidence for factual challenges to the candidate's applications.
In addition the points on these pages prove that the Statement of Candidacy (herein
saC) is too general and therefore imposes deficiencies in the uniformity of elections. The sac
violates 14thAmendment equal protection rights and 1stAmendment rights because the sac
does not specifically identify conformity with us and IlConstitutional mandatory requirements
to be a USA Citizen. The sac therefore eviscerates the petitioner's right to assess candidate's
subjective and self certifying statement of being legally qualified.
81Page
The Plaintiff makes the point there is no definition of legally qualified from which she
can find as reference to assessthe candidate's applications. Again, affirming that "while
evidence of eligibility exists in the public record for other qualifications required for legally
qualified, it does not for citizenship." (R p129 point 104)

On page 130, Meroni states the fact that this problem will re-occur in the 2012 election.
(point 108) Specifically reporting that there is no definition in the Illinois Statues (or in Federal
Statues) that define natural born citizen. Without a definition, the voter who has a right to
object, cannot asses the veracity ofthe candidate's self certifying and self defining statement
according to a standard of law, especially as required in legally qualified.
Big time due process problem!
Furthermore, the requirement for being legally qualified for any office specifically as
relates to citizenship status (natural born citizen, US citizen or naturalized citizen) or age, is
never moot; yet without public record that information cannot be accessed nor can it be
prosecuted. This refers back to lessons learned from State's Attorney Louis Bianchi in McHenry
County Court. (Meroni v ISBEFebruary 2010)
It is this very question that originally brought the petitioner to this controversy of law
surrounding the most profound right in a Republic; the veracity of the vote, and the integrity of
the ballot.
It is a question of law that there is no definition of natural born citizen and also no
posting of proof establishing fact or evidence of "legally qualified"
These questions of law will re-occur. They already have. (Separate issues in 2008 - Alan
Keyes - placed on ballot without signing a Statement of Candidacy and Obama) While these
cases are not part of this review, they are germane as examples. This question of law requires
judicial intervention and resolution because fundamentally this is not a political question that
should be resolved by negotiations in the legislature.
These questions of law will re-occur when the petitioner returns during the next cycle of
candidate qualification for ballot to discern if the candidates are legally qualified. If the
91Page
protection of laws. (II Constitution Ar lSec 1 AND 11 - Bill of rights
petitioner adjusts her wordage in some fashion} the Board will still refuse her, not because the
merit ofthe claim is deficient} but because the ISBE will hide behind similar procedures
designed to frustrate the petitioner's lawful access to the election process.
The harm done to the public confidence in its government is indisputable.
Just a month ago, CNN - a Liberal Cable News Media posted the following shocking
poll. Poll numbers for those questioning the Constitutional eligibility of Barack Obama continue
to rise. It is shocking to have such a basic question unanswered considering it is the core to our
Republic (Exhibits pages 01-02 CNN)
Do you think Barack Obama was definitely born in the United States, probably born in the United
States, probably born in another country, or definitely born in another country? July 16-21, 2010
Americans Democrats Independents Republicans
Definitely born in U.S. 42% 64% 37% 23%
Probably born in the U.S. 29% 21% 31% 34%
Probably born in another country 16% 7% 17% 27%
Definitely born in another country 11% 8% 12% 14%
No opinion 2% 1% 2% 3%
Other polls reflect similar or even larger percentages of Americans (around 1/3) who
question the very validity of this government, which if not constitutionally eligible, is reducing
Americans to mere slaves, (15 Amendment violation) as unwilling recipients of the Executive
Office's contrived governance that is not constitutionally based.

Is Mr. Obama a natural born citizen? The truth is he subjectively self certified to legally
qualified; he is the only one with proof of his affirmation, and he has refused to enter that
proof into the public record. Despite obvious political realities of the situation, the reason this
large public question is germane to this discussion is because of this unconstitutional law (10
IL5C 10) and a lack of governance from the ISBE (50E8) and the General Assembly. There is no
ability for the public to look for resolution of that question. Thus, the question lingers in the
public arena, now nearly 1/3 of the electorate are concerned with this same profound question,
demoralizing the voting public and undermining the authority of the office Mr. Obama (or any
other candidate or elected official) holds.
It is beyond the absurd, it is tragic.
10 I P age
Just like there is no record in a legal format establishing that Mr. Obama is a natural
born citizen, so too there is no evidence of citizenship of any candidate in office in Illinois; with
the exception of the 11 or so that produced proof to the petitioner.
Subjective self certification of legally qualified is not legally sufficient for proof for
constitutional mandates, especially when the description of legally qualified is subjective to the
opinion ofthe signer and no fact is in the public domain to assess it.
While the initial scope of this petition of Judicial Review of an Administrative decision,
does not factually address the issue of natural born citizen; this is included here as a case in
point affirming the Plaintiff's testimony, especially since the Defense mischaracterized
Plaintiff's responses on these pages of testimony in question.
It is incredibly demoralizing to struggle so intensely for such a simple answer ...
"Yes, but .... Are they legally qualified .... ?"
Lastly these pages (R 128-130) the Defense referenced, address the fact that the ISBEis not
doing its job because it refuses to enforce standards of apparent conformity.
Meroni asserts in arguments on these pages that the obligation shifts on a SOCfor the
signatory to prove with evidence their qualifications when challenged. (by affirming they are in
possession of licenses required and because they are the only one who has access to the
information)
Meroni also asserts that apparent conformity standards that do not include proof of
constitutional eligibility deprive the objector of due process because she cannot challenge what
is not provided in the factual record.
R Page 121
Defense also erroneously references Plaintiff's testimony in R- 121, claiming the
Plaintiff affirmed candidates had to prove citizenship to the Board. This section includes the
Oath of office ofthe Board of Election members. This Oath was renewed on July e" 2010
11 I P age
The pleadings then progress to establishing responsibility of the various players in the
game. There are many important points in those pleadings, none of which include a statement
to the effect that the petitioner believes candidates are constitutionally required to prove to
the Board they are citizens. This is a misstatement of Meroni's position.
However, to address that point specifically. This is a question of Law. The candidates
must be UScitizens (and of certain ages, no less then 18). There is no public posting of proof
such that only one party in the contest has proof of eligibility, and therefore the election that
they administer over is not "fair and equal" as required by the Illinois constitution (3rd
Amendment). The ISBE(SBOE)eviscerates the voter's rights when they fail to assure the
fairness ofthe election process. While they cannot make law, they are required to report to
the General Assembly. They have broad powers which include that they are bound by oath to
uphold the Illinois and US Constitution. Yet, they fail to do so. Who ultimately is responsible
for holding the proof of US Citizenship, that question the petitioner deliberately does not
address. Her point is that proof of citizenship should be part of the public record and available
for examination during the application for ballot and subsequent objection period. A
subjectively derived and self certifying statement is not legally sufficient to establish fact of
citizenship in the public record.
Lastly page 121 addresses the fact that barriers to contest citizenship as currently
framed are an extreme barrier on the electorate. And that a constitutionally unstable or false
ballot undermines the American electoral process with implications at all level ofthe
government.
standard-of Review
The Defense is fundamentally wrong in arguing that this is a mixed question of fact and law.
The Defense admits in its own pleadings there are no facts in dispute and that no facts were
ever in dispute. Clearly there are only questions of law involved because there is no evidence
available, and therefore the question of law arises in this controversy.
12 I P age
The correct standard of Review in this case is a Question of Law. Questions of Law are
reviewed de nova. (Bill v Education Officers Electoral Board of Community Consolidated School
District NO. 181, 299 JII.App.3d 548701 N.E.2d 26223311/. Dec. 619 (i" Dist. 1998)
Mixed questions of law and fact require the following (1) where historical facts are
admitted, (2) where rule of law is undisputed, and (3) where the only remaining issue is
whether the facts satisfy a statutory standard. Meroni's petition involves no facts. The Defense
and Plaintiff agree that there are no admitted facts. The Defense refuses to prove what facts
are admitted because there were none.
Clearly there is a rule of law in dispute.
Speaking of facts: There are no facts to judge because no facts are given, so what are
we to argue? We are to argue questions of law! Thus Ms. Reese's brief is in error. To be a
mixed question the rule of law must be undisputed. In this case the rule of law is what the
dispute is about.
The offending laws do not require any public fact to establish proof of eligibility - There
are no facts regarding eligibility. The Defense correctly argues there is "no dispute as the fact
presented". This is because no facts are available in the public record to prove or not,
eligibility. (Defense motion page 6 line 4)
If the question of Law to be considered is whether the objections meet the statutory
requirement, then Defense has failed to provide any fact to prove that the objections were too vague.
No evidence is presented affirming that the candidates objected to were confused or somehow
prejudiced against because of confusion, nor that they did not understand what was asked of them. 11
of the candidates challenged produced proof of citizenship.
The Defense deliberately ignores Plaintiffs 2nd statement. Her Objector petition must be read in
its entirety to be understood.
Objections Insufficient as a Matter of Law:
The State does not claim any case in point nor identify anyone who was unsure of what the
Petitioner was seeking, conveniently ignoring the definition of constitutional requirements in question-
"all candidates for office must meet certain Constitutional requirements for office. A" candidates must
be a specific age and be a Citizen of the United States of America to hold office in Illinois. (R 1 #2)
13IPage
The Legal Question here is: Does the Rule 4 allow broad based denial ofthe petitioner's 1st and
14th Amendment Rights, as well as Illinois Constitutional Rights (Article LSee1 and 2; and Article III See 3)
u When reviewing challenges to a state's election laws, courts must weigh
the urn'character and to the rights protected by the First and Fourteenth
Amendments .' against 'the precise interests put forward by the State as
justifications for the burden imposed by its rule.'O" Burdick v. Takushi, 504
U.S. 428, 434, 112 S.Ct. 2059, 2063, 119 L.Ed.2d 245 (1992) {quoting Anderson
v. Celebrezze, 460 u.s. 780, 789, 103 S.Ct. 1564, 1570, 75 L.Ed.2d 547 (1983».
In applying this flexible standard, courts must also consider "the extent to
which those interests make it necessary to burden the Plaintiff's rights." Id.
(quoting Anderson, 460 u.s. at 789, 103 S.Ct. at 1570) . If the state subjects
these rights to "severe" restrictions, the regulations must be "narrowly drawn
to advance a state interest of compelling importance," Norman v. Reed, 502 U.S.
279, 289, 112 S.Ct. 698, 705, 116 L.Ed.2d 711 (1992); rnsee Socialist Workers
Party, 440 U.S. at 184, 99 S.Ct. at 990. If the state imposes reasonable,
nondiscriminatory restrictions on these rights, however, the state's important
regulatory interests will generally be sufficient to justify the regulations.
Burdick, 504 U.S. at 434, 112 S.Ct. at 2063-64. Libertarian Party v. Rednour"
10 ILCS 5/10-8 permits any voter having objections to any certificate of nomination or
nomination papers the right to file objections within the 5 day qualifying period. In this case the
objection is based on insufficiency of the candidates papers, not because of proof that the candidate is
specifically lacking in constitutional sufficiency but because there is no fact in the public realm to discern
the constitutional Qualifications of the candidate. This is a Question of Law.
Motion to Strike and Dismiss
Please enter these exhibits as testimony provided during the SOEBhearings.
Exhibit: Meroni Responds Constitution Party (R-120-146)
Exhibit: Meroni Responds Boyd (R-147-162)
Exhibit: Meroni Responds Libertarian Party ( R 163 - 190)
Exhibit Meroni Responds Gregg Moore (R 190- 108)
Exhibit Meroni Responds Stephen Estill (R- 209 -223)
Exhibit Meroni Responds Carl Officer (R 224- 239)
Exhibit: Exception to the Hearing Officer's and General Counsel's Recommendation to Grant
Motions to Strike and Dismiss. (Meroni Exhibits p 014-019)
14 I P age
Exhibit: Estill Responds(Meroni Exhibits033)
The SOEBdecision granting a motion to Strike and Dismiss to Carl Officer again reflects
the Board over stepping it's authority in order to avoid the question at hand. Meroni did not
receive Mr. Officer's motions, and she alerted the Board and Mr. Officer ofthis (Meroni Exhibits
06-07- Officer Email). In addition even after complaint was made about not receiving the
motion, none were produced in the record. To Meroni's knowledge, Mr. Officer never made a
motion to Strike and Dismiss, thus the Board, acting like the lawyer for Mr. Officer, pleading for
him. Essentially sua sponte, making motion for Mr. Office.
The same is true of Mr. Stephen Estill. The Plaintiff is not aware of any Motion to Strike
and Dismiss from Mr. Estill. The motion Mr. Estill did file provided no response to Meroni's
objection. Clearly it was insufficient. By taking on the role of Mr. Estill's counsel, the Board
violated Meroni's rights to equal protection, the Hearing Officer obviously biased against her
interests with no fair arbitrator at the Board.
Ironically and incredibly, the Hearing Officer Menzel's ruling - affirmed by ISBE(SBOE)-
effectively stepping in to protect Mr. Estill's insufficient pleading, while arguing the right to do
so against Ms. Meroni's petitions on grounds her pleadings were insufficient. Essentially sua
sponte, making motion for Mr. Estill

I know •••huh?
Mr. Moore failed to file a Strike and Dismiss Motion. His motion to dismiss was
inaccurate because it stated that the age and citizenship proof was in the filed papers. Had this
claim been held in a Hearing under the weight of evidence standards, it would have been
proven clearly as false. Therefore the Board erred in granting essentially sua sponte a motion
that essentially assumed Mr. Moore's role as counsel, while arguing Ms. Meroni's deficiency in
her part 3 of her petition.
Mr. Moore makes an interesting example for the Defense to use. First, the ISBE(SOEB)
assumes a motion for Mr. Moore. (No Strike motion was submitted) secondly they decided to
grant a motion he did not make depriving Meroni the natural effect of her right to object to
candidates legal qualifications to be on her ballot.

15 I P age
protection of laws. (11Constitution Ar lSec 1AND 11- Bill of rights
Importantly - Thirdly, the petitioner had the opportunity to meet with and to speak with
Mr. Moore on a couple of occasions. A black man, he clearly has a strong foreign accent. Mr.
Moore expressed some offense to the petitioner's objection to his candidacy saying anyone
should be able to run for office, regardless of citizenship status. Still, he proudly affirmed he is
proud to be a Naturalized Citizen. Meroni assured Mr. Moore that her objection was not
prejudicial to him, and that she had objected to all of the candidates. Mr. Moore promised to
send Meroni a copy of his naturalization papers, but to her knowledge, he has thus far failed to
do so.
If the Petitioner had access to Mr. Moore during the 5 day period, or earlier, and had
objected strictly based on his accent, then the Constitutional Rights (1st and 14th) of both the
candidate and the objector would be infringed upon. Further the objector at that point could
only assert a reason based on profiling and thus is forced by the insufficiency of the Statue, to
issues related to "1983" and civil rights infractions.
Shon-Tijan Santiago Horton makes a different case. During the 5 day objection period,
the only information the Petitioner had about Horton was his name. "Shon Tijan Santiago
Horton" Unfamiliar, with the ethnic background of Mr. Horton's name, on the face of his
application, Meroni was unable to discern if he was a man or woman, let alone his citizenship
status. As it works out, Mr. Horton provided his birth certificate. Thus while he is not a
Defendant in this case, his case is germane because the Petitioners objection to his candidacy
was rejected in the Board's erroneous sua sponte Rule 4 decision.
To the point of civil rights, if either of these candidates had been challenged and
argument in support of that objection was based on accents or ethnicity of the name, the
Petitioner could be held in violation of civil rights profiling. Thusly, affording rights unequally
between candidates and the voters is costly in many regards, not the least of which is creating
an unnatural civil rights tension between voters and candidates; which are easily resolved be it
not for this restrictive and unconstitutional law. (10 ILCS5/10) The petitioner is denied her
right to assess candidates except through profiling as a consequence of this deficient statute.
The Luck of the Draw Worksheets filed out for each candidate succinctly illustrates the
difficulty of the problem. (R 145-146, 161,177-183, 206-207, 223, and 225). There is no rational
16 IPa ge
legal basis to use to discern constitutional mandates establishing "legally qualifications" in the
public record. Related to Standing and Remedy (R- 136)
Invoking Rule 4 - Sua Sponte and to Strike Objections
Please review "Exceptions to Hearing Officer's Recommendation to Invoke Rule 4 Sua Sponte
and to Strike Objections in their entirety" (Meronl Exhibits pages 08~013)
In addition, Plaintiff assets - Christopher Pederson: This candidate brings a unique challenge to
this Legal question. In the first instance, the ISBE(SBOE) erred in accepting his candidate filings because
on the surface they were clearly insufficient. This shows complete disregard for its duties as required by
Law (Election Code 10 ILCS 5/10) and judicial rulings (Druck).
Incredibly the ISBElater attempts to shift the responsibility for its lack of governance to the
Plaintiff stating without any legal authority that this is an issue she should have with the Legislature,
effectively eviscerating the election process, especially since the election code 10 LlCS5/10 - 8 allows
objectors a 5 day time to assess candidates for ballot placement according to being legally qualified
and it is the ISBE(SOEB) ministerial mandate to advice the Legislature and make policy, not the
petitioners. (10 ILCS 5-1a)
Druck is particularly interesting because it rules against candidate access. The candidate, Druck
was denied ballot access because ofthe number of voter signatures in his nomination papers. (Druck
thought his attorney Spiegel) argued that the Apparent Conformity standards were randomly enforced
through the objection process. " (2) whether Druck's first and fourteenth amendment
rights are violated if the signature requirements for ballot access in
section 10-2 of the election code are only enforced when the objections are
filed pursuant to section 10-8 of the election code" (Druck v. Illinois State Board of
Elections [1-08-2440] Fourth Division November 26,2008 pg 2)

The court decided 1) the nomination papers have to be filed as required by the Code and (2) the
nomination papers have to be in apparent conformity with the provisions the election code 10 ICLS5/10
-8 (West 2006) (Druck v. Illinois State Board of Elections [1-08-2440] Fourth Division November 26,2008
Pg 14)
The Defense does not argue or present evidence that any candidate was confused by the
objection. It assumed the deficiency, standing in as counsel and making argument for the candidates,
prejudicially in their favor, and denying her any right to a hearing on the question of merits.
17 I P age
protection of laws. (II Constitution Ar lSec 1 AND 11 - Bill of rights
The 4th rule needs to be struck as providing the Illinois Board of Elections assumed powers. This
is a first impression case on this rule. The Defense provides no legal justification for the right to impose
this Rule 4. Petitioner would like to brief specifically about it.
AmendingJllinois Code
The petitioner believes it is well within the wisdom, mandates and abilities for the
General Assembly and the ISBE (SBOE) to fulfill their mandated responsibilities, and surely that
role should not be given to a mere voter.
The Defense mischaracterizes the petitioner by refusing to admit that the petitioner
attempted to resolve this issue of law within the processes of the board along with her right to
object, the core of the disagreement is over the law.
"I would ask the Board, what would you like me to state and to prove that my
ballot is constitutional and that my candidates are eligible" (Pg 90 Line 16-18 )
"One of the options that I made for all, because I recognize the difficulty of this
problem. The Illinois Generol Assembly has not done their job. The ISBEhas not done
their job. You have not recommended that we have a security issue related to our ballot
that anybody basically - right now, Mickey Mouse could sign up and get on there as long
as nobody objects to it.
Nobody has done their job in that regard. And I recognize that. I'm sympathetic
to it. But what I don't understand is what we're going to do ABOUT MY BALLOTIN
November. Because when you guys turn down ... and Ifully understand that my options
of winning here, my chances of winning in this board is very small. Okay... but when you
turn it down, the consequences are going to be that I'm going to court.
And I am here to say our country right now is in a huge problem. Chicago is too.
Is there any way that we can avoid court? I would like to try to do that as part of our
conversation today.
And I also want to go to some of these candidates and say, if you .... If the Board
makes this decision today, and you decide that, yes, you are going to ... you are going to
hold these objections up (meaning deny the Objector her Hearing on the merits-
18 I P3ge
clarification in words added) then you've now got all of these candidates that all they
had to do was show me a birth certificate and I would withdraw my objection to them
and they would not have to go on to the next level of civil court.
And I know you may not be able to jorcibly say "present your certifications" but
you can recommend it. There's nothing in the policies and procedures that would
prohibit that.{pg 92-93)
Second: Response to Defense quoting -The full transcripts state.

"And the arguments don't say that I'm not entitled to the information. They just say
procedurally that there's no process. But if you don't provide me the process, how can I be in
conformity under my five-day objection period?
I know you guys are a ministerial body. I know you don't set laws. I know you're not
going to address constitutional issues. That's not your role potentially. But this is an issue of
process. I want to have a ballot that I know is valid. I can't do that going to the General
Assembly" (R - 95) In this context by process, Meroni affirms she was referring to the fact that
the law does not provide for a process that the ISBE enforces assuring constitutional eligibility-
The ISBE (SBOE) doesn't enforce any apparent conformity standards.
The comment in relation to the General Assembly refers to the fact that save
extraordinary legislative action, nothing can be done in the General Assembly to assure
candidates on Meroni's upcoming 2010 ballot are constitutionally (legally) qualified.
This is clearly a question of law.
"IfPlaintiffwishes to see the Statement of Candidacy provision changed, then her

recourse is with the legislature and not with the Board" ( Defense motion - P 9 lines 6-9)
Defense fails to establish legal sufficiency or legal precedence imposing this limitation on her
right to vote and is clearly wrong.
Delay V Board of Elections is important because the Court affirms in Delay that the Board cannot
take an interested role in the proceedings, thus Meroni asserts in fact this ruling does apply to her point
19 I P age
that the Board exceeded its authority when devising motions for candidates and then deciding on that
motion, sua sponte. Defense has not presented case law to substantiate the usage of sua sponte.
The Defense complains about Plaintiff's lack of case law to prove her position in opposition of the
Board's erroneous usage of sua sponte, yet refuses to cite any legal cause for their extraordinary usage
of power and in support of their Rule 4, Rules of Procedure as adopted by the Board at its July 6, 2010
meeting. (Defense motion p 12 Line 15-19); or of their usage of sua sponte motions - both as Motions to
Strike and Dismiss and in the Rule 4 usage.
III : Addjtioi'laJ-lssues - Apparent Conformity
In relation to apparent conformity, besides constitutional requirement, having consistent
standards holds considerable weight from judicial viewpoints. '[ A]s a practical matter, there must be
a substantial regulation of elections if they are to be fair and honest and if some sort of order,
rather than chaos, is to accompany the democratic process' "quoting Storer v. Brown, 415
US.724, 730, 39 L. Ed. 2d 714, 723, 94 S. Ct. 1274, 1279 (1974),
When the word "shall" appears in a legislative provision, courts have generally interpreted the
provision to be mandatory Watson v. Howard, 322 III. App. 3d 562, 565, 749 N.E.2d 427, 429 (2001);
Niziolek v. Chicago Transit Authority, 251111.App.3d 537, 541, 189111.Dee.780, 620 N.E.2d 1097 (1993).
In Druck V ISBE the Court states "We find, based upon our reading of the Election
Code, (1) that section 10-2 of the Election Code imposes signature requirements; (2) that section
10-8 imposes conditions precedent for nomination papers to be valid before a candidate's name
is placed on the ballot; (3) that section 1O~14 requires the SBOE, the election authority with
whom the nomination papers are filed, to certify the papers; and (4) that, if the nomination
papers are valid on their face and the election official does not remove the candidate's name
from the ballot, section 10-8 provides a vehicle for an objector to challenge the nomination
papers. 10 ILCS 5/10-2, 10-8 (West 2006).
This Judicial opinion supports the ministerial (not discretionary) requirement of the ISBE
to enforce apparent conformity standards. It also affirms that 10-8 rightfully provides a vehicle
for the objector to challenge nomination papers. However, in the instance of constitutional
mandates of age and citizenship, the subject at hand, that vehicle is denied its intended effect for
the petitioner because of a lack of fact in the public record.
20 I P age
To avoid questions of fact from entering into this dispute, Meroni agreed to remove all
objections from candidates who produce proof of citizenship. This was the only option available to her
in light of the deficiency of the Statute. (10 ILSC5/10-8)
Candidate's potential claims of privacy issues when the constitutional mandates for
public office is citizenship would not sustain a judicial review, based on the merits. Surely, the
Public's right to know would prevail.
IV Conclusion
That this matter is exclusively a matter of law, and that the Judge examines the Law questions,
de nova. These cases do raise a judiciable controversy under the Constitution and cannot be relegated
to the political arena.
That the Primary question of law involved: Is the public entitled to a public record affirming that
US and Illinois Constitutional mandates are met, especially as relates to age and citizenship?
That the court will allow the petitioner to amend her remedies to be as follows:
To rule as a point of law denying the Board the right to act as the moving party in the
proceedings for motions of Strike and Dismiss.
To rule that Rule 4 restricts the due process rights of the Petitioner and is unconstitutional.
st
That the Court will answer - Is there a fundamental due process, and 1 and 14t h Amendment
controversy, especially equal protection violations caused by the insufficiency of 10-5/10-5 and 1- 5/10-
8.
There is a National Security issue to assure only elected officials are holding office. The
petitioner seeks leave to write a brief on this.
To find that 10 ILSC5/10-8 is unconstitutional because it fails to assure a process whereby proof
of citizenship and age is included in the public record, especially during the 5 day contest period.
That Constitutional mandates are never moot, that the Court, in it's judicial wisdoms, assure
proof of citizenship is kept available in the public record for as long as required.
That the Court find that in order to affirm an application of legally qualified, evidentiary proof
of meeting all milestones of legal compliance with the specifications of "legally qualified" becomes part
ofthe public record.
21IPage
That the Court would rule on the problem of the term for legally qualified on the Statements of
Candidacy being too general and leaving the term to the subjective interpretation of the self interested
politician. Therefor definitions of legally qualified must be made public.
That the Court rule it is unconstitutional to keep from the public apparent conformity standards
and that these should be kept in the public view.
That the court rule the Board acted outside of its authorities in granting the motion to Strike and
Dismiss and the Rule 4 sua sponte, depriving the petitioner of her various constitutional rights,
especially 1st and 14th.
The Court permits the petitioner time to prepare a Writ of Mandamus to seeking
testimony from the Board about how it secures the constitutional integrity of the ballot, and to
account for its willful disregard of the Court's and Law requiring them to practice and enforce
apparent conformity standards.
In lieu of a Writ, that the Court rule as judicially empowered on the issue of the Board's
failure to perform it's ministerial duties.
Meroni seeks the Court to bring grant other reliefs she is entitled to.
22 I P age
~~ -----------------------------
Sharon Ann Meroni
~0-r:~'/f~
Pfaintiff: Sharon Ann Meroni
Address: One Surrey Lane
Barrington Hills, 11 60010
23 IP2 g =:
protection of laws. {II Constitution Ar lSec 1 AND 11- Bill of rights
CERTIFICATE OF SERVICE
I certify I have served, through email and through the US Postal Service, the defendants
were served via their attorney of record, Jessica Reeves. At the address know for her at the
Illinois State Board of Elections in Springfield
CANDIDATES:
JEFF TREXLER
MICHAEL L WHITE
GARY DUNLAP
LOUIS COTTON
TIMOTHY BECKER
DAWN CZARNY
BILL MALAN
JAMES PAULY
JOSH HANSON
JUILEFOX
MIKELABNO
ED RUTLEDGE
LEX GREEN
GREGG MOORE
CARL E. OFFICER
WILLIE BOYD, JR
COREY DABNEY
EDMUND J. SCANLON
CHRISTOPHER PEDERSEN
on September 20,2010
SHARON MERONI
~;I/~>
24IP~;;c
• C1 C "-
Ail men are by nature free and independent and have certain inherent and inalienable rights among them are life, liberty and the pursuit of
Meroni's Exhibits
CNN pg. 001 - 002
Mark Shelder - Apparent Conformity pg. 003 - 005
Officer Emails pg. 006 - 007
Exception: - Motions to Strike and Dismiss pg. 008 - 013
Exception - to Rule 4 sua sponte pg. 014 - 020
Meroni v ISSE - McHenry County pg. 021 - 032
Estill Response to Objections , pg. 033

..I
•••
OPINION o
a.
RESEARCH
Interviews with 1,018 adult Americans,including 335 Democrats, 398
Independents, and 285 Republicans, nducted by telephone by Opinion
Researcb Corporation on July 16-21, 2010. The margin of sampling error
for results based on the total sample is plus or minus 3 percentage points.
Results in this document labelled "All Americans" or "Total" are based on
this sample of 1,018 adults.
FOR RELEASE: WEDNESDAY, AUGUST 4 AT 11 AM
_~ I OPINION RESEARCH CORPORATION 10 -1- July 16-21,2010
- -----.--- ------------------
41. Do you think Barack Obama was definitely born in the United States, probably born in the United
States, probably born in another country, or definitely born in another country?
July 16-21, 2010

All
Americans Democrats Independents Republicans
Defmitely born in U.S. 42% 64% 37% 23%

Probably born in the U.S. 29% 21% 31% 34%
Probably born in another country 16% 7% 17% 27%
Definitely born in another country 11% 8% 12% 14%
No opinion 2% 1% 2% 3%
.~ I OPINION RESEARCH CORPORATION 10 -2- July 16-21,2010

002....
Apparent Conformity I Blog - Champaign County Clerk, IL - Mark Shelden http://blog.champaigncolIDtyclerkcom/2009/08/05/apparent-conformity/
• Home
• Blog Policies
Aug 052009
Apparent Conformity
Published by Champaign County Clerk at 10:07 am under Elections
Challenges to nominating papers are a brutal reality in Illinois politics. Hundreds of decisions have been rendered around the State either
removing people from the ballot or sustaining their right to be on the ballot. The primary vehicle for removing someone from the ba1lotis
rf)
through the objection process. This is where an interested voter objects to the nominating papers of a candidate or a public question.
Q
A less known course, and far less taken, is for an Election Official to refuse to file or certify a candidate. The justification for this is found in (J
the Illinois Election Code.
Certificates of nomination and nomination papers, and petitions to submit public questions to a referendum, being filed as required
by this Code, and being in apparent conformity [emphasis added] with the provisions of this Act, shall be deemed to be valid
unless objection thereto is duly made in writing within 5 business days after the last day for filing the certificate of nomination or
nomination papers or petition for a public question (10 ILCS 5/10-8)
A 1914 Illinois Supreme Court case, Giese v. Dillon, also provides some guidance on this concept.
The statute imposes the absolute duty on the clerk to submit the question to be voted upon when a petition is filed in compliance
with the statute. He is given no discretionary power when a petition proper on its face is filed. His only function is to determine
whether, upon the face of the petition, it is in compliance with the law. (Giese v. Dillon, 266 Ill. 272)
Around the State, Election Authorities have been loathe to play the "apparent conformity card". It has been subject to substantial debate
because the defmition of apparent conformity is not, well, apparent. In one case, the court conceded that there is substantial grey area in the
matter, while ruling that on the particular issue apparent conformity had not been met. Election Authorities have often asked that this be better
clarified in the Election Code.
In Champaign County, we likewise have been reluctant to refuse a filing based on apparent conformity. I consider it to be an extraordinary
remedy and one that should not be used when others are available and when, in the absence of employing the remedy, no harm will be done to
the election process. The one time we rejected nominating papers based on the lack of apparent conformity was in 2003 when the Green Party
was trying to claim established political party status in Champaign based on Carl Estabrook's race for Congress in 2002. At the time, there was
lof6 9/2012010 2:52 PM

Apparent Conformity I Blog - Champaign County Clerk, 1L - Mark Shelden http://blog.champaigncountyclerk.coml2009/08/0 5/apparent-conformi tyl
some idea that our office might accept the nominating papers and allow the objection process to play out. I decided against that because I
realized there could be harm to the election process (we would have been required to print Green Party ballots for every precinct in the County
for the March 2004 Primary election). While the objection process might have resolved the issue, there was no guarantee that it would. I was
sued over the decision and the Circuit Court agreed with my actions.
Shortly thereafter, we established our own guidelines as to what apparent conformity is. We also created an extensive information sheet to
guide candidates through the requirements. Here is what we look for in order to accept a filing. First, the nomination papers must contain a
signed and notarized statement of candidacy and at least one petition. Second, the statement of candidacy must have an office that is on the
ballot and the party (for the primary filing period) must be one that is established (Green, Democratic, and Republican). Notable is the fact that
in the past we have not counted signatures in Champaign County prior to filing. This is probably the most contentious element in the apparent
conformity debate.
Our reason for not counting signatures was two fold. First, if the nominating papers conform as above, there is really no injury to the process
by allowing a candidate on the ballot who falls short of the signature requirements. Second, there is a suitable remedy available for others to '~
remove the person from the ballot. Third, while the statutes define the signature requirements, they have been subject to much review by the .~
courts and in fact some signature requirements were struck down in 2006 by a Federal Court. Fourth, there is a potential for an arbitrary ~
element to be applied in counting the signatures. (Unregistered voters, incomplete or missing addresses, invalid signatures, etc.)
However, a number of Appellate Court decisions (none in our own 4th District) have been issued in the last decade that have a less strict
interpretation of apparent conformity. In my eyes, rejecting a filing is an extraordinary remedy, like an injunction or restraining order. I think
the recent apparent conformity cases consider it to be a less serious and more ministerial matter. Of interest might be these cases.
Nomination petitions that on their face lack the number of signatures required for ballot access in section 10-2 are not in
conformity of the Election Code. (Druck v. State Board of Elections, 326 Ill. Dec. 220)
For example, by examining the face of the petition, a clerk can determine whether it contains the requisite number of signatures.
(Dillon, 266 Ill. at 276.) If it does not, the petition is not in apparent conformity with the election statutes and the clerk has no
duty to certify the question for the ballot. (North v. Hinkle. 295 Ill. App. 3d 84)
In light of these and other cases, we will be counting the number of signature lines filled on petitions to make sure they meet the minimum
published guidelines and to reject those petitions that don't meet that threshold. We will not be checking the validity of those signatures.
At the State Board of Elections level there was an interesting filing for the 2002 election. Marisellis Brown filed to run for Governor as an
Independent candidate in December 2001 with a statement of candidacy and a single petition sheet with a single signature. The requirement at
that time was for 25,000 signatures. The State Board accepted the filing, no one objected, and Brown appeared on the November 2002 ballot.
If you apply the past standards for Champaign County above you'll see that our office would have handled it the same way. Under the new
standards, we would refuse the filing.
2of6 9/20/20102:52 PM
Apparent Conformity I Slog - Champaign County Clerk, IL - Mark Shelden http://blog.champaigncolmtyclerk.com/2009/08/05/apparent-conformity!
More dubious I feel was the State Board of Elections' handling of the Alan Keyes Presidential filing in November 2007 for the February 2008
Primary. The filing for Keyes included just five petition sheets and no statement of candidacy. No valid objection was filed and Keyes
remained on the ballot, absent any written notice from him that he wanted to be on the ballot. We would not have accepted the filing under
our standard in Champaign County. Once again, we would be looking at the potential injury. Without a sworn statement of candidacy, it
would be possible for someone to put a person on the ballot without their knowledge or consent.
Like many areas of election law, there is a lack of clarity in the statute that occasionally gets settled in court, only to find the matter once more
in dispute in future elections. Anyone wanting more background on this issue can read some of the cases below.
Jenkins v. McIlvain, 338 Ill. App. 3d 113
Welch v. Educational Officers Electoral Board for Proviso High School District 209. 255 Ill. Dec 641
Haymore v. OlT,et. a12008, 325 1lIDec. 89
Bruns v. Kuntz, Unpublished Iroquois County case

~
One response so far <)
~
One Response to "Apparent Conformity"
1. # Champaign County Clerk on 24 Aug 2010 at 9:08 am by Auditor Referendum Will Not Be on November Ballot I Blog - Champaign
County Clerk, IL - Mark Shelden
[...] have written in the past about the principle of apparent conformity. This decision I am making today comports well with what I have
written in the past. Of[ ...]
Trackback URI I Comments RSS
Leave a Reply
Name
Mail (hidden)
Website
30f6 9/20/20102:52 PM
Page l of l
Subj: Re: Meroni v Officer 10 SOEB GE 537 - Motion for extension of time [granted]
Date: 7112/201011:12:37 P.M. Central Daylight Time
. ,~ ,
From:
To:
According to the fist sent out, Mr. Spiegel is representing Mr, Walls and Mr. Scanlan. This is my second
notification I have not received a response.
In a message dated 7/9/2010 5:49:08 P.M. Central Daylight Time, Angelica37@aol.comwrites:
Thank you -
I believe you are also representing a couple of additional candidates? I have only received
this one.
Thanks,
Sharon
In a message dated 7/9/2010 5:27:59 P.M. Central Daylight Time, andrew.spiegel@gmail.com

writes:
ISharon:
Here is the consolidated motion on behalf of the Libertarian Candidates
Copy was already sent to the hearing Officer.
Andrew B. Spiegel
Monday, September 20,2010 America Online: Angelica37

Page 1 of1
Subj: Sharon Meroni Response to Carl E. Officer

Date: 7/15/201012:19:54 P.M. Central Daylight Time
From:
Reply-to:
To: t
I never received in themail.Mr. Officer's response. Not knowing what to'do, Lhcve responded
without it and ask that I be allowed to amend my response ... if needed.
Also, should I snail mail this to Mr. Officer? I do not have a fax.
Please contact me if there are any issues.
God Bless,
Sharon
(So)
Monday, September 20, 2010 America Online: Angelica37
1
STATE OF ILLINOIS )
) SS
COUNTY OF COOK )
STATE BOARD OF ELECTIONS SITTING AS THE DULY CONSTITUTED STATE

OFFICERS ELECTORAL BOARD
STATE OF ILLINOIS
IN THE MATTER OF: )

SHARON ANN MERONI )
Objector, )
VS. )
)
JEFF TREXLER ) 10 SOEB GE 524
MICHAEL L. \iVI-IITE ) 10 SOEB GE 532
GARY DUNLAP ) 10 SOEB GE 533
LOUIS COTTON ) 10 SOEB GE 534,
TIMOTHY BECKER } 10 SOEB GE 535
DA \-\TN CZAR.NY' } 10 SOEB GE 541
)
BILL MALAN ) 10 SOEB GE 526
JAMES PAULY ) 10 SOEB GE 527
JOSH HANSON ) 10 SOEB GE 528
jUILEFOX ) 10 SOEB GE 529
MIKE LABNO } 10 SOEB GE 530
ED RUTLEDGE ) 10 SOEB GE 543
LEX GREEN ) 10 SOEB GE 544
}
GREGG MOORE } 10 SOEB GE 525
)
CARL E. OFFICER } 10 SOEB GE 537
}
STEPHEN F. ESTILL ) 10 SOEB GE550
)
'W1LLIE BOYD,JR. ) 10 SOEB GE 553
Candidates. )
EXCEPTIONS TO THE HEARING OFFICER'S Al'JD GENERAL COUNSEL'S

RECOMMENDATION TO GRANT MOTIONS TO STRIKE Al~D DISMISS (Al~D/OR
FOR SUMMARY JUDGMENT)
A.ND MOTION TO DISMISS THE RECOMMENDATIONS OF THE HJ:<ARING
OFFICER AND GENERAL COUNSEL
This matter comes before the State Board of Elections as the duly qualified Electoral Board,
Now here comes the Objector, taking Exception to the Hearing Officer' and General Counsel's
1
2
recommendations to the Board to grant the Motions to Strike and Dismiss (and/or for Summary
Judgment) filed in the above referenced matters and filing this Motion to set aside the
recommendations.
1. Mr. Ken Wenzel is the Hearing Officer, Mr. Steve Sandvoss is the General Counsel who
have made recommendation in this matter to the ISBE through the SOES.
2. Verified Objector's Petitions were timely filed on June 28, 2010 with respect to each of the
Candidates. No one has claimed a lack of timeliness or found deficiency in the Objector's
Statement of Interest filed according to 10 ILCS 5/10-8
Any legal voter of the political subdivision or district in which the

candidate ... having objections to any certificate of nomination or
nomination papers or petitions filed, shall file an objector's petition
....
The obj ector's petition shall give the obj ector's name and residence
address, and shall state fully the nature of the objections to the
certificate of nomination or nomination papers or petitions in question,
and shall state the interest of the objector and shall state what relief
is requested of the electoral board.
3. The Objector's Statement of Interest states the Objector's
" interest in filing the following objections is that of a citizen

desirous of seeing to it that the Illinois and US Constitutions are
upheld, laws governing the filing of nomination papers for a candidate for
election to the office of are properly
complied with and/or that only a qualified candidate would appear upon the
ballot as a candidate for said office."
4. Neither of the Recommendations addresses the Constitutional issues raised in the

Objector's Statement of Interest.
5. The two Recommendations seek to circumvent the Objectors Standing and therefore
'Interests' without legal cause and without finding insufficiency in the Objector's Interest
which is in the Spirit and Intent of all Election Law as set out in the Illinois and US
Constitution.
6. The Objector takes strong exception and makes strong protest to the Illinois State Board of
Elections that her Civil Rights are violated by their lack of governance in this matter.
Elections that her various US and Illinois Constitutional Rights are violated by their lack of
governance in this matter. (Especially, but not exclusively, US Bill of Rights, Illinois Bill of
Rights, Illinois Article III, Section 3 & 4)
8. The US and Illinois Constitution requires all Candidates for office be US and Illinois Citizens.
The Soard refuses to permit any process by which Objectors can exercise their (her) right to
Object and/or verify "Legally Qualified" during the 5 day period.
2
3
9. The Hearing Officer and General Counsel seem to believe the Petitioner is magical and can
produce evidentiary testimony when the process and those administrating it refuse to
require it.
10. The Recommendations fail to address critical Civil Rights Issue and seek to dismiss without
merit the Objector's uncontested Interest to uphold the Laws and the Constitution.
11. The Objector has claimed her Civil Rights are violated by the Board's, and it's lawful agents,
lack of correct governance and refusal to act upon their oath to uphold the US and Illinois
Constitution.
Civil Rights violations exist because there is no way for the Objector to identify the
qualifications of candidates except to use "Profiling" evidence.(See Exhibits from the Meroni
Response) Also this example is clearer shown in a recent related issue in Missouri ( Hector
Maldonado candidate for US Senate Letter on Scribd and Mr. Maldanado on video declaring
his Civil Rights were violated)
12. Civil Rights violations exist because the issue places an unnatural tension between the
Candidates running for office and those that wish to object when no evidence is available to
objectively evaluate that candidate.
13. Civil Rights and Due Process violations exist based on a lack of legal statutes that prove
"Must and Shall" constitutional qualifications for the position applied for are met, and
because of the lack of an official process by which Candidates - who are almost always
more than willing to prove their Citizenship - can in fact prove their qualifications.
14. Due Process violation: The only party that has access to the information affirming Legally
Qualified is the candidate.
15. The Hearing Officer in refusing to hold hearings, had deprived the Objector's uncontested
Standing and Interest to examine the Candidate's claims of being Legally Qualified.
16. The Recommendations claim:
" The Objector does not raise, reference or cite any requirement under the
Illinois Election Code indicating that the Candidates must provide the
proof she desires to see, and there is no allegation as to any specific
Election Code requirement(s) which any of the Candidates are alleged to
have violated with regard to the Petitions."
17. RESPONSE - The Objector's Petition lays out the full objection as she understands it.
There is no proof of the Candidate's affirmation available in the public record. The Objector
can not specify a deficiency without alleging information that she has no way to acquire,
especially during the brief 5 day objection period.
18. RESPONSE - That Recommendation (above) violates various Illinois and US Constitutional
rights, not exclusive to, but especially Due Process.
19. RESPONSE - The recommendations do not argue that there is another path by which the
information could be obtained.
3
010
4
20. RESPONSE - The Hearing Officer fails to find the Objector is deficient in her claim that
insufficient evidence exists in the nomination papers, only that she could not produce what
does not exist in the public record.
21. RESPONSE - The Recommendations do not argue she is not entitled to the information,
only that procedurally there is no process to provide it - Establishing the Board's deficiency.
22. RESPONSE - Fails to state that the Board is not required to provide information proving
legally qualified - only that it has not done so.
23. RESPONSE - The Objector makes her Objection to each candidate, not based on non-
existent code but on the USA and Illinois Constitution to which the Board and all of its
Agents, Codes and Rules must answer to and uphold.
24. RESPONSE - The Objector cannot refer to some law or rule that does not exist.
25. RESPONSE - The lack of.existence of a law, rule or regulation to prove constitutional
eligibility is not the fault of the Objector, but it is the responsibility of the IBSE in its
Administration role.
26. The Recommendations Claim:
and .,. shall state what relief is requested of the electoral board. H
"Each of the Candidates signed standard forms of Statement of Candidacy which

included, verbatim, the language averring to their qualifications for office
that is required under Section 10-5 of the Illinois Election Code (10 ILCS
5/10-5) . Those averments are unrebutted, and nothing could be presented by
the Obj ector within the proper scope of hearing the Obj ections that would
rebut them."
27. RESPONSE - I cannot rebuke statements without a public record to do so.
28. RESPONSE - Relief requested is
WHEREFORE, your Objector respectfully requests that the petition papers of

__________________________________ , as a candidate for
, be declared insufficient and not in
----~------~--~~----~--~--
compliance vri t h the laws of the State of Illinois
29. RESPONSE - When the Relief is granted, it is step 1 and step 2. If the Nomination papers
are insufficient, then the candidate is not placed on the ballot.
30. "The Candidate's nomination papers are insufficient because they

fail to demonstrate and/or provide documentation that the candidate
meets the constitutional requirements for office."
31. RESPONSE - The Objector petition is specifically phrased because the Objector is unable
to prove or disprove the Candidate's affirmation of being 'Legally Qualified" because no
evidence is available in the public record.
4
01 I
5
32. RESPONSE - The ISSE fails to provide a definition for "Legally Qualified" such that the
Objector can exercise her rights with Due Process.
33. Through the March 2010 TRO, (Meroni Vs Illinois State Soard of Elections) and the letter to
the ISSE (Exhibit 2) the Objector has openly informed the Soard and attempted to follow up
seeking to testify and or present these various deficiencies to the Soard.
34. The Objector takes particular issue with the Hearing Officer's blatant attempt to mis-
characterize her legally filed response to the Candidates listed above as rambling and not
related to the matter. The Hearing Officer makes this statement devoid of any cause of Law
or without citing any evidence, attempting to prejudice this process without proving his
ridiculous affirmation. He makes this statement clearly demonstrating he does not grasp the
constitutional issues raised, or without demonstrating any respect to the Citizen's rights and
the tremendous effort involved in these Objections -
35. Also without cause of evidence to prove his claim the Hearing Officer places the following
unsubstantiated statement into the Public Record.
The Objector appears to have some passing awareness that there are
longstanding legal remedies provided at law should an unqualified person
somehow be elected (e.g. quo warranto) and that the law provision for
dealing with the situation (e.g. the doctrine of de facto officers) but
finds them unsatisfactory.
36. This statement is presented without proof and is prejudicial to the process, clearly trying to
shift the burden of responsibility from wherein it currently remains, with the ISSE and its Agent
Mr, Menzel and Mr. Sandvoss who have the responsibility, as their Oaths require, to uphold
the US and Constitution.
37. Objector was told in the March 2010 TRO testirnony.tjvleroni V ISSE) by your counsel,
Mark Ishu, that she had to exercise her options through ISBE Administrative processes (see
transcripts from the Court Proceedings)
38. The Objector went through the procedures and has standing and is still denied access to
any information whatsoever establishing the Legal Cause to claim the candidates are legally
qualified ..
39. FURTHER RESPONSES - The ISSE incorrectly identified Mr Gregg Moore, Mr. Stephen
Estill, Mr. Carl Officer as having filed "Motions to Strike and Dismiss" when they did not file
these Motions.
40. RESPONSE - The Hearing Officer failed to rule on the specific motions by the various
parties. Specifically, the Hearing Officer and General Counsel failed to address the filings of
Mr Gregg Moore, Mr. Stephen Estill, Mr. Carl Officer.
41. RESPONSE - The Hearing Officer and General Counsel erred in their assessment of the
filings of Mr Gregg Moore, Mr. Stephen Estill, Mr. Carl Officer.
OiL 5
6
42. RESPONSE - Contrary to Illinois code 10 ICLCS 5/8 - 8 and legal bindings and
responsibilities
(Specifically, the clerk s duty is to determine whether, upon the

face of the petition, it is in compliance with the law. Dillon, 266
Ill. at 276.)
The ISBE does not use Apparent Conformity Standards to vet applications and now
provides no way for the citizenry to do so either.
43. The ISBE fails to set or post clear Apparent Conformity Standards so the public understand
what qualifications the Applicants on the Ballot have.
44. The ISBE Fails to have any Apparent Conformity Standards and in direct opposition to it's
responsibilities
45. The Board of Elections fails to provide a definition for 'legally qualified' creating a due
process violation for the petitioner who wishes to challenge the legal qualifications of the
candidates
46. No Candidate's (listed above) papers provide evidence that the Candidate is legally
qualified. Therefore the Objector has offered each candidate the opportunity to prove they are
citizens, and then she will withdraw her objection.
47. Rule /I-B and E Objections to Circulators provides the "Competent evidence" may be
presented to prove eligibility. Yet no such rule specifies "competent evidence" that will prove
the same standard for Candidates.
48.4 Candidates have provided proof of citizenship: These candidates' objections were
removed.
49. The Objector moves to
1) Set aside/Deny the Motions to Strike and Dismiss of the candidates for the Constitution
Party and the Libertarian slate, along with Mr. Boyd and to allow Hearings to proceed as
required to establish Constitutional eligibility of the candidates.
2) Set aside the Hearing Officer's bizarre recommendations as relates to motions never
filed by Mr. Moore, Mr. Officer, and Mr. Estill.
3) Request all candidates objected to voluntarily submit proof of Citizenship, with a raised
seal birth certificate or naturalization papers. This will reduce the need for further
litigation
4) The Hearing Officers unsubstantiated statements in point above (34 and35) be stricken
from the record for a lack of proof.
Respectfully Submitted,
SHARON A MERONI PRO SE
/
STATE OF ILLINOIS )
) SS
COUNTY OF COOK )
STATE BOARD OF ELECTIONS SITTING AS THE DULY CONSTITUTED

STATE OFFICERS ELECTORAL BOARD
STATE OF ILLINOIS
IN THE j\tV\ TTER OF: )

SHARON ~i\JN MERONI )
Objector, )
vs. )
)
SHON-TUAN "SANTIAGO" HORTON ) 10 SOEB GE 531
WILLIAM WALLS III ) 10 SOEB GE 538
COREY DABNEY ) 10 SOEB GE 539
EDWARDJ. SCANLON ) 10 SOEB GE 540
Al"\fDYMARTIN ) 10S0EBGE549
)
CHRISTOPHER PEDERSEN ) 10 SOEB GE 542,545,546,547,
) 10 SOEB GE 548,551 and 552
Candidates. )
EXCEPTIONS TO HEARING OFFICER'S RECOMMENDKrION TO INVOKE RULE 4

SUA SPONTE AND TO STRIKE OBJECTIONS IN THEIR ENTIRETY
This matter comes before the State Board of Elections as the duly qualified Electoral Board.
Now here comes the Objector, taking Exception to the Hearing Officer' and General Counsel's
recommendations to the Board to invoke Rule 4 - Sua Sponte filed in the above referenced
matters:
1. Mr. Ken Wenzel is the Hearing Officer, Mr. Steve Sandvoss is the General Counsel who
have made recommendation in this matter to the ISBE through the SOEB.
2. Verified Objector's Petitions were timely filed on June 28, 2010 with respect to each of the
Candidates. No one has claimed a lack of timeliness or found deficiency in the Objector's
Statement of Interest filed according to 10 ILCS 5/10-8
Any legal voter of the political subdivision or district in which the

candidate ... having objections to any certificate of nomination or
nomination papers or petitions filed, shall file an objector's petition
._.The objector's petition shall give the objector's name and residence
address, and shall state fully the nature of the objections to the
certificate of nomination or nomination papers or petitions in question,
o\Lf 1
and shall state the interest of the objector and shall state what relief
is requested of the electoral board.
3. The Objector's Statement of Interest states the Objector's
" interest in filing the following objections is that of a citizen

desirous of seeing to it that the Illinois and US Constitutions are
upheld, laws governing the filing of nomination papers for a candidate for
election to the office of are properly
complied with and/or that only a qualified candidate would appear upon the
ballot as a candidate for said office."
4. Neither of the Recommendations addresses the Constitutional issues raised in the

Objector's Statement of Interest.
5. The two Recommendations seek to circumvent the Objectors Standing and therefore
'Interests' without legal cause and without finding insufficiency in the Objector's Interest
which is in the Spirit and Intent of all Election Law as set out in the Illinois and US
Constitution.
Elections that her Civil Rights are violated by their lack of governance in this matter.
Elections that her various US and Illinois Constitutional Rights are violated by their lack of
governance in this matter. (Especially, but not exclusively, US Bill of Rights, Illinois Bill of
Rights, Illinois Article III, Section 3 & 4)
8. The US and Illinois Constitution requires all Candidates for office be US and Illinois Citizens.
The Board refuses to permit any process by which Objectors can exercise her right to Object
and/or verify "Legally Qualified" during the 5 day period.
9. The Hearing Officer and General Counsel seem to believe the Petitioner is magical and can
produce evidentiary testimony when the process and those administrating it refuse to
require it.
10. The Recommendations fail to address critical Civil Rights Issue and seek to dismiss without
merit the Objector's uncontested Interest to uphold the Laws and the Constitution.
11. The Objector has claimed her Civil Rights are violated by the Board's, and it's lawful agents,
lack of correct governance and refusal to act upon their oath to uphold the US and Illinois
Constitution.
Civil Rights violations exist because there is no way for the Objector to identify the
qualifications of candidates except to use "Profiling" evidence.(See Exhibits from the Meroni
Response) Also this example is clearer shown in a recent related issue in Missouri ( Hector
Maldonado candidate for US Senate Letter on Scribd and Mr. Maldanado on video declaring
his Civil Rights were violated)
2
Ols
12. Civil Rights violations exist because the issue places an unnatural tension between the
Candidates running for office and those that wish to object when no evidence is available to
objectively evaluate that candidate.
13. Civil Rights and Due Process violations exist based on a lack of legal statutes that prove
"Must and Shall" constitutional qualifications for the position applied for are met, and
because of the lack of an official process by which Candidates - who are almost always
more than willing to prove their Citizenship - can in fact prove their qualifications.
14. Due Process violation: The only party that has access to the information affirming Legally
Qualified is the candidate.
15. Incredibly, the Hearing Officer and General Counsel argues against themselves in these
recommendations. Claiming on one hand the Objector cannot contest the SOC because she
does not prove the lack of veracity in the SOC signature affirming legally qualified, yet
agreeing to place Mr. Pedersen on the ballot without any Statement of Candidacy signed.
"Each of the Candidates signed standard forms of Statement of Candidacy which included,
verbatim, the language averring to their qualifications for office that is required under Section
10-5 of the Illinois Election Code (10 ILCS 5/10-5). Those averments are unrebutted, and
nothing could be presented by the Objector within the proper scope of hearing the Objections
that would rebut them."
Mr. Pedersen has not averred to possessing the correct credentials and therefore his papers
CLEARLY"fail to demonstrate and/or provide documentation that the
candidate meets the constitutional requirements for office."
16. Mr. Sandvoss informs the Objector on 8/05/10 that contrary to IL Code, the ISSE does not
use any Apparent Conformity Standards. This necessitates all issues related to candidate
placement must be addressed through Objection. Yet, incredibly they recommend approving
a candidate (Mr. Pedersen) who clearly has not affirmed he is eligible. The Hearing Officer in
refusing to hold Hearings has deprived the Objector's uncontested Standing and Interest to
examine the Candidate's claims of being Legally Qualified.
17. Rule 11-8 and E Objections to Circulators provides the "Competent evidence" may be
presented to prove eligibility. Yet no such rule specifies "competent evidence" that will prove
the same standard for Candidates
18. The Objection to Mr. Horton was removed on July 21st. 2010.
19. RESPONSE - The Hearing Officer fails to find the Objector is deficient in her claim that
insufficient evidence exists in the nomination papers, only that she could not produce what
does not exist in the public record.
"The Objector does nol raise, reference or cite any requirement under the Illinois Election Code
indicating that the Candidates must provide the proof she desires to see, and there is no
allegation as to any specific Election Code requirementts) which any of the Candidates are
alleged to have violated with regard to the Petitions. "
of ~ 3
20."The Candidate's nomination papers are insufficient because they
meets the constitutional requirements for office." This is the deficiency.
The only way to resolve it is through the hearing process.
21. RESPONSE - The Objector's Petition lays out the full objection as she understands it.
There is no proof of the Candidate's affirmation available in the public record. The Objector
can not specify a deficiency without alleging information that she has no way to acquire,
especially during the brief 5 day objection period.
22. RESPONSE - That Recommendation (above) violates various Illinois and US Constitutional
rights, not exclusive to, but especially Due Process.
23. RESPONSE - The recommendations do not argue that there is another path by which the
information could be obtained.
24. RESPONSE - The Recommendations do not argue she is not entitled to the information,
only that procedurally there is no process to provide it - Establishing the Board's deficiency.
25. RESPONSE - Fails to state that the Board is not required to provide information proving
legally qualified - only that it has not done so.
26. RESPONSE - The Objector makes her Objection to each candidate, not based on non-
existent code but on the USA and Illinois Constitution to which the Board and all of its
Agents, Codes and Rules must answer to and uphold.
27. RESPONSE - The Objector cannot refer to some law or rule that does not exist.
28. RESPONSE - The lack of existence of a law, rule or regulation to prove constitutional
eligibility is not the fault of the Objector, but it is the responsibility of the IBSE in its
Administration role.
29. RESPONSE - I cannot rebuke statements without a public record to do so.
30. RESPONSE - Relief requested is
WHEREFORE, your Objector

respectfully requests that the petition papers of
, as a candidate for
--------------------------------- , be declared insufficient and not in
----~----~~----------~~---
compliance with the laws of the State of Illinois
31. "It should further be noted that the Objector asks that the Board declare Candidates' Petitions
"insufficient and not in compliance with the laws of the Slate of illinois" but does not ask that
the Candidates names be removed from (or otherwise not be printed on) the November 2,
2010 General Election ballot. " (Menzel)
32. RESPONSE - When the Relief is granted, it is step 1 and step 2. If the Nomination papers
are insufficient, then the candidate is not placed on the ballot.
or} 4
33. "The Candidate's nomination papers are insufficient because they
meets the constitutional requirements for office."
34. RESPONSE - The Objector petition is specifically phrased because the Objector is unable
to prove or disprove the Candidate's affirmation of being 'Legally Qualified" because no
evidence is available in the public record.
35. RESPONSE - The ISSE fails to provide a definition for "Legally Qualified" such that the
Objector can exercise her rights with Due Process.
36. Through the March 2010 TRO, (Meroni Vs Illinois State Soard of Elections) and the letter to
the ISSE (Exhibit 2) the Objector has openly informed the Board and attempted to follow up
seeking to testify and or present these various deficiencies to the Board.
37. The Objector takes particular issue with the Hearing Officer's blatant attempt to mis-
characterize her legally filed response to the Candidates listed in terms related to racism
when she specifically objects to this process as violating her Civil Rights.
"That provision in Rule 4. of the Rules was added after the 2008 election cycle, following the
filing of certain objections based upon the utterly untenable assertion that non-white persons
ought not be permitted to run for office. The Objections at issue here do not assert a
proposition as socially offensive as the prior matter, but they are equally untenable as a matter
of the applicable law."
"The Objector herself appears to be totally sincere and earnest in presenting the Objections.
However, as legal pleadings, the Objections can only be characterized as entirely frivolous"
The Hearing Officer thinly concealed racist related remark claims to add weight to the
argument that the Objector's petition similarly lacks merit. The Objector vehemently
DENOUNCES Mr. Menzel and Mr. Sandvoss for this OBVIOUS political ploy!
This statement clearly demonstrates neither grasp the constitutional issues raised, or
without demonstrating any respect to the Citizen's rights and the tremendous effort involved
in these Objections -
38. Objector was told in the March 2010 TRO testimony,(Meroni V ISSE) by your counsel,
Mark Ishu, that she had to exercise her options through ISBE Administrative processes (see
transcripts from the Court Proceedings)
39. The Objector went through the procedures and has standing and is still denied access to
any information whatsoever establishing the Legal Cause to claim the candidates are legally
qualified ..
40. RESPONSE - Contrary to Illinois code 10 ICLCS 5/8 - 8 and legal bindings and
responsibilities
(Specifically, the clerk s duty is to determine whether, upon the

face of the petition, it is in compliance with the law. Dillon, 266
5
Ill. at 276.)
The ISBE does not use Apparent Conformity Standards to vet applications and now
provides no way for the citizenry to do so either. NO such standards were used on Mr,
Pedersen.
41. The ISSE fails to set or post clear Apparent Conformity Standards so the public understand
what qualifications the Applicants on the Ballot have.
42. The ISSE Fails to have any Apparent Conformity Standards and in direct opposition to its
responsibilities
43. The Board of Elections fails to provide a definition for 'legally qualified' creating a due
process violation for the petitioner who wishes to challenge the legal qualifications of the
candidates
44. No Candidate's (listed above) papers provide evidence that the Candidate is legally
qualified. Therefore the Objector has offered each candidate the opportunity to prove they are
citizens, and then she will withdraw her objection.
45.4 Candidates have provided proof of citizenship: These candidates' objections were
removed.
46. The Objector moves to
1) Set asidelDeny - and to allow Hearings to proceed as required to establish Constitutional

eligibility of the candidates.
2) Set aside the Hearing Officer's bizarre recommendations specifically as relates to Rule 4
- Relating to Mr. Pedersen and all other candidates on this motion, who have failed to file
any response proving or disproving their qualifications
3) Request all candidates objected to voluntarily submit proof of Citizenship, with a raised
seal birth certificate or naturalization papers. This will reduce the need for further
litigation
4) The Hearing Officer's unsubstantiated racism remark and remark related to frivolous be
stricken from renounced by the Board and removed from the record.
Respectfully Submitted,
SHARON A MERONI PRO SE
6
257. An Injunction enjoining the State Board of Elections from certifying new voter registration
applications until procedures are put in place correcting the current deficiencies outlined here.
258. Any and all other relief the court may deem appropriate
259. List of Exhibits:
Exhibit 1 Katherine Schultz questions 1-14
Exhibit 2 Katherine Schultz email questions 1-3
Exhibit 3 Katherine Schultz certified affirmation
Exhibit 4 Willard Helander's Answers 1-17
Exhibit 5 Willard Helander's certified statement
Exhibit 6 Mark Shelden Questions 1-17

(Certified statement pending arrival)
VERIFICATION OF CLAIMS
The Statements and Claims made herein are the statements and claims ofthe petitioner's and
those statements incorporated herein of others as part of the public record concerning these matter. On
oath and subject to the laws of perjury, the undersigned petitioner affirm and assert that the preceding
allegations and factual statements, including those factual statements alleged on information and belief
are true to the best of her knowledge, and that she has asserted these claims, being legally competent to
testify to these matters, and having acted voluntarily without promise of payment or by threat; in good
faith and based upon her understanding of the United States Constitution and the Illinois Constitution,
and the duly enacted laws which spring there under.
On my sacred honor and in witness before my Lord God.
xxxxxx XXX XXXXXX (AKA CHALICE JACKSON)

AND FOUNDER OF PATRIOT'S HEART MEDIA NETWORK,
IT'S DOL Y AUTHORIZED REPRESENTATIVE
Petition for Injunctive Relief It's a Republic, if you can keep it" Benjamin Franklin
A frequent reoccurrence to the fundamental principles of civil government is necessary to preserve the blessings of liberty. These blessings
cannot endure unless the people recognize their corresponding individual obligations and responsibilities. (Article 1, Section 23 IL Cons.)
24
Dear Katherine,
i wish to express my appreciation for your willingness to help Mary end me learn about the election
system; especially as relates to McHenry County, but also in reference to state and national elections.
; learned a great deal in speaking with you. I wish to clarify some of the information. I would like to
include this information in the EMERGHJCY petition consuming my attention at this time. The last
opportunity I had to speak with Judge Prather, she specified I needed to include details. Thus, there ar·e
a few points, I want to be specifically clear about. Numbered, I post them below.
References to specific codes are appreciated as well as any other information that might help to
illustrate the election process.
1) Please briefly list the process by which a candidate gets on the ballot in McHenry County.
A candidate is required to file petitions papers, with the required number of signatures, a statement of
candidacy and would also possibly file a loyalty oath during the prescribed filing period
2.) What documents are required of a candidate to prove constitutional eligibility to be on the
ballot?
No proof required - Statement of Candidacy form states "qualified voter" and "!egally qualified to hold
such office"
3) Please specify how election law and related processes verifies the constitutional eligibility of a
candidate for office.
To the best of my knowledge verification is not required and is not part of the filing procedures
4) What statement or oath is required of candidates swearing eligibility'
.f:!" loyalty oath is optional. The Statement of Candidacy does state that the candidate is a "qualified
voter" and "legally Qualified to hold such office". The candidate must sign said form and his/her
signature must be notarized
5) How is the citizenry notified of potential candidates for the ballot during the qualification
period?
NO notification is required McHenry County posts all filings received in the County Clerk's office on the
Clerk's website. Normally newpapers will also report filings as part of their new coverage
Petition for Injunctive Relief It's a Republic, if you can keep it." Benjamin Franklin
25
021
a. Vvhat process is available for a citizen to contest a candidate's eligibility for office during
that period?
Filings are public record and are open for inspection during normal business hours. There is a
set time for filing objections to candidate petitions
b. What avenues are available to a citizen questioning a candidate's eligibiHty after that
time period?
After the objection period has passed, and no objedions are filed, a candidate is placed on the ballot
6) In the authority of your office and after the above mentioned contest period, should you
question if a candidate is constitutionally eligible for office, what election law empowers you to
investigate your suspicion?
This is a legal question and would need to be researched. My roll in filing petitions is basically
ministerial
7) \Nhen an election has occurred. vote tallies completed. is there a process then for which a
candidate is verified as constitutionally eligible for the office?
I am not aware this is a requirement. There is no process in place to my knowledge
8) In the Illinois and Federal election processes that you are familiar with, are there procedural
differences such that names submitted for ballots in Mc+lenrv County from State and Fede-ral
sources, a re verified as constitutionally eligible for office?
You would need to speak or check with other sources as to their procedures. i arn not aware of any law
requiring verification
9) One requirement for candidacy is voter registration. Please explain the ways voters are
registered in Illinois. \:Vhat documents are required to esracnsn age, crnzerisntp and resrdence>
There are different methods of voter registration: County Clerk's office, deputy registrars, drivers
license facilities, agency registrations and mail in registration being the majority. All ask for age, proof is
not required. Place of birth is asked for by the Clerk's office and by deputy registrars. Proof is not
required. Registrants born outside of the US are asked for additional naturalization information. Voter
registration done at drivers license facilities and agencies are asked if they are citizens and sign an oath
that they are, and mail in, simply sign an oath attesting to citizenship. On registrations done through the
Clerk's office and/or deputy registrars, 2 forms of 10 are required, both with the registrants name and 1
with his/her current address. Keep in mind that registration sources, other than the County Clerk',
Petition for Injuncti ve Relief It's a Republic, if you can keep it." Benjamin franklin
26
022-
office and/or deputy registrars and applications to register and if any information is not received or if
the voter iO card is returned undeliverable the registration application is not accepted.
10) Are there voter registration processes in use right now, that does not require potential voters to
swear to place of birth and that they are US citizens authorized to vote?
All require the oath of citizenship. Only Clerk's office and deputy registrars require place of birth
11} As an overview only, and as possible, please describe an instance within the current system
where citizens have unknowingiy been registered to vote through the State Driver's iicense
registration process.
We have occasionally had registrations that have been processed and later the registrant has requested
removal because they are not citizens. I have never seen one, where someone has voted on these
raquests for removal
12) In the voter registration process, how is citizenship status verified? What code authorizes the
process for verifying citizenship status of a registered voter?
Citizenship is not verified and I am not aware of any requirement and/or authorization to do this
13) If a voter comes to the poll, and there is a question of his identity or registration status, by what
means is the voter's right to vote accommodated during the voting process?
There is a challenged affidavit to fill out and verification and/or proof required
14) Please include any other information you think might assist the Court in understanding the
process of verification of eiigibility of candidates for ballots in McHenry County and the citizens
entitled to vote in McHenry County. Information, especially as relates to vulnerabilities in the
system which may allow ineligible participants to engage in the election.
I think all of my answers have stated the requirements and processes as I am aware of them
A frequent reoccurrence to the fundamental principles of civil government is necessary to preserve the blessings of liberty, These blessings
27
02-3
From; •. I II
Sent: Saturday, January 02,20109:16 AM
To: co untvclerk-Mfs
cc. II .
' ·"a·t',·~ Schultz,i
".v , ':;' .......••
Subject: FW: Thank you!
t>,/ly eni;,d server sent noti(e that this en13;J 'iJas not dpEvpred rhus,! fe-senff it .vith hopes it g0P~ thl t)ugh th!':,:.
tiHlei
ho~ 7
Sent: Friday, January 01, 2010 2:01 PI.,
To: lkcschuit:.9}co.rnchenrv. H.us'
cc:. £ _ .
sUI)Ject: ! hank you'
ko rh.e
I ~\i{tnt to tncnk '!'OU for t";.::. graciousnes8 of your ~·e5PGnsc:. I must admrt +c VDu. rt made me. cr~.. ';""~':r(;Ly -'1
c.ppr2.ciot!on fer YOloW wor-k.
<nowlcds~ of the c.ec+ion proces s or iGd< there-of, is a }m~gE- contributor' to ~")ar;";e""sin the vC·fing
prcr.css. :::hove expE..-rl{;.ncec i'ho-rve~'Y- p ersonc llv as I nave mo oe i1",V v.:ay tn--ovgh tr is pr-ocess. I h':l~/~~
pn:·f~un.:i r-cspec+ for the way lv\cHenry Caunty reaches out TOthe, common ci<zenrv ;15Sist!og us .. L sow
in your -e.sponse TO Mc.,~\,one me. end I' see it at the (-:our"i' le ve: which mcke s regal r e sour ccs succ.nc t lv
OVCd0bi·;:;,
to uS the.. common foiks: Hcv1ng now had the opportunity to rnee!' you for' -:ht: t=jr's-t ti!ne r ~nO\l-;
f;r'$-tncr.d 'that-:t is Q value of yours- such t ho." vou ie-cd vour of":!cc +c engage wdi-! t he citizen:; sc ')pcr;iy.
Thon-k youHT
':~h~'f'Caodi1'·:ona1 que-sticf1S have COfTle ":"0 mind.
1) l~Url1'19 the "5 day Contest Pe:~~c-a:Jf-or bcllor quallficcTion, does ,\t$:HEnr"!' Coun-y post nc'!'r;:(: of
candidates for ell StaTe. and Federal o ff iccs
10.10 nCT_ I beileve th0.t the SHE posts c ll filings r hc+ ore done o t their c~f!ce
2) Speclf,caliy. was B""DCk Otomno 5taier.-,,,r;' of Cond,.e:wcy postea fo" t",e $5 Pn,siGent,,,, "'ee'iC," trt
20CE? An.;:;l if ~Q, rvicv :r p Ic c s e know wi-ere:.
T would ~rno.gin€."rha! post r"9 of his filing wns done but ugo;n it would [,,01 be. done 0)-'~h!s o-.ffiCC
3) 4.r'c yo!...: CWQr"c ·f cny IDe. : r-.Je1li5p~1.per'$ pc s t e d the ~nfor-hlat;on ;}f /'.;\r Obat'0o's Statem('~nT of
Conei! due 'i dunng ..•.
~le (:DnT€.st pe;-iod"')
T WOUld rhit1Y that the P:-lfJf?rs would have ~jo"\ec0ve,''Jge on t~1:5 +dlng bur oguin rt L$ noi soml:'".:rhm9 thiS
o~fic2 !.l,lm,id iTac\<:
A frequent reoccurrence to the fundamental principles of civil government is necessary to preserve the blessings of liberty, These blessings
28
I(illht'rille SChlJiL'
M(llcnry C.ounly (IPIk
6(,/ Wlllt.' Hd,
\NuocJstuck, It. Gl10 )S f
I \Vb.1I 10 tf t.rnk you to! fiJIjll;~ in tJw (pH·-;1ionn,:lfri~ rt,!!.l!"tl!nr, iHll( {,·.·..;P\In! vntpf n·I~I'-Ir·,)[ion ,;n!!
(.llldjd.ltt"'~ (,.pttiiu .ltlOIl in yO\U {·OUlHw'". I .un ill t tu- tin"tl ',t,W.t'.., of fHt>p.UIll!: mv ItltHI(}11 10 tilt' Lift wi
Cuurt, tlskill!; Ihl~ c cn rr t to e dtfr c-,-; thi.,., ic;\\H'. 1,1111hdPPY to plovidt'" (OPY' to holh OfYCIlI. ,H,d will ~h) 'M
one of tilt.' hiHrir-f<; rhill individual ci!i7t~ns h~lV(>in ,ldrlrp<;::;inj~ rn.HIPfCi nr \"Iflniticc.lnl plltliir: irllf'f(' ••r i.
..,
d{'IlHlll'.lTdtlllg Ih.II II i-,pi 'tj'.fldH .lllt pohlu 1111('"",\
I wUllld .tppl (.( 1.111'it If vou wcuud ~.I~:ntill.' ',i,lh'[lH'HI Iu-Iow ,HId I ('lilly YOIIl ~.W!l.HlJlI·_ ",\I{ h tlltl: lrn.tv
tIIfOtlH lilp Court Hl.)l VOII .it-,o 1('<'1tl u-, 111.1\1('(i-; oj ~.I!:n!ht.Hl{ pllhl!r IIltl'ft".:'
iil.Jnl... yOll, vI'ry nun hi
')h.lloo i\.4,:IUIIJ
i
1/
//
/k
Ir:lt.t-:''l.1?,y.1\L£. (b. ·Sc.. k(..(.., /t:«:..
J
,lll'.VVVlt'd.1 q\W,.IIOW1.lif~' fOf ~h.II\)j1 f\.-1.'!lllH,
(('(!anfillf~ the vote-r n~Hi~tr'Hiofl ,I/HI ranclici.Hf' flhn!~ nrU(f'iJt:fl", u'.('d ill the' ~ld!I'" of fllin(w., ,HH1 M(.!lens,{
County. ';HHi wil! tl·~tlf\, .)~ c.1Hl'd tor in .llw.niflf! on tilt- ni.rrt or .
A frequent reoccurrence to the fundamental principles of civil government is necessary to preserve the blessings ofliberty. These blessings
cannot endure unless the people recognize their corresponding individual obligations and responsibilities. (Article 1, Section 23 IT- Cons.)
29
TO the lake County Clerk:
I am attempting to understand the registration process and have prepared 17 questions. f really am
seeking your knowledge of the matter and i wish to include it in my case to testify about voter fraud in
lllinnis. McHenry County Clerk Katherine Schultz ..has answered the questions. It would be very
important to have a second Clerk's answers.
What I have done, is tracked the process of voter registration and the sac, including the 5 day law. My
case presents that these are unconstitutional and restrict the Clerk's ability to administer a fair election
because they fail to empower anyone to verify vs. certify. I understand Apparent Conformity and am
not trying to change that. I assert that access to all voter rights is apriori to citizenship verification.
I appreciate your input as an elected official, who speaks of her knowledge. I don't need long answers.
Thank you!
1) Please briefly list the process by which a candidate gets on the bailot in McHenry County.
l\li cdndidares in it are required to fiU.l. norrunaung papers In the -appropndtl::l offrr o i:, dC'(tlitL.:ili.Lf'
willI ',{dtt' !dV~,;flf.);dt~f to have thej( names lJ!dCeC1

on the ballot The non')lnallrlg pdpf:'r<,fi)r}'~I~t
)f d St at erne nt of Candidacy. Petilion Sfll.;l~ts with tht.? i op fdled in bv tt1€' Cnf1(tidat€ 3$ to the
n~H'np .:)f thl? ;_~'1r1i(1alE> aodr~(:.{., ort« p ~(Jught. p •artv ,-10(1term it .JopiJcdule dnd UPlf'f ."!ptIOf'td.i
[nrm s. Son·(l offices recPJire certiflf"dnOfllat;<,pc;;sor •.•tf) You can gp-'t,] lJ€'taih?d hOL)kh?t r'ut 011
uv !hl.: H SL~te [iOdrri of t:lectltHl:l on thpir wr-b site at htq.r//v.'ww.e!ec::-Ion"stilf?il LC,/
2) What documents are required of a candidate to prove constitutional eligibility to be on the

ha!JoP
No ft rrru-, pro v ,dl.JoU by "he Stdte Bnrtrd of F/pctI01''i "pf'(ifica!ty OeaJ with the stiJti-> or fpder:JI
COIIstltutinp. but the voter i-s reCiting thel,i art' d reill~lered voter in thp dr<..pic,-_ S.epdrdt~Jy the
t:lf"r-tion COlle "let<;. fort h tne (t?q:Jiren1e-nts that a pe"-~0n lh;) 18 ve ar s at fige. a US Clti!("n ann c1
'-I,:
•....
J!cipot ot thf~ prr-c incr for .30 at :11':: tinle at till'" next election. If y:}U read Ih~ ~tdtt>"1H'nt (:1
Candidacy YOl; ..vdl see d recrtat of the> element'" rnat the person is qUdlifie-d f(!f the offir e .
3) Please spe cifv how election law and related processes verifies the constitutional eligibility of a
candidate for office.
Yt,u Ili'r d l 10 hr> rnun::>',pecifiL as to your point w ha t i~ thi~ ortic e and I)Jhich (onj.t!tulIt1nal
rp.quirp!nt-nr .-!rp you asking about) An-" you referril''iF.to crtizenship ? voter regblfdtl\) Ii:, ft"d!!Y
an honor svstem in prdctic.ai terms. Spcondarilv. lhpre to;: • .:ln oath on thp anpuuariou f o r d uallor
l.wh(,th(~r voting by rna!l. early in per sun or on E!eLtiop Dav} that a vorer IS Iullv quallfip(i to
;.ret~;-stt:"H:d_ fiVif1~ ell the addres!", arid a r.it rz e n}. If i!lo 110-1<;13ted in clear, direct t er ms.
4) What statement or oath is required of candidates swearing eligibility?

Ac:. ~tatE,lLJabove, UH?oath is given when r~gi~terjng to vot e and thove regi<;Tering by mdiJ d .•.., qot
take Jt! (Jdth or shv'h 10, but' setf c.er ufv' they -tire thdt person and live ar that addr e sv.
Citi;?"?ns.hrp r c, n o t verified and the(f~ an:. no rpSOUfU'S 3vaiLabie to pif>ction Dffiodl'!. to veril',' it
';-,l0uid b(' rt21pful It thp stat e .•vovrfd run t he- s:!:HPwide VOter reg;~trdtion ddtabil~e dgdin·,t t·w 11:)[
30
of illegal residents i believe there have be-en proposals at the federal level for a state IFvel <ort
i:fgdin!>t I:legal lesi erus regi~lerll1g, Dorrt Ihifll<.. IL hd':J.got t en that far. but there mov b(~sorne
re oor ts by groups pointing out the benefit <.lnd risk (ACORN, SE1U.J
S} How is the citizenr'! notified of potentia! canoidates for the ballot during the qualification
period? Voters de no t receive any notice about pore ntiat candidacies during the filing period.
Once all candidates file there is a p "nod for Objections and anv persons mav inspect the fiiing
DdPPfS, purchase cop-es and make an appointment to view the list: of registered von=rs
d. what process 1$ availabte for a citizen to contest a candtdares ei!g!bility (or officE' during
that period') Se-e above. caveat, to bf" an objector, "d
rhe pe rso n must be a Cl)g:istpn ..
voter 111 the specific d.stric i and bp ··deslruus of se erng the- laws. of the state beirrg
upheld: t ~tandlng)
b.. What avenues are available to a citizen questioning a candrdares eligibility after that
time period? t.aw entorccme-nt and cfi!nindi investig..!tion -- verv rarp- to t~lk(' lt1l~p=>t
and allot alP invt"st!gr:ltOfS.
6} In the authority of your office and after the above mentioned contest period, should you
question if a candidate is constitutionally eligible for office, what election law or mechanism is
civailable to investigate your suspicion? SE'e 5 b ..There have ber-n numerous inst ance-s of
per~on5 who voted many U!11e; and f.ater appheu for citilen~hq) individuals havl? r orne to {)"r
office: and aske-d that voting history be purged ;Hld name n·)rTlov€'"d. vv e will canu"J rpgl-strriti(H"l at
votr-rs reoue sr. but do not remove history, Wp have no tnve stigato r s «n staff .Hld do not 0ftFtJ
get staff dedfCated ro r oncerns d~ mdnv c ther JTlCIf,;' prr-ssmg n('ed~
7,1 \fv'hen an etection has occurred, vote tallles completed, :5 there a process then for which a
candrdata IS verified as ccnstuunonanv 2ligible for tile office? NO. The only pfule~.s would be
c;orn('-'Qne roising thp is suo to flewspilper •• e nd 5tdte' Attorney. Attorney G~nel"a! ,elt.. \Vuuid
r e•.•.•ult In e n Ere c t io rr Coorevr.
Si Through State Board processes and Iega! authorities. if the election results are certified, is there
any point where constitutional e!igibility is verified rJSpart of that" process? Not to rnv
knuwtedge.
9) In the Uiinais and Federal ejection processes that you are familiar with ...are there procedural
differences such that names submitted for ballots in your County from State and Federal
sources, are verified as constitutionally eligible for office?
All st<'ltE= and federal otfu.es are certified to our office by the SBE. The- for m-, requirpd t o bl~ fih·-.,d
ore public re-cord and ale "5plf certifying' as In thp Prlt·tifirl1erH ~Ohr- rpf.istert"d i'lnn ro VOte" ..
registered in llIinQis .. \A/hat documents are required to establish age, citizenship and residence?
Petition for Injunctive Relief It's a Republic, if you can keep it» Benjamin Franklin
cannot endure unless the people recognize their corresponding individual obligations and responsibilities. (Article 1, Section 23 lL Cons.)
31
~\ in the voter regisrranon process, how is citizenship status verified? By wha t statute and (ode
outhorize s the process for con-firming citi2enship status of a registered voter) i-lor.l.'! "',-'lb.. ·n.
Thf're ,'i no vt)rif.callon requireo r:tnd in theory alloweo. There IS nor scce ss to tt)~ fi!t-'s hr1lld:'.
e nforcerne nr ano other agenCies fomod . It i••a orne f''''~ of r over YOlJr p·"es, "it"P 110 ..,.~:O'1p ~her
I: ele is r.o VUClllr'::
ld) If a voter cernes to the poll, and there is a question of his identity or registration status, by what
means is the voter's right to vote accornmodated dunng the voting process? A vct~Jr b rl'{pl!(I;'d
to SI)QW !D in 'he fol!(n.ving ~1r(un"l<";trtnn -'s
.. only.
<1.1p~iii.::l!,:rE'd by n"~~11
ano thd fiOt nrov-de 10 at time- maiipd !r -lppti':-lt'('HI r·,:1.IJ~:"how 2 niP! e--; nt
!lfl"Y 10with «idr _:,'"of regis:~;Hi"'-H
·~....!:,tc:[.r!!.:l.:-Is!:'.QJnoi!.[~{"p0'1 postal -.flr\.' c.P aunir -:J') r(," Ii ••..•Its .,t adj--p"-.5 "'",1 sl sl 0 .v 2 PI,> e-
rrl" Il} r.' th ddnr.:>c!,> nf fI.?B.·:;.~r;;l;,!r
',.1 (,Jl.f( p,-qV!~C-~ ~·l'ff~r-.e!H_d:_ddr~-sc;.--='Y!ll"ur-'l!!f_~l!!J.ft..d_l?~li(}J..

~__ JO (l' ;$ ,.~1"'~1.~t1
rHIO must -- ':hv ,;::
;:i~"'\.c"~ )f .11rf'flt·n ,th
,•.•.. the- ;;:H.fdrp~o;, of '·~~I')rrat,{if·.
r! ; \o·C.'eL r e, 1=jla !t.np•.t:>tlbi ud~(-U!_w itt}lex _Q~lthf'- "_Jt~_ .•...not '!'",."h: tIIlH; •.
r:;>~
••.fir 't'tl," tJq'
r-o t I 1 .ic !!"Ig.
III ,Ifly \·f thesl~ (ill..ldn'O.tances. It-the v 1!('f canoot p-o duce iO. tht=> vot er ~..
:1'1b,=",i!lo~\lf-'d d rHO\;:~IC 1;11
U._Jlli)r .o.;hicn ce n t be
IH...• (o -,t on Efertior- [Jay "'-\VO!p.~ nor f{llll1d ll.1g;sterpd h Jt wnom h£'ltt'VI.I', hl~ or
c.]•• I f "f:Sl€'r.::-n h,. ...
Ii-<.o vote a fJ'o v iS;..)r~cI bA!iot
...', During the "5 day Contest Period" tor ballot. qualificatio o, does your County post notice of
candidat e s fD-( aH Stare and Federa! offices? pre- (o.J rp.fprr,:ig to [!"If' '1f"ri.-H1 10r !")oj~·'...ti fI
(I I 111;dli·lg p(>tlill'f'~_ 'f so .111 CcH dIOdlt..'S INhn Lie dP o(J':)tt'd on o of wt.·tJ'-ile ".10!v. I! ,In
ct>W' t.C·fl ·5 tdco . t hat .s not ed 'Nt:'; do riof hav..- "forpl<HIO·l about --]odld<-1 ~s ding at tt.,- ~l:·f
nftlr~'t. lJotil (pq·tiC..-ItlOll 0 Ti~r •••
"(.J Specificaliy, \9;35a st aremenr of Candidacy posted to r-tile US presidenrinl etecuon in 2005 ~ And
if so, mav j p!p.asl..-: know where. W,, nover :.I=eflornilldting PdrH~; So inr {;lilliludll'':>. filirH! d~ ! I,t",
-,ldb1. fht' nn.h, furm we: re cv rve is .llL'lfifitdlioll f()rlll
1.7 i Are you aware if anv local f;Jel. ..vspapers posted the sac durmg the 5 day contest period for th0.
2008 primerv election? No. DCI nol 11;)(j.. thrs Illtopndt!Op. ·l'ht: !·e'u.!rd5- • pull!!';' ,Pid t<.lrt b(~
d l r..
;lb~<~inpu b-, oro ss (Ii noivllh.:al<;
32
---- -------- ----_. __._---- -----------------

!ll·i:, .•i:..: . "'("~!irl'Tnt-:;,1 -:-j! ;!r-:. -.o:(~;":ti(1r: f1.!1':'~ r);:-"S~-~'ii:<fj;'-:!-l·•..
'l.!-:!ln~·: C:': ~'!t-~ b!"!!L:-;; C-":;JPL;~C
:.•';~ "_'fH!;' t H 1: ',;','j ...•..·':-:'i.-·~: pl::.·~:.;(.::.~ d~_':~':'!.~J:1i i; !t-;;;t f .\:!V ~'1;~10.:: ,~C\.:·'d( d i.:.'[;"'i(;tt!
~··II'H, :l.n~~:.11!IH 1..:; i11:{"lf~,t(llE'r~
{J!i ;~~,: i;~hl ! 1'1.(1 L; {j;~' •. j~~·':\)ft!i J~:r:G(::;:.,1;-. !h~; '~\'~i.'~;·,}qt~·ti;1U\\jl ;,;1('\ ,,::.: .~..,/!; ;f'~'
'::l"';,~' ;;\[ ::j: l..::;:>!':": dn:·1 i::'l!r~;H1;, &'-':."1:-'~I'" t:h~.-·t:::;'....; \/:17\ f rt-''l::1' Vl!~f; il::'" t'~'.-!i!;H'
:...;:
:!~~~:,
.'..li:::'~~;~~v T:~! v :;~;' :1;,:" ;:,'1.';("1 ~': r1;1 i.~.1"q.(Js,L! d:l .i..»: ::~;:.!~!I.' ;~;-!iL~~\ '~{H'!~;-'..i.?
l' : :!'\.i : j ,! 'i' :..: ,I., .'- ,. ',1" ,.
,',Ii
" :'.n'~' . \ 'j ~';, I
1; "
; ,:'l!l,",P.v t·, ";l't! !i"1'·;1l.1!f'Y' 'lfj~·:,-'~i,;:t;:';l! ,! "~P;.: f ,;:~, ,L~l ';.d'~

d1l'.. !h \·'t"·:,(·! !i" .\-i'!·i,' ',<dtf .' "<ilr:~', ',1,.<:' ::t
"
'';r,·· '( "
'" 'I'{ d'; -,'f'; :,:-.:j 1"-' -j',;.:' ,:-~~P,}:') ~~_~:'d'-! "i." 'f;, ; ,:~'::);' l; ;(:. ji>,!~i. ~i ;; r ' i!' ;1',
'i',,:> r : •..
: ~:r·;'.I: ;:~'''_'!,:;.n~.! (.,'", '.'1~<·l;,.~·.· ~'~L': p. 'f,' i' ;:,' ,;".,,';"1' i ;"
!~'~:'f1tl\' '~'.:i;'· ! ~;'lt,'~-i :,li:-',·' rt-'cu::1~,;-;<l"~' ~"jil; ;)-.;. L, .li.:::( '1.- ,.j !~Il' ~.!',~i!:~'~:_1! -."jj;"
\!p;; .
.~; .
:;'. ("'~"",l~d\'1;l~ ,~q\' t.'! "qi/'~'·'·)~';'l:i.:!qt"r~ :~, L'\" ~!;,:~)..:-~p~;t.!. \, ~~~l:;>

{~Ot;::-~l·~' ;·t . ,;;qU!ft:' !;!'~~("'~
(:{ n, .;:'n;lr~.:\!J,}:·i t (i;'! ~n" '~;0: n·-·(~L·;l \ii';7
33
appncants need only indicate by oral statement that they were previously naturaiized or
that they were native born.
The mail-in registration form removes any requirement of a source document and any
element of verification. Interestingly. after years of being registered voters. individuals
have requested our office delete their voter registration record and delete the voting
history. These persons have further requested that they be given a letter staling they
are not registered for use as a part of federal court application for citizenship.
Nex1. consider the process of where the registered voter is actually voting. Whire tne
state is required to maintain a statewide registry of voters (deemed to provide detection
of duplicate registration in two or more districts). there is also no process to prevent
multiple registrations and voting in more than one jurisdiction. The statewide regis1ry is
managed on an ad hoc basis in the various jurisdictions. is not enforced uniformly, nor
IS it uniformly administered at the local level.
Example:
/\ voter registered in County f...
I year later. voter moved to County B and registered.
4 years later. voter returned to County A and registered again
lllinors system does not consistently require thai County B remove or mark as inactive
the voter on the list who moved back to County A, Procedures at the iocat levei are
inconsistent. Some jurisdictions send data to the statewide registry that reflects only the
first registration date. which in the example given would show a date prior to moving to
County 8 and have the voter eligible to vote in B after returning to County A for the
second time. Millions of dollars can be spent of 3 statewide voter registry. but if the
procedures for using the data are not consistent across the state and reflective of where
the voter actually resides. the process is far from error free.
One step that could make the process more accurate would be for the statewide
database to be sorted against the database of illegal non-citizens used by the state lor
jury pools. Interesting that you can't sit on a jury, but one can vote and elected or retain
those managing the criminal justice system. Also. requiring consistent recording
keeping standards as well as requiring uploads to the state registry to include tile most
recent registration dates within the statewide database fields would enable accurate
determinations of current residency.
While this is not a comprehensive discussion. it is indicative of the "new design' for
voter registration and its missing protocols that serve to prevent the voting process from
being accurate and integrity based from start - never mind the emphasis on the
accurate finish. The truth is - garbage In. garbage out.
t'
fd;L~.([ {~~ 3!3i2010

Willard R. Hetander Date
Lake County Clerk
cannot endure unless the people recognize their corresponding individual Obligations and responsibilities. (Article 1, Section 23 IL Cons.)
34
To Mark Shelden:
tam atternpting to understand the- registration process and have prepared 17 questions. I really am
seeking your knowledge of the matter and I wish to include it in my case to testify about voter fraud in
Illinois. McHenry County Clerk Katherine Schultz and Lake County Clerk, Wiliard Helander have
answered the questions. It would be very important to have a Clerk from downstate as welL
What J have done, is tracked the process of voter registration and the SOC including the S day law. My
case presents that these are unconstitutionai and restrict the Clerk's ability to administer a fair election
because they fail to empower anyone to verify vs. certify. I understand Apparent Conformity and am
not trying to change that. Our action in court will also address the fact tha voter registration processes
are not 'unttorm as constitutionally required.
I appreciate your input as an elected official, who speaks of his knowledge. I don't need long answers.
Thank you!
1) Please briefly list the process by which a candidate gets on the ballot in Champaign County
Candidates in Champaign County get on the ballot pursuant to state statute. \/Ve design ciur own
petition and nominating papers for candidates in Champaign countv. We check for apparent conforrnity
by ascertaining that the requisite number of signatures were cottectc d, that there is a sworn statement
of candidacy for an office and party that is on the ballot.
2) What documents are required of a candidate to prove constitutional eligibility to be on the

ballot?
Sworn statement.
3) Please specify how election law and related processes verifies the constitutional eligibility of a
candidate for offlce ,
Only through the objection process
4) What statement or oath is required of candidates swearing eligibility?
Statement of candrdacv,
A frequent reoccurrence to the fundamental principles of civil government is necessary to preserve the blessings ofliberty. These blessings
35
030
S) How is the citizenry notified of potential candidates for the ballot during the qualification
period?
We post candidates on the web and make that information available by request.
a. What process is available for a citizen to contest a candidate's eligibility for office during
that period?
The objection process as laid out in statute.
b. What avenues are available to a citizen questioning a candidate's eligibility after that
tirne period?
No other methods during the candidacy period. A quo warranto action is allowed for those elected.
6) In the authority of your office and after the above mentioned contest period, should you
question if a candidate is constitutionally eligible for office, what election law or mechanism is
available to investigate your suspicion?
Our ability to investigate these claims would be contingent upon the evidence provided us in the
objection period.
7) When an election has occurred, vote tallies completed, is there a process then for which a
candidate is verified as constitutionally eligible for the office?
No.
8) Through State Board processes and legal authorities, if the election results are certified, is there
any point where constitutional eligibility is verified as part of that pro cess>
No
9) In the Illinois and Federal election processes that you are familiar with, are there procedural
differences such that names submitted for ballots in your County from State and Federal
sources, are verified as constitutionally eligible for office?
No
cannot endure unless the people recognize their corresponding individual Obligations and responsibilities. (Article I, Section 23 IL Cons.)
36
cJ31
registered in Illinois. What documents are required to estabiish age, citizenship and residence?
NVRA and article 4 of the election code. No documents are required at all for the NVRA form.
Article 4 registrations require documentation of address but not of age or citizenship.
11) Are there voter registration processes in use right now, that do not require potentia! voters to
swear to place of birth and that they are US citizens authorized to vote?
No
12) As an overview only, and as possible, please describe an instance within the current svster»
where citizens have unknowingly been registered to vote through the State Driver's license
registration process.
I'rn not aware of those right no"v. We don't track those.
13) In the voter registration process, how is citizenship status verified" By what statute anci code
authorizes the process for confirming citizenship status ofa registered voter?
Citizenship status is never verified.
14) If a voter comes to the poll, and there is a question of his identity or registration status, by what
means is the voter's right to vote accommodated during the voting process?
If a voter's right to vote is challenged by another person, and that chailenge is upheld by a majority of
the election judges, the voter may vote provisionally,
It's a Republic, if you can keep it." Benjamin Franklin

Petition for Injunctive Relief
cannot endure unless the people recognize their corresponding individual obligations and responsibilities, (Article 1, Section 23 IL Cons.)
37
032--
--.--~.----.-----.--~---
15) During the "5 day Contest Period" for ballot qualification, does your County post notice of
candidates for all State and Federal offices?
On the web.
15) Specifically, was a Statement of Candidacy posted for the US Presidential election in 2008? And
If so, may I please know where.
No. No statements of candidacy were filed in our office for the office of President.
17) Are you aware if any local Newspapers posted the SOCduring the 5 day contest period for the
2008 primary election?
I would doubt that anyone published a statement of candidacy. I'm certainly not aware of any that
did.
cannot endure unless the people recognize their corresponding individual obligations and responsibilities. (Article 1, Section 23 IL CODS.)
38
Stephen F. Estill, Petitioner
Candidate for Illinois Governor -Illinois General Election
To: Mr. Menzel, Illinois State Board of Elections
Subject: Response to Objections
I request that my name be allowed on the ballot for the following reasons:
1. Nowhere in my petition did I state that I was running for Lieutenant Governor. (thought they
were independent of one another. Now I know otherwise. My Lieutenant Governor is Larry
Jones of Springfield, Illinois. Therefore, I ask that this objection be stricken.
2. I was only able to obtain 225 signatures as I was working alone and going door to door. Since
people in the past have been allowed on the ballot with fewer signatures than the 25,000, ( ask
that this requirement be waived.
3. I believe that my candidacy offers a unique opportunity for people to vote for an alternative
candidate.
Thank you,
Stephen F. Estill
Mason City, IL 62664

Candidate for Governor of Illinois
Website: nttp) lindependentronwvernor-iiiinois.com

Meroni V ISBE - Meroni Responds To Reese 10-09-20

Caricato da

Informazioni sul documento

Titolo originale

Copyright

Formati disponibili

Condividi questo documento

Condividi o incorpora il documento

Opzioni di condivisione

Hai trovato utile questo documento?

Questo contenuto è inappropriato?

Copyright:

Formati disponibili

Meroni V ISBE - Meroni Responds To Reese 10-09-20

Caricato da

Copyright:

Formati disponibili

IN THE CIRCUIT COURT FOR THE SEVENTH JUDICIAL CIRCUIT OF ILLINOIS SANGAMON

COUNTY, SPRINGFIELD ILLINOIS

IN THE MATTER OF: )

I - Introduction - Personal Statements

Constitution. The Right to be represented by constitutionally eligible representatives, regardless at what

Constitutionally qualified to govern ....According to the US and Illinois Constitutions means to be

ballot placement with no remedy or relief in the law available.

McHenry County Court.

administer the election statutes.

This is the only place I can contest a candidate placement on my ballot.

ThelSBEofdutiesaredefinedlO ILCS 5/1A-8} (from Ch. 46, par. lA-8)

Section lA -8 defines the duties and include

Review and inspect procedures and records relating to conduct of

equal protection rights.

require a background check, which includes proof of citizenship.

Indeed this is not a political question, it is a judiciable question.

can't candidates for office? Perhaps passports will work .

li.,- Res'ponse_to Defenses "Brief in support of administration decision

Response: BRIEFIN SUPPORTOF ADMINISTRATIVE DECISION-This section is a direct response to the

Comments related to Defense's Introduction

one candidate Christopher Pederson, (discussed later), ....Iegal qualifications of office"

b. Accordingly, they do this at the time the petitions are accepted.

Elections (SBOE) is violating in refusing to impose apparent conformity standards

apparent conformity standards or the lack there of.

standards of apparent conformity.

Judicial Review is Law and Fact.

b. State stipulates there are no facts in dispute.

c. State stipulates there were never any facts in question

4) The Petitioner's original petition makes 4 points.

candidate for said office.

The Defense provides no challenge to Plaintiffs standing or interest

requirements in question in the objection petition "All candidates must be a specific

Reeves Response do they

i. Dispute this point of Law

ii. Claim any deficiency whatsoever in this statement.

_______ 0._ .. _._0 _

affirms with exact specificity what the question is about.

provide documentation (fact or evidence) the candidate meets the constitutional

i. This is not disputed by any fact.

desired ballot position.

i. The Defense offers no fact to substantiate its claim of deficiency. Indeed it

conformity on the ballot

(SOEB)and the General Assembly to do their jobs!

absence of public document to establish constitutional qualifications. This defect of law

compliance with Constitutional mandates is the candidates.

evidence for factual challenges to the candidate's applications.

subjective and self certifying statement of being legally qualified.

qualified, it does not for citizenship." (R p129 point 104)

according to a standard of law, especially as required in legally qualified.

Big time due process problem!

County Court. (Meroni v ISBEFebruary 2010)

posting of proof establishing fact or evidence of "legally qualified"

should be resolved by negotiations in the legislature.

designed to frustrate the petitioner's lawful access to the election process.

The harm done to the public confidence in its government is indisputable.

Office's contrived governance that is not constitutionally based.

other candidate or elected official) holds.

It is beyond the absurd, it is tragic.

the exception of the 11 or so that produced proof to the petitioner.

Plaintiff's responses on these pages of testimony in question.

It is incredibly demoralizing to struggle so intensely for such a simple answer ...

"Yes, but .... Are they legally qualified .... ?"

doing its job because it refuses to enforce standards of apparent conformity.