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Supreme Court for the County of Albany Index no.: 1600 - 2019
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AD HOC NEW YORKER REPUBLICAN COMMITTEE
PLAINTIFF,
against ORDER TO SHOW CAUSE
===========================================
Upon the Complaint affidavit of Plaintiff's Trustees affirmed 30 December 2020, the plaintiff in
the above matter, and upon the exhibits annexed thereto with Memorandum of 3 January 2021,
LET the defendants in this matter show cause before this Court on the _____ day of January,
2021 at 9:30 o'clock in the forenoon of that day, or as soon thereafter as counsel can be heard,
why permanent injunction should not be granted to stay any certification of New York's
presidential electors based upon the commingled use of mail-in-votes ballots without permissive
application that on or after 14 December 2020 was sent to Washington District of Columbia for
tally and certification plenary authority by President of Senate on 6 January 2021, pending
determination of court hearing has been taken on this order, and for such other and further relief
this Court may deem just and appropriate. Sufficient reason appearing therefore, it is
ORDERED that the above-referenced use of mail-in-votes ballots without permissive application
is hereby stayed pending the hearing brought on by this order to show cause, and it is further
ORDERED that personal or overnight mail service of a copy of this order to show cause and the
papers upon which it is granted upon the Defendants on or before the ______ day of
___________, 2021 shall be deemed good and sufficient service thereof, and it is further
ORDERED that the motion brought on by this order to show cause shall not be orally argued
unless counsel are notified to the contrary by the Clerk of the Court.
PLAINTIFF, MEMORANDUM
against
IN SUPPORT OF
MARK ELLIOT ZUCKERBERG; FACEBOOK INC.;
KAMALA DEVI HARRIS; HILLARY R. CLINTON; INJUNCTIVE RELIEF
and ANDREW M. CUOMO
DEFENDANTS.
=======================================
This AD HOC NEW YORKER REPUBLICAN COMMITTEE MEMORANDUM IN SUPPORT
persona annexed COMPLAINT with SUMMONS and PROPOSED RESTRAINT ORDER that on
31 December 2020 having given the State Legislature NOTICE of INTENT to PETITION,
appended herewith, to seek timely relief against imminent irreparable harm caused by Defendants
along with others similarly situated too numerous to name, whose criminal foreign election
interference used mail-in-vote ballots to rig the 3 November 2020 and 14 December 2020 elections
based upon prima facie evidence by operation of New York State and Federal Constitutional /
Statutory law(s) warrants timely emergency injunctive relief under C.P.L.R. §6312 by Temporary
Restraint Order (see the Proposed Order herewith) before the 6 January 2021 joint session of the
U.S. Congress when the President of the U.S. Senate Michael Pence with plenary authority to tally
and certify the legal Electoral College votes certified on or after the 3 November 2020 and 14
December 2020 election of all Electors of each State of several States for Democratic National
Committee (DNC) Candidates Joseph R. Biden for President of the United States (POTUS) and
Kamala D. Harris for Vice President of the United States (VPOTUS) who is not a Natural Born
Citizen (NBC) eligible to serve per se in accordance with U.S. Constitution Article 2 Section 1
1
Clause 5 see Complaint Footnote #2 and Exhibit C, and two DNC electors may not serve as
SES/SEA members for Trust or Profit see Complaint Footnote #1 must be excluded; and that
Defendants' unconstitutional acts are tortuous inducement of fraud injury involving New York State
Constitutional / Statutory arbitrary and capricious crimes under NYS EL § 17–142 - Giving
consideration for franchise shown at Complaint Footnote #3, and NYS EL § 17–154- Pernicious
political activities shown at Complaint Footnote #4, and this Complaint is novel as a question of
first impression to be ordered heard before this court; and as such, stands alone notwithstanding any
fraud allegations argued outside of this Complaint in other venue(s) to re-elect Republican National
Committee (RNC) POTUS Donald J. Trump Candidate and VPOTUS Michael Pence Candidate.
B. New York Allow for No-Excuse Absentee Voting Amendment proposed for (2021)
https://ballotpedia.org/New_York_Allow_for_No-Excuse_Absentee_Voting_Amendment_(2021)
The legislature may, by general law, provide a manner in which, and the time and place at which,
qualified voters who, on the occurrence of any election, may be absent from the county of their
residence or, if residents of the city of New York, from the city, and qualified voters who, on the
occurrence of any election, may be unable to appear personally at the polling place because of illness
or physical disability, may vote and for the return and canvass of their votes in any election.
New York Allow for No-Excuse Absentee Voting Amendment may appear on the ballot in New
York as a legislatively referred constitutional amendment on November 2, 2021.
The ballot measure would authorize the New York State Legislature to pass a statute for no-excuse
absentee voting. As of 2019, the state constitution required voters to be absent from their county of
residence, ill, or physically disabled to vote with an absentee ballot.
C. The Constitution of the State of New York ARTICLE XIX AMENDMENTS TO
CONSTITUTION [Amendments to constitution; how proposed, voted upon and ratified;
failure of attorney-general to render opinion not to affect validity] Section 1. Any amendment or
amendments to this constitution may be proposed in the senate and assembly whereupon such
amendment or amendments shall be referred to the attorney-general whose duty it shall be within
twenty days thereafter to render an opinion in writing to the senate and assembly as to the effect of
such amendment or amendments upon other provisions of the constitution. Upon receiving such
2
opinion, if the amendment or amendments as proposed or as amended shall be agreed to by a
majority of the members elected to each of the two houses, such proposed amendment or
amendments shall be entered on their journals, and the ayes and noes taken thereon, and referred to
the next regular legislative session convening after the succeeding general election of members of
the assembly, and shall be published for three months previous to the time of making such choice;
and if in such legislative session, such proposed amendment or amendments shall be agreed to by a
majority of all the members elected to each house, then it shall be the duty of the legislature to
submit each proposed amendment or amendments to the people for approval in such manner
and at such times as the legislature shall prescribe; and if the people shall approve and ratify
such amendment or amendments by a majority of the electors voting thereon, such amendment
or amendments shall become a part of the constitution on the first day of January next after
such approval. Neither the failure of the attorney-general to render an opinion concerning such a
proposed amendment nor his or her failure to do so timely shall affect the validity of such proposed
amendment or legislative action thereon. (Formerly §1 of Art. 14. Renumbered and amended by
Constitutional Convention of 1938 and approved by vote of the people November 8, 1938; further
amended by vote of the people November 4, 1941; November 6, 2001.) (Emphasis by Plaintiff)
3
"I'm issuing today's executive order because we want boards of elections to count votes efficiently
and we want them to get it right, but we want it done in a timely manner. We don't want to hear
after-the-fact excuses."
The executive order requires county boards of elections to take the following actions:
A. That the Zuckerberg facilitation of non-permissive voting by mail is not in accordance with
Election Law;
B. That Governor Cuomo's Executive Order imprimatur arbitrary use of power is a facilitation of
fraudulent inducement of non-permissive voting by mail is not in accordance with Election Law;
C. That there is no legislative grant of non-permissive voting by mail in accordance with Election
Law and therefore Zuckerberg / Facebook vote harvesting facilitation is in bad faith with law;
D. That DNC Electors Clinton and Cuomo must show cause why they are not holding an office of
trust or profit or else be disqualified as DNC Electors;
E. That Senator Kamala D. Harris must show cause why she should not be deemed ineligible to
hold the VPOTUS office;
DEMAND FOR TIMELY INJUNCTIVE RELIEF
4
for VPOTUS and RNC POTUS Donald J. Trump Candidate to re-elect the POTUS and RNC VPOTUS
Michael Pence Candidate to re-elect the VPOTUS. That the Court Declare and Order:
A. That Defendants by using an un-ratified amendment that violates the New York State Constitution
Article XIX Amendment Ratification Compliance, Article 2 Section 2 compliance is arguably a ..
violation of NYS EL § 17-142.for giving consideration for franchise and§ 17-154./or
pernicious political activities; and
B. That Zuckerberg Facebook Defendants facilitation is an illegal unconstitutional tortuous
interference violation of the U.S. Constitution Article 2 Section 1 Clause 2;
C. That the Zuckerberg Facebook Contracts with various New York subdivisions are void;
D. That Democratic Party Elector Defendants Cuomo and Clinton are Senior Executive Association
members under the United States for trust & profit and as such may not serve as Electors per se are
a nullity by operation oflaw that reduce the Democratic Party Candidates ofPOTUS and VPOTUS
to 29 Electors; and
E. Further the Democratic Party Electors for KAMALA D. HARRlS are reduced to zero electors as a
matter oflaw because the candidate is not a Natural Born Citizen and therefor ineligible to hold
office of VPOTUS; and
F. That Plaintiffs are entitled to an audit of the entire 3 November 2020 Elections to singly out illegal
mail-in-ballots from legal absentee ballots andre-tally of all votes for down-line candidates; and
G. Plaintiff is entitled to different and other relief including hearing on preliminary injunction, along
with expenses of this action as the Court deems necessary.
Dated: January 3 ,
2021
Hurley New York 12443
William Van Allen in esse sui juns Trustee for the
HOC NEW YORKER REPUBLICAN COMMITTEE
351 North Road Hurley NY 12443 Phone: 845-389-4366
Fax 845-331-1925 email: hvanallen@hvc.rr.com
5
DOS Process by:
FACEBOOK INC.
1601 WILLOW ROAD
MENLO PARK, CALIFORNIA, 94025
Service by USPS Certified with Return Receipt plus copy by regular mail:
6
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UCS-840
REQUEST FOR JUDICIAL INTERVENTION (rev. 07 /29/2019)
Index No: 1600 Date Index Issued : 03/19/2019 For Court Use Only: I
CAPTION Enter the complete case caption. Do not use et al or eta no. If more space is needed, attach a caption rider sheet. lAS Entry Date
MARK ELLIOT ZUCKERBERG; FACEBOOK INC.; KAMALA DEVI HARRIS; HILLARY R. CLINTON AND
I- -
ANDREW M. CUOMO I~
RJ I Filed Date
-
Defendant(s)/Respondent(s)
NATURE OF ACTION OR PROCEEDING Check only one box and specify where indicated.
COMMERICIAL MATRIMONIAL
0 Business Entity (includes corporations, partnerships, LLCs, LLPs, etc.) 0 Contested
0 Contract NOTE: if there are children under the age of 18, complete and attach the
0 Insurance (where insurance company is a party, except arbitration) MATRIMONIAL RJI ADDENDUM (UCS-840M).
0 UCC (includes sales and negotiable instruments) For Uncontested Matrimonial actions, use the Uncontested Divorce RJI {UD-13).
0 Other Commercial (specify): _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ TORTS
NOTE: For Commercial Division assignment requests pursuant to 22 NYCRR 202.70{d), 0 Asbestos
complete and attach the COMMERCIAL DIVISION RJI ADDENDUM (UCS-840C}. 0 Child Victims Act
r----------------------------~
REAL PROPERTY Specify how many properties the application includes: --- - 0 Environmental {specify): - - - - - - - - - - - - - - - - - - -
0 Condemnation 0 Medical, Dental or Podiatric Malpractice
0 Mortgage Foreclosure (specify): 0 Residential 0 Commercial 0 Motor Vehicle
Property Address: - - - - - - - - - - - - - - - - - - - - - 0 Products Liability (specify) : - - - - - - - - - - - - - - - - - -
NOTE: For Mortgage Foreclosure actions involving a one to four-family, 0 Other Negligence ( s p e c i f y ) : - - - - - - - - - - - - - - - - - -
owner-occupied residential property or owner-occupied condominium, 0 Other Professional Malpractice (specify): - - - - - - - - - - - - -
complete and attach the FORECLOSURE RJI ADDENDUM (UCS-840F). 0 Other Tort (specify):
0 Tax Certiorari SPECIAL PROCEEDINGS
0 Tax Foreclosure 0 CPLR Article 75 (Arbitration) [see NOTE in COMMERCIAL section]
~O~_:O:::t::.:h.:::er:...:R~e:,::a::._lP:...:r.:::o.!:.pe:::rt..:y~(~s!:pe:::c::.:ify!..:)C:..:=================:..jO CPLR Article 78 (Body or Officer)
OTHER MATTERS @) Election Law
0
------
Certificate of Incorporation/Dissolution [see NOTE in COMMERCIAL section]
-
0 Extreme Risk Protection Order
0 Emergency Medical Treatment 0 MHL Article 9.60 (Kendra's Law)
0 Habeas Corpus 0 MHL Article 10 (Sex Offender Confinement-Initial)·
0 Local Court Appeal 0 MHL Article 10 (Sex Offender Confinement-Review)
0 Mechanic's Lien 0 MHL Article 81 (Guardianship)
0 Name Change 0 Other Mental Hygiene (specify): - - - - - - - - - - - - - - - -
0 Pistol Permit Revocation Hearing 0 Other Special Proceeding {specify): - - - - - - - - - - - - - - - I
0 Sale or Finance of Religious/Not-for-Profit Property
0 Other (specify):
STATUS OF ACTION OR PROCEEDING Answer YES or NO for every question and enter additional information where indicated.
YES NO
Has a summons and complaint or summons with notice been filed? ® 0 If yes, date filed :
Has a summons and complaint or summons with notice been served? ® 0 If yes, date served:
Is this action/proceeding being filed post-judgment? 0 ® If yes, judgment date:
NATURE OF JUDICIAL INTERVENTION Check one box only and enter add itional information where indicated.
0 Infant' s Compromise
0 Extreme Risk Protection Order Application
0 Note of Issue/Certificate of Readiness
0 Notice of Medical, Dental or Podiatric Malpractice Date Issue Joined: _ _ _ _ _ _ __
0 Notice of Motion Relief Requested : Return Date: _ _ _ _ _ _ __
0 Notice of Petition Relief Requested: Return Date: _ _ _ _ _ _ __
® Order to Show Cause Relief Requested : Return D a t e : - - - - - - - -
0 Othe r Ex Parte Application Relief Requested:
0 Poor Person Application
0 Request for Preliminary Conference
0 Residential Mortgage Foreclosure Settlement Conference
0 Writ of Habeas Corpus
0 Other (specify) :
RELATED CASES
I
List any related actions. For Matrimonial cases, list any related criminal or Family Court cases. If none, leave blank.
If additional space is required, complete and attach the RJI ~DDENDUM (UCS-840A).
Case Title Index/Case Number Court Judge (if assigned) Relationship to instant case I
PARTIES For parties without an attorney, check the "Un-Rep" box and enter the party's address, phone number and email in the space provided.
If additional space is required, complete and attach the RJI ADDENDUM (UCS-840A).
Un- Parties Attorneys and Unrepresented Litigants Issue Joined Insurance Carriers
Rep List parties in same order as listed in the For represented parties, provide attorney's name, firm name, address, phone and For each defendant, For each defendant,
caption and indicate roles (e.g., plaintiff, email. For unrepresented parties, provide party's address, phone and email. indicate if issue has indicate insurance
defendant, 3'0 party plaintiff, etc.) been joined. carrier, if applicable.
Name: AD HOC NEW YO RKER REPUBLICAN COMM ITIEE
0
Tru stee HAROLD WILLIAM VAN AL LEN 351 North Road Hurley NY 12443 Ph one: 845·389-4366 Fax 845-331·1925 email: twanallen@hvc.rr.com
Role(s) : and Trustee CHRISTOPOHER EARL STRUNK 141 Harris Avenue Lake Luzerne NV 12846 Phone: 518-416-8743 email: strunk@leader.com
0 YES ®NO
Plaintiff
Name:
D Role(s): QYES QNO
Name:
D Role(s) : QYES 0NO
Name:
D Role(s): 0YES 0NO
Name:
D Role(s): 0YES 0NO
Name:
D Role(s): OYES 0NO
Name:
D Role(s): 0 YES 0NO
Name:
D Role(s): 0 YES 0 NO
Name:
D Role(s): 0YES 0NO
Name:
D Role(s) : OYES 0NO
Name:
D Role(s) : 0 YES QNO
Name:
D Role(s) : 0 YES 0NO
Name:
D Role(s): 0YES QNO
Name:
D Role(s): 0YES QNO
Name:
D Role(s): 0YES 0NO
I AFFIRM UNDER THE PENALTV OF PERJURY THAT, UPON INFORMATION AND BELIEF, THERE ARE NO OTHER RELATED ACTIONS OR PROCEEDINGS,
c
EXCEPT AS NOTED ABOVE, NOR HAS A REQUEST FOR JUDICIAL INTERVENTION 10 OR PROCEEDING.
USPS eReceipt
From: DoNotReply@ereceipt.usps.gov
Sent: Thu, Dec 31, 2020 at 2:21 pm
To: STRUNK@LEADER.COM
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CORINTH
97 MAIN ST
CORINTH, NY 12822-9998
(800)275-8777
12/31/2020 02:21 PM
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Priority Mail® 2-Day 1 $7.75
Flat Rate Env
Mount Kisco, NY 10549
Flat Rate
Expected Delivery Date
Tue 01/05/2021
Tracking #:
9505 5105 5456 0366 2601 95
Insurance $0.00
Up to $50.00 included
Total $7.75
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Grand Total: $46.50
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Debit Card Remitted $46.50
Card Name: Debit Card
Account #: XXXXXXXXXXXX6593
Approval #
Transaction #: 673
Receipt #: 013370
Debit Card Purchase: $46.50
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The State of New York Index no.: 1600 - 2019
Supreme Court for the County of Albany
================================
AD HOC NEW YORKER REPUBLICAN COMMITTEE
PLAINTIFF,
against
SUMMONS
Plaintiffs place for service:
351 North Road
Hurley NY 12443
-------------------------------------------------------------------------------X
To the above-named Defendants:
YOU ARE HEREBY SUMMONED to answer the complaint verified December 30,
2020, that is the complaint with index no.: 1600-2019 herein, and to serve a copy of your
answer, or, if the complaint is not served with this summons, to serve a notice of
appearance, on the Plaintiff within 20 days after the service of this summons, exclusive of
the day of service (or within 30 days after the service is complete if this amended summons
is not personally delivered to you within the State of New York; and in case of your failure
to appear or answer, judgment will be taken against you by default for the relief demanded
in the complaint.
FACEBOOK INC.
1601 WILLOW ROAD
MENLO PARK, CALIFORNIA, 94025
Service by USPS Certified with Return Receipt plus copy by regular mail:
PLAINTIFF, COMPLAINT
for timely Injunctive relief
against
MARK ELLIOT ZUCKERBERG (born May 14, 1984); and FACEBOOK - 1601 WILLOW ROAD
MENLO PARK, CALIFORNIA, 94025 re: NYS EL § 17–142. Giving consideration for franchise / § 17–154.
Pernicious political activities Attn: NYS Legislature U.S. Constitution Article 2 Section 1 Clauses 2, 3 (1) and 5(2)
DEFENDANTS,
KAMALA DEVI HARRIS
United States Senator for California 112 Hart Building, Washington, DC 20510 Phone: (202) 224-3553
Attn: NYS Legislature authority per U.S. Constitution Article 2 Section 1 Clause 2 and Clause 5
DEFENDANT,
HILLARY R. CLINTON, Democratic Party VPOTUS Elector / SEA member for trust & profit
15 Old House Lane, Chappaqua , New York 10514 Attn: NYS Legislature authority per U.S. Constitution
Article 2 Section 1 Clause 2 and Clause 5
DEFENDANT, and
ANDREW M. CUOMO, Democratic Party VPOTUS Elector / SEA member for trust & profit
NYS State Capitol Building Albany, New York 12224, 4 Bittersweet Lane, Mount Kisco, NY 10549
Attn: NYS Legislature under U.S. Constitution Article 2 Section 1 Clause 2 and Clause 5: New York State Senate
172 State St, Albany, NY 12210 Phone: (518) 455-2800; and New York Assembly Governor Nelson A.
Rockefeller Empire State Plaza 202 Legislative Office Bldg, Albany, NY 12248 Phone: (518) 455-4218
DEFENDANT.
For Persons holding an Office of Trust or Profit - U.S. Constitution Art. 2 Section 1 Clause 2 and Clause 5 include:
SENIOR EXECUTIVE SERVICE (SES) c/o U.S. Office of Personnel Management 1900 E Street, NW Washington,
DC 20415-1000; and
SENIOR EXECUTIVE ASSOCIATION (SEA) 7945 MacArthur Boulevard Suite 201 Cabin John, Maryland 20818
Phone: (202) 971-3300
DONALD J. TRUMP, President of the United States 1600 Pennsylvania Avenue Washington DC 20500
==========================================================
1
U.S. Constitution Article II, Section 1, Clause 2: Each State shall appoint, in such Manner as the Legislature thereof
may direct, a Number of Electors, equal to the whole Number of Senators and Representatives to which the State may
be entitled in the Congress: but no Senator or Representative, or Person holding an Office of Trust or Profit under
the United States, shall be appointed an Elector.
2
U.S. Constitution Article II, Section 1, Clause 5: No Person except a natural born Citizen, or a Citizen of the
United States, at the time of the Adoption of this Constitution, shall be eligible to the Office of President; neither shall
any Person be eligible to that Office who shall not have attained to the Age of thirty five Years, and been fourteen
Years a Resident within the United States.
1
This COMPLAINT by the AD HOC NEW YORKER REPUBLICAN COMMITTEE (Plaintiff) in
propria persona seeks timely relief against imminent irreparable harm caused by Defendants along
with others similarly situated whose willful acts of election inference by unconstitutional tortuous
inducement of fraud involves NYS EL § 17–142. Giving consideration for franchise (3) / § 17–154.
Pernicious political activities (4) to rig the 3 November 2020 and 14 December 2020 elections that
3
2016 New York Laws ELN - Election Article 17 - (Election) VIOLATIONS OF THE ELECTIVE FRANCHISE
Section 17-142 - Giving consideration for franchise. Except as allowed by law, any person who directly or indirectly,
by himself or through any other person:
1. Pays, lends or contributes, or offers or promises to pay, lend or contribute any money or other valuable
consideration to or for any voter, or to or for any other person, to induce such voter or other person to vote or
refrain from voting at any election, or to induce any voter or other person to vote or refrain from voting at such
election for any particular person or persons, or for or against any particular proposition submitted to voters, or to
induce such voter to come to the polls or remain away from the polls at such election or to induce such voter or
other person to place or cause to be placed or refrain from placing or causing to be placed his name upon a
registration poll record or on account of such voter or other person having voted or refrained from voting for or
against any particular person or for or against any proposition submitted to voters, or having come to the polls or
remained away from the polls at such election, or having placed or caused to be placed or refrained from placing
or causing to be placed his or any other name upon the registry of voters; or,
2. Gives, offers or promises any office, place or employment, or promises to procure or endeavor to
procure any office, place or employment to or for any voter, or to or for any other person, in order
to induce such voter or other person to vote or refrain from voting at any election, or to induce any voter or other
person to vote or refrain from voting at such election, for or against any particular person or for or against any
proposition submitted to voters, or to induce any voter or other person to place or cause to be placed or refrain
from placing or causing to be placed his or any other name upon a registration poll record; or,
3. Gives, offers or promises any office, place, employment or valuable thing as an inducement for any voter
or other person to procure or aid in procuring either a large or a small vote, plurality or majority at any election
district or other political division of the state, for a candidate or candidates to be voted for at an election; or to cause
a larger or smaller vote, plurality or majority to be cast or given for any candidate or candidates in one such district
or political division than in another; or,
4. Makes any gift, loan, promise, offer, procurement or agreement as aforesaid to, for or with any person to
induce such person to procure or endeavor to procure the election of any person or the vote of any voter at any
election; or,
5. Procures or engages or promises or endeavors to procure, in consequence of any such gift, loan,
offer, promise, procurement, or agreement the election of any person, or the vote of any voter, at such election; or,
6. Advances or pays or causes to be paid, any money or other valuable thing, to or for the use of any other
person with the intent that the same, or any part thereof, shall be used in bribery at any election, or knowingly pays
or causes to be paid any money or other valuable thing to any person in discharge or repayment of any money,
wholly or in part expended in bribery at any election, is guilty of a felony.
4
2015 New York Laws ELN - Election Article 17 - (Election) VIOLATIONS OF THE ELECTIVE FRANCHISE 17-
154 - Pernicious political activities. It shall be unlawful for any person to:
1. Intimidate, threaten or coerce, or to attempt to intimidate, threaten or coerce, any other person for
the purpose of interfering with the right of such other person to vote or to vote as he may choose, or for the purpose of
causing such other person to vote for, or not to vote for, any candidate for the office of governor, lieutenant-
governor, attorney-general, comptroller, judge of any court, member of the senate, or member of the assembly at any
election held solely or in part for the purpose of selecting a governor, lieutenant-governor, attorney-general,
comptroller, any judge or any member of the senate or any member of the assembly; or,
2. Directly or indirectly, promise any employment, position, work, compensation, or other benefit,
provided for or made possible in whole or in part by any act of congress or of the legislature appropriating funds
for work relief or relief purposes, to any person as consideration, favor or reward for any political activity or
2
based upon the prima facie evidence by operation of State and Federal Constitutional / Statutory
law(s) warrants timely emergency injunctive relief under C.P.L.R. §6312 before the 6 January 2021
joint session of the U.S. Congress when the President of the U.S. Senate Michael Pence with
plenary authority to tally and certify the legal Electoral College votes certified on or after the 3
November 2020 and 14 December 2020 election of every Elector(s) of each State of several States
for both DNC Candidate Joseph R. Biden for President of the United States (POTUS) and ineligible
DNC Candidate Kamala D. Harris for Vice President of the United States (VPOTUS) and RNC
POTUS Donald J. Trump Candidate to re-elect the POTUS and RNC VPOTUS Michael Pence
a Trust Association registered with New York State Secretary of State (see Exhibit A) with The
Trustees: Harold William Van Allen and Christopher Earl Strunk, who in esse sui juris are both
United States Natural Born Citizens over 18 years of age registered to Vote in New York
for the support of or opposition to any candidate or any political party in any nominating convention or in any
election; or,
3. Deprive, attempt to deprive or threaten to deprive, by any means, any person of any employment,
position, work, compensation or other benefit provided for or made possible in whole or in part by any act of
congress or of the legislature appropriating funds for the work relief or relief purposes, on account of any political
activity or on account of support for or opposition to any candidate or any political party in any nominating
convention or election; or
4. Solicit or receive or be in any manner concerned in soliciting or receiving any assessment, subscription or
contribution for any political purpose whatever from any person known by him to be entitled to or receiving
compensation, employment or other benefit provided for or made possible by any act of congress or of the legislature
appropriating, or authorizing the appropriation of, funds for work relief or relief purposes; or
5. Furnish or to disclose, or to aid or assist in furnishing or disclosing, any list or names of persons
receiving compensation, employment or benefits provided for or made possible by any act of congress or of the
legislature appropriating or authorizing the appropriation of, funds for work relief or relief purposes, to a
political candidate, committee, campaign manager, or to any person for delivery to a political candidate, committee or
campaign manager, and it shall be unlawful for any person to receive any such list or names for political purposes.
No part of any appropriation made by any act of congress or of the legislature, heretofore or hereafter
enacted, making appropriations for work relief, relief, or otherwise to increase employment by providing loans and
grants for public works projects, shall be used, and no authority conferred by any such act upon any person shall be
exercised or administered, for the purpose of interfering with, restraining or coercing any individual in the exercise
of his right to vote and to vote as he may choose at any election.
Any person who violates any of the foregoing provisions of this section shall be guilty of a misdemeanor.
3
2. The Trustees individually voted at the General Election of 3 November 2020 for the Electors
for re-election of POTUS Donald J. Trump Candidate and VPOTUS Michael Pence
accordingly, despite the despicable activities of the New York State Democratic Party and
Republican Party Committees in control of the New York State Board of Elections along with
those persons similarly situated as Defendants among others too numerous to name, and whose
3. That the State of New York Governor ANDREW M. CUOMO, the Democratic Party
VPOTUS Elector (Cuomo Defendant) is now a SEA member for trust & profit having served
for trust and profit at least two years as the U.S. Secretary of Housing Urban Development and
is a SES member located for service at the NYS State Capitol Building Albany, New York
4. That former U.S. Senator from NYS and U.S. Secretary of State HILLARY R. CLINTON, the
Democratic Party VPOTUS Elector (Clinton Defendant) is now a SEA member for trust &
profit having served for trust and profit at least two years as the U.S. Secretary of State is a
SES member located for service at 15 Old House Lane, Chappaqua , New York 10514; and
5. That Cuomo Defendant and Clinton Defendant (SEA Defendants) are unconstitutional Elector
defendants chosen in violation of U.S. Constitution Article II, Section 1, Clause 2 as SEA
members for trust & profit who have aided and abetted concerted opposition on 20 January
6. That SEA Defendants prepared in concert with the Peoples Republic of China (PRC) and
Chinese Communist Party (CCP) eventually against DJT starting no later than 2015 when a
U.S. NIH-funded $3.7 million project grant was approved by Dr. Anthony Fauci in 2015, after
the Obama White House imposed a ban on 'monster-germ' research, and that in October 2014,
4
viruses related to influenza, such as the Middle East respiratory syndrome (MERS) and severe
7. That as a result, the illegal outlawed research was outsourced to China’s Wuhan Institute of
Virology for the CCP in 2019 known as the Covid-19 pandemic project creation of the SARS-
CoV-2 modified with Gain of Function, as the CoronaVirus bio weapon created in Wuhan PRC
inter alia as the excuse to facilitate mail-in-vote ballot election of Electors of each State of
several States for DNC Candidates for POTUS and VPOTUS versus DJT; and
8. That SEA Defendants promoted the expansion of late term abortion with expectation that fetal
tissues for international sale would be used for the manufacture of a CORONAVIRUS vaccine
delivered by Fauci and Obama with $3.7 Million funding in 2015 that was promoted by the
Pirbright Institute of Great Britain that in 2018 received a U.S. patent for the virus aided and
abetted by the Gates Foundation, SEA Defendants and others yet named to facilitate inter alia
mail-in-vote ballot use for the 2020 election of Electors of each State of several States for
whoever would be both DNC Candidates for POTUS and VPOTUS; and
9. In 2019 SEA Defendants facilitated mail-in-vote ballot use for the 2020 election of Electors of
each State of several States for both DNC Candidates for POTUS and VPOTUS without
presenting changes to NYS Constitution Article 2 Section 2 for ratification by the people
required by NYS Constitution Article XIX (5) that without ratification renders any Law void.
5
ARTICLE XIX - AMENDMENTS TO CONSTITUTION
[Amendments to constitution; how proposed, voted upon and ratified; failure of attorney-general to render
opinion not to affect validity] Section 1. Any amendment or amendments to this constitution may be proposed in the
senate and assembly whereupon such amendment or amendments shall be referred to the attorney-general whose duty it
shall be within twenty days thereafter to render an opinion in writing to the senate and assembly as to the effect of such
amendment or amendments upon other provisions of the constitution. Upon receiving such opinion, if the amendment
or amendments as proposed or as amended shall be agreed to by a majority of the members elected to each of the two
houses, such proposed amendment or amendments shall be entered on their journals, and the ayes and noes taken
thereon, and referred to the next regular legislative session convening after the succeeding general election of members
of the assembly, and shall be published for three months previous to the time of making such choice; and if in such
legislative session, such proposed amendment or amendments shall be agreed to by a majority of all the members
elected to each house, then it shall be the duty of the legislature to submit each proposed amendment or amendments to
the people for approval in such manner and at such times as the legislature shall prescribe; and if the people shall
5
10. That Cuomo Defendant approved the State Legislator passage of mail-in-vote ballot use for
election of Electors of each State of several States for both DNC Candidates for POTUS and
VPOTUS in 2019 as if for an amendment to the State Constitution Article 2 Section 2; and
11. That Cuomo Defendant approved the State Legislator passage of mail-in-vote ballot law use in
election of New York State's Electors at the 3 November and 14 December 2020 elections as
similarly done in each State of several States for both DNC Candidates for POTUS and
VPOTUS in 2020 as if an amendment to the State Constitution Article 2 Section 2 (6) - but was
not presented as such proposed amendment to the state voters vote - is not ratified ; and
12. That Cuomo Defendant and State Legislature with NYS Attorney General decided to use the
un-ratified passage of the mail-in-vote ballot law change to the State Constitution Article 2
approve and ratify such amendment or amendments by a majority of the electors voting thereon, such amendment or
amendments shall become a part of the constitution on the first day of January next after such approval. Neither the
failure of the attorney-general to render an opinion concerning such a proposed amendment nor his or her failure to do
so timely shall affect the validity of such proposed amendment or legislative action thereon. (Formerly §1 of Art. 14.
Renumbered and amended by Constitutional Convention of 1938 and approved by vote of the people November 8,
1938; further amended by vote of the people November 4, 1941; November 6, 2001.)
6
NYS Constitution Article 2 for Suffrage [Absentee voting]
§2. The legislature may, by general law, provide a manner in which, and the time and place at which, qualified voters
who, on the occurrence of any election, may be absent from the county of their residence or, if residents of the city of
New York, from the city, and qualified voters who, on the occurrence of any election, may be unable to appear
personally at the polling place because of illness or physical disability, may vote and for the return and canvass of their
votes. (Formerly §1-a. Renumbered by Constitutional Convention of 1938 and approved by vote of the people
November 8, 1938; amended by vote of the people November 4, 1947; November 8, 1955; November 5, 1963.)
§3. No person who shall receive, accept, or offer to receive, or pay, offer or promise to pay, contribute, offer or promise
to contribute to another, to be paid or used, any money or other valuable thing as a compensation or reward for the
giving or withholding a vote at an election, or who shall make any promise to influence the giving or withholding any
such vote, or who shall make or become directly or indirectly interested in any bet or wager depending upon the result
of any election, shall vote at such election; and upon challenge for such cause, the person so challenged, before the
officers authorized for that purpose shall receive his or her vote, shall swear or affirm before such officers that he or she
has not received or offered, does not expect to receive, has not paid, offered or promised to pay, contributed, offered or
promised to contribute to another, to be paid or used, any money or other valuable thing as a compensation or reward
for the giving or withholding a vote at such election, and has not made any promise to influence the giving or
withholding of any such vote, nor made or become directly or indirectly interested in any bet or wager depending upon
the result of such election. The legislature shall enact laws excluding from the right of suffrage all persons convicted of
bribery or of any infamous crime. (Formerly §2. Renumbered by Constitutional Convention of 1938 and approved by
vote of the people November 8, 1938; amended by vote of the people November 6, 2001.)
6
Section 2 for the 2020 election of Electors to facilitate both DNC Candidates for POTUS and
VPOTUS, in preparation met with Dr. Anthony Fauci and the Gates Foundation; and
13. That Cuomo Defendant issued Executive Orders for the patented CORONAVIRUS so-called
pandemic to cover the un-ratified mail-in-vote ballot law to rig election fraud anyway; and
14. That Cuomo Defendant to back-fill State budget shortfalls decided to grift CARES Act Federal
funds never letting an opportunity go to waste ordered use of the fatally flawed PCR virus test
to generate CARES act Funds and nursing home bed elevated reimbursement, to make his point
willfully murdering the elderly forced into nursing homes after He removed his own mother
15. If this were enough for the ex HUD Secretary who was HUD under secretary for community
development for the Clinton Administration before the Texas HUD grifter Henry G. Cisneros
was imprisoned, and according to Catherine Austin Fitts, the pattern of mayhem property
destruction in various Democratic controlled urban areas in States resembles the HUD
Community Development funding patterns for redevelopment funding, and it is alleged that
Cuomo Defendant, aided and abetted by the State Attorney General with oversight over State
non-profits, facilitated terrorist organizations to commit mayhem under the guise of mask
16. That the despicable activities of the New York State Democratic Party and Republican Party
Committees in control of the New York State Board of Elections along with those persons
similarly situated as Defendants among others too numerous to name were unable to launch a
candidacy for either of the parties to defeat the DJT re-election on or after the 3 November
2020 and 14 December 2020, agreed in August 2020 to the nomination of DNC Candidate
Joseph R. Biden for POTUS and DNC Candidate Kamala D. Harris for VPOTUS; and
7
17. That KAMALA DEVI HARRIS, the United States Senator for California with place for service at
112 Hart Building, Washington, DC 20510 (Harris Defendant) is not a Natural Born Citizen (NBC) in
violation of NYS EL §6-122-2 (7) is ineligible for VPOTUS office by the U.S. Constitution
Article II, Section 1, Clause 5, is aided and abetted by SEA Defendants, and that there is an
open New York Court of Claims Claim No: 135318 filed 10 September 2020 by Claimant AD
HOC NEW YORKER REPUBLICAN COMMITTEE Trustees (see Exhibit C); and
18. That Cuomo Defendant tyrannical executive orders that impose shutdown of the New York
economy interrupted the ability to finance the 2020 election, and Cuomo Defendant illegally
sought mail-in-vote ballot election funds from CCP collaborator MARK ELLIOT
ZUCKERBERG who is the CEO of FACEBOOK (Zuckerberg Facebook Defendants)- with place
for service through the NYS Secretary of State at 1601 WILLOW ROAD MENLO PARK, CALIFORNIA,
94025 as reported and acknowledged by the New York Times (see Exhibit D); and
19. That Zuckerberg Facebook Defendants throughout select New York County Subdivisions
provided a contract for grant funds to finance the 2020 election using Election Systems &
Software and Dominion Voting Systems Equipment for ballots under illegal mail-in-voting law
requirements subject to a claw back provision (see Exhibit E) violates Election Law:
Dominion Voting
1642 Allegany County ImageCast Systems
Dominion Voting
1643 Broome County ImageCast Systems
Cattaraugus Dominion Voting
1644 County
ImageCast Systems
Dominion Voting
1945 Cayuga County ImageCast Systems
7
NYS ELN Law Section 6-122-2 Designation or nomination; eligibility, restrictions
A person shall not be designated or nominated for a public office or party position who (1) is not a citizen of the
state of New York; (2) is ineligible to be elected to such office or position; or (3) who, if elected will not at the time
of commencement of the term of such office or position, meet the constitutional or statutory qualifications thereof or,
with respect to judicial office, who will not meet such qualifications within thirty days of the commencement of the
term of such office.
8
Grant Funds No. Participating County Machine Type Company
9
Grant Funds No. Participating County Machine Type Company
10
20. As such Defendants by using an un-ratified amendment that violates the New York State
giving consideration for franchise and § 17–154. for pernicious political activities; and
interference violation of the U.S. Constitution Article 2 Section 1 Clause 2 accordingly; and
22. That renders all such mail-in-voting ballots law done without State Voter ratification
compliance with the State of New York Election Law that requires individual application for
absentee voting by the State Constitution Article 2 Section 2 therefore renders each mail in vote
without permissive application void ab initio injures Plaintiff Trustees in favor of DJT with
those similarly situated, and each such vote is disproportionately diminished and diluted; and
23. Under the U.S. Const Article 2 Section 1 Clause 2 and the 12th Amendment the NYS
Legislature has plenary authority to determine the Electors for the December 14, 2020 election
of POTUS and VPOTUS does not empower the New York State Executive and or Courts per
se. On 9 December 2020 Jesuit Coadjutor and now the CCP accessory to mass murder and
election fraud with its UBS/CCP Dominion Voting Systems (DVS), and which Andrew M.
Cuomo ordered the Electors certified after the 3 November 2020 general election may only vote
24. That the Trustees were parties in interest to the case United States of America v. New York State
Board of Elections et al NDNY 2006-cv-00263 (GLS) under the 28 USC 1343 Violation of
Civil Rights that foisted the CCP's Dominion Voting Systems (8) upon NY voters using the Help
America to Vote Act (HAVA) that was Filed March 1, 2006, and alleged used in the 2006
election of Andrew M Cuomo then Attorney General of New York sworn in on 1 January
2007, and thereafter, Cuomo won the 2010 New York gubernatorial election and reelected
8
https://www.ntd.com/400-million-sec-filing-links-dominion-ubs-and-china_536295.html
11
twice after winning primaries against liberal challengers Zephyr Teachout (2014) and Cynthia
25. Analysis of each election above referenced, as a complete certified set of numbers, applies with
Bedford's Law when the leading digit d (d ∈ {1, ..., 9}) that
such set thus have the following distribution: that d is the sum
P(d) is proportional to the space between d and d + 1 on a logarithmic scale. Therefore, this is
the distribution expected if the logarithms of the numbers (but not the numbers themselves)
26. For example, a number x, constrained to lie between 1 and 10, starts with the digit 1 if 1 ≤ x < 2,
and starts with the digit 9 if 9 ≤ x < 10. Therefore, x starts with the digit
1if log 1 ≤ log x < log 2, or starts with 9 if log 9 ≤ log x < log 10. The interval [log 1, log 2] is
much wider than the interval [log 9, log 10] (0.30 and 0.05 respectively); therefore if log x is
uniformly and randomly distributed, it is much more likely to fall into the wider interval than
the narrower interval, i.e. more likely to start with 1 than with 9; the probabilities are
proportional to the interval widths, giving the equation above (as well as the generalization to
27. If it please the Court, Bedford's Law as with any natural law such as the Pareto distribution and
Price's Law, is sometimes stated in a stronger form, asserting that the fractional part of the
logarithm of data is typically close to uniformly distributed between 0 and 1; from this, the
12
28. That the results of the 3 November 2020 General Election for Defendant Harris who is not NBC
when the SEA Defendants' devised vote-by- mail law is used, such illegal votes must be
discarded as such changes the results of all down line election results and is worthy of a Court
29. Further, if the above were not enough, Defendants met with and coordinated use of the
experimentation in violation of the Nuremberg Code to transform each vaccinated New Yorker
into a full spectrum surveillance device nano-chip integrated into the person DNA as type of
developed in the PRC with the Pilgrim Society of Great Britain; and
30. Further, Jesuit Coadjutors and now the CCP sinecure mass murderer who with Anthony Fauci
and William Gates with Barack Hussein Obama and Joseph R. Biden apparently includes James
Biden who forwarded a letter to Governor Cuomo in New York via his Director of Scheduling,
Annabel Walsh (see Exhibit F) for the purpose to set up a meeting in early April with
Governor Cuomo, along with a Chinese billionaire and therefore top China leader, former Deep
State actors and the Bidens. Included in the memo were the following :
James Biden – Former VP Joe Biden’s brother who sent the email
Governor Cuomo of New York – a close friend to the Bidens
Hunter Biden – son of VP Biden and known practicing drug addict
Ye Jianming – Chairman of CEFC
Zang Jianjun – Executive Director of the Board, CEFC
(t) member of the Royal Family of Luxembourg – not sure who this is
James Gilliar – Chairman, J2CR
Rob Walker – President , J2CR
CEFC was a large Chinese conglomerate as noted above in the strategic announcement.
13
DEMAND FOR TIMELY INJUNCTIVE RELIEF
14
JOINT TRUSTEE COMPLAINT VERIFICATION AFFIDA VI!T
STATE OF NEW YORK ) STATEOFNEWYORK)
$1-Yt r:nrcJ · ss. J 5!,.
Accordingly, I, ·Christopher Earl Strunk, being duly Accordingly, I, .Harold. William Van Allen, being duly
aff~ed, depose and say tmder penalty of peJjury: afflnncd, depose and say under penalty of peJjury:
1 am a Trustee of Plaintiti AD HOC NEw YORKER l am a Tmstee of Plaintiff AD HOC NEW YORKER
REPUBLlCAN COMMITTEE. and have read the REPUBLlCAN COMMITTEE, and have read the
toregoing CO:MPLAlNT with Exhibit A thru F, toregoing COMPLAINT with Exhibit A tluu F,
against Detendants malicious tortuous interference against Defendants malicious tortuous interterence
with elections and wbo with Defendants' illegal Mail- '"ith elections and who with Defendants' illegal Mail-
In-Voting ballot without permissive application is void In-Voting ballot without pem1issivc application is void
ab initio in,jures Plaint itT Trustee in favor of DJT and ub initio i11iures PlaintilT Trustee in favor of DIT and
down ballot candidates as with U1ose similarly situated, down ballot candidates us with those similarly situated,
and each such vote is disproportionately diminished and each such vote is disproponionately diminished
and diluted sum~rs imminent in-eparable hanu in that and diluted suffers imminent irreparable harm in tbat
Defendants have illegally fashioned and used the mail- Defendants have illegally fashioned and used the mail-
in-vote law \vithoul ratification by the People. in-vote law without ratification by tlte People.
Affirmant knows the contents t11ereof apply to me as in AITmmml knows the contents ther..::of apply to rue as in
that time is of the essence with irreparable hann with that time is of the essence with irrt!parable lmmt with
likelihood of success \vith reasonable relief available to likeliliood of success with rca:;onabk relief available to
this court. and that the same is true to m. own this court, m1d that Ute same is true to my own
knowledge, except as to t.qe matters therein stated to be lmowledge, except as 1.0 the matters therein slated to be
alleged on information and beliet: and as to those alleged on information and belief, and as to those
matters I believe it to be true. am available for matters I believe it to be true, am available tor
testimony. The grmmds of my beliefs as to all matters testimony. The grounds of my beliefs as to all matters
not slated upon information and belief are a~ lollows: not stated upon intormation and belief are as foijows:
third parties, books and records, and personal third parties, books and recon.ls, and personal
knowledge.
That an Ute 3Dbuny of December in the year 2020 That on lht! flf~ay or December in the year 2020
belore me t11e undersigned, a Notary Public in and tor before me U1e undersigned, a Notary Public in and for
said State personally appeared, Christopher Enrl said State personally appeared, Harold Willinm Van
Strunk, personally lmown to me or proved to me on the Allen. personally knO\m to me or proved, to me on the
basis of satistactorv evidence to be the individual whose basis of satistactory evidence to be the individual whose
nan1e is subscribed to lhe \\~thin instrument and name is subscribed to the wititin instrument and
acknowledged to me that he atlhmed and executed the acknowledged to me that he affinned and executed the
nmne in ltis capacity, and Utat by his signature on tlte name in his capacity, and that by his signature on the
instrument, tlte individual, or the person upon behalf of instrument, l.h~ individool, or the person upon behalf of
which the individual(s) acted, executed the instnunent. which the individual(s) acted, executed the instrument
~~
Notary Public, Stat~ ofNew York
p••t ·-~"'t ~.~ ·~· 'J f
/
!{Or~.!', , - · ··1.. 1 l ; r~w York
JOELLE L. WAR GTON
= NOtartPublic, State of New York ~5
-:.- .. S9ratoga Co. #01WA6280757
- · ', JO)_m_ission Expires May 13, 20~
....
The AD HOC NEW YORKER REPUBLICAN COMMITTEE in propria persona (Plaintiff), is
a Trust Association registered with New York State Secretary of State
Exhibit A
Cuomo Defendant, aided and abetted by the State Attorney General with oversight over State
non-profits, facilitated terrorist organizations to commit mayhem under the guise of mask
compliance submission cult requirements supposedly to prevent patented CORONAVIRUS
contamination transmission
Exhibit B
AD HOC NEW YORKER REPUBLICAN COMMITTEE
Christopher Earl Strunk, Trustee
141 Harris Avenue Lake Luzerne, New York 12846-1721
(518) 416-8743 email: strunk@leader.com
~~{ RACHELA.HAYSLETTE
Notary Public, State of New York
Notary Public, Sta e of New York warren County #01HA6378601
Commission Expires July 30, 20~
KAMALA DEVI HARRIS, the United States Senator for California with place for service at 112
Hart Building, Washington, DC 20510 (Harris Defendant) is not a Natural Born Citizen (NBC) in
violation of NYS EL §6-122-2 is ineligible for VPOTUS office by the U.S. Constitution Article
II, Section 1, Clause 5, is aided and abetted by SEA Defendants, and that there is an open New
York Court of Claims Claim No: 135318 filed 10 September 2020 by Claimant AD HOC NEW
YORKER REPUBLICAN COMMITTEE Trustees
Exhibit C
State of New York Court of Claims
___________________________________________
Claimants
v. Claim
with demand by
THE STATE OF NEW YORK Order to Show Cause
for Injunctive Relief
Defend ant
1. The post office address for claimant CHRISTOPHER EARL STRUNK at his domicile
registered to vote on November 3, 2020 (see Exhibit A) is 141 Harris Avenue POB 34 Lake
2. Absent any New York Republican party leadership and or courage to act herein, Claimant is the
3. This claim arises from the acts or omissions of the defendant. Details of said acts or omissions in
correcting the description by the New York Board of Elections Law for those running for office
requirements to hold office of President of the United States (POTUS) and or Vice President of
the United States (VPOTUS) (see Exhibit C) deceptively states that citizenship status must be
"BORN A CITIZEN" as per United States v. Wong Kim Ark, 169 U.S. 649 (1898)(1) as if one of
the requirements of the US Constitution Article 2 Section 1 Clause 5 rather than the express
"NATURAL-BORN CITIZEN" (NBC) Term of Art is born on soil of citizen parents explained by
the U.S. Supreme Court (SCOTUS) in Minor v. Happersett, 88 U.S. (21 Wall.) 162 (1875) (2).
1
https://www.law.cornell.edu/supremecourt/text/169/649
2
https://en.wikisource.org/wiki/Minor_v._Happersett/Opinion_of_the_Court
1
4. The NBC term of art standard has a stricter criteria than the Wong Kim Ark decision regarding
being born a citizen created a simple test for jurisdiction for which all the elements must be true:
5. The use of “Domicile and residence” are questions of law important in many subject areas
including taxes, custody, citizenship, student scholarships (in-state vs. out-of-state), etc., and
SCOTUS defines Domicile: Mitchell v. United States, 88 US 350 – Supreme Court 1875
2
6. The use of the 14th Amendment “subject to the jurisdiction...” clause involves questions of law
Court 1873
7. The father - child relationship even after a divorce involves questions of law important herein ,
and SCOTUS defines it in: Miller v. Albright, 523 US 420 – Supreme Court 1998
3
8. The use of “Domicile” in the State of California important involves questions of law important
herein , and SCOTUS reverse a California court: Adoption of Lindsay C., 229 Cal. App. 3d 404
9. As for a uniform standard for domicile that involves questions of law important herein , SCOTUS
4
as the above figure from the birth certificate lists 2531 Regent Street Berkeley California the usual
residence for the student mother and father such is obviously student housing… a 16 unit
apartment, certainly not a legitimate residence and domicile for citizenship purposes. is listed at
https://www.propertyshark.com/mason/Property/38755137/2531-Regent-St-Berkeley-CA-94704/
10. That KAMALA DEVI HARRIS birth certificate (see Exhibit D) shows she was born to foreign
parents with temporary residence, who based upon information and belief were duly married
Jamaican non-immigrant students present in the California USA only on a non-immigrant student
visas, during which time both parents lived in Stanford University student housing and who did
11. As such KAMALA DEVI HARRIS was born a Jamaican Citizen according to the Jamaican
Constitution (3) and remains under Jamaican Jurisdiction notwithstanding the intent of the 14th
Amendment is defined under the 8 U.S.C. §1101 (a) (15) (F) statutory requirements for her
3
https://pdba.georgetown.edu/Constitutions/Jamaica/jam62.html
4
8 U.S.C. § 1101 - U.S. Code - Unannotated Title 8. Aliens and Nationality § 1101. Definitions (a) As used in
this chapter--(15) The term “immigrant” means every alien except an alien who is within one of the following
classes of nonimmigrant aliens--(F) (i) an alien having a residence in a foreign country which he has no
intention of abandoning, who is a bona fide student qualified to pursue a full course of study and who seeks to
enter the United States temporarily and solely for the purpose of pursuing such a course of study consistent
with section 1184(l) of this title at an established college, university, seminary, conservatory, academic high
school, elementary school, or other academic institution or in an accredited language training program in the
5
12. Further, and at best arguendo, under the 14th Amendment that remains to be adjudicated U.S.
Senator KAMALA DEVI HARRIS may be adjudged an "Anchor Baby" or a "Birth Right
Citizen" as a matter of dual allegiance with limited provision of Federal jurisdiction over the birth
in California when both non U.S. Citizen parents were using non-immigrant foreign student visas
to study in California in that the mother is from India and the father is from Jamaica as her
Alameda County Birth Certificate shows in Exhibit D, and her Jamaican student father at her birth
in California is under The Jamaica Constitution Order in Council 1962 made on 23rd July 1962
when laid before Parliament 24th July 1962 coming into Operation-Section 3(2) of the Order in
Council, and sections 80, 81, 94 (1) and (2), 103, 104, 111, 124 and 125 (in part) of the
Constitution on the 25th July 1962 with the remainder immediately before the 6th August 1962 at
the Court at Buckingham Palace, the 23rd day of July, 1962 Present, THE QUEEN'S MOST
EXCELLENT MAJESTY IN COUNCIL Her Majesty, by virtue and in exercise of the powers in
that behalf by subsection (1) of section 5 of the West Indies Act, 1962 or otherwise in Her vested,
is pleased, by and with the advice of Her Privy Council 1962 Jamaican Constitution designates
that KAMALA DEVI HARRIS is a Jamaican Citizen under CHAPTER II CITIZENSHIP Section 3.
Persons who become Jamaican citizens on 6th August 1962. subsection 3C - Every person born
outside Jamaica shall become a citizen of Jamaica - clause (b) on the date of his birth, in the case
of a person born on or after the sixth day of August, 1962, if, at that date, his father or mother is a
United States, particularly designated by him and approved by the Attorney General after consultation with the
Secretary of Education, which institution or place of study shall have agreed to report to the Attorney General
the termination of attendance of each nonimmigrant student, and if any such institution of learning or place of
study fails to make reports promptly the approval shall be withdrawn, (ii) the alien spouse and minor children of
any alien described in clause (i) if accompanying or following to join such an alien, and (iii) an alien who is a
national of Canada or Mexico, who maintains actual residence and place of abode in the country of nationality,
who is described in clause (i) except that the alien's qualifications for and actual course of study may be full or
part-time, and who commutes to the United States institution or place of study from Canada or Mexico;
6
13. That KAMALA DEVI HARRIS' father DONALD JASPER HARRIS status is as follows:
14. And as for the non-immigrant student Mother from India who married the non-immigrat student
Jamaican Father:
15. Jamaica as with India and Canada remain part of the British Commonwealth of Nations, and as
such arguendo, KAMALA DEVI HARRIS as well as her divorced parents remain defacto subjects
16. Further as applies herein, KAMALA DEVI HARRIS' parents divorced when she was seven, and
when she was twelve, as subjects of the Commonwealth Queen, Harris and her sister moved with
their mother Shyamala to Montreal, Quebec, Canada, where Shyamala had accepted a research
and teaching position at Jesuit McGill University-affiliated Jewish General Hospital; and
7
17. Further, KAMALA DEVI HARRIS attended a Jesuit associated French-speaking middle
graduating in 1981.
18. Arguendo, KAMALA DEVI HARRIS never renounced her Jamaican citizenship like Ted Cruz
did in regards to Canada when he decided to run for POTUS in 2016; and
19. As such, Defendant's use of the BORN A CITIZEN term that was used before 2008 until now is
intentional harmful disinformation that Claimant sues the Defendant for as it unjustly causes
Claimants loss of opportunity costs, and now in 2020 is being done all over again for KAMALA
DEVI HARRIS who is a fraudulent candidate on the ballot must be removed and or a warning to
unsuspecting voters that she is a foreigner interfering with the 2020 New York Election; and
20. Claimant has even more concrete evidentiary proof than for the CIA's POTUS Usurper Barack
Hussein Obama Claimant had for judicial use from 2008 through 2016, the Usurper still remains
ineligible to be the President of the United States Trustee / Administrator over any United States
Departments with fiduciary responsibilities the Usurper is not entitled to the emoluments of office
must be clawed back as the Usurper who denied use of Claimant's power of Attorney on January
23, 2009 the Usurper continued as a proven Indonesian and whose every action is void ab initio.
21. Nonetheless as an outlaw entity conducted an act of treason, The 2020 Democratic National
Convention (DNC) held a presidential nominating convention from August 17 to 20, 2020, at the
Wisconsin Center in Milwaukee, Wisconsin, and virtually across the United States.
22. The DNC nominated JOSEPH ROBINETTE BIDEN JR. their POTUS candidate and KAMALA
DEVI HARRIS their VPOTUS candidate, who after 20 August 2020 were certified by NANCY
PELOSI are U.S. Constitution Article 2 Section 1 Clause 5 eligible for the New York ballot.
23. That Claimant from 2008 through 2014 sought relief and exhausted his remedies to no avail;
however in the process provided the State of New York etal full and complete notice regarding
the misrepresentation using BORN A CITIZEN for those running for POTUS / VPOTUS.
8
24. In my ballot access challenge in the trial court at an IAS Term, Part 27 of the Supreme Court of
the State of New York, before Justice Arthur M. Schack held in and for the County of Kings, at
the Courthouse, at Civic Center, Brooklyn, New York, on the 11th day of April 2012 for Index
No: 6500-2011 decision and order that STRUNK in the matter of Natural Born Citizen and
associated conspiracy to be baseless claims about defendants which are fanciful, fantastic,
25. Further, on 4 March 2014 the New York State Supreme Court Appellate Division for the Second
Department Judicial panel sitting in review of Appellant's Amicus motion in Appeal Cases 2012-
05515, 2013-06335 and 2014-00297 from orders in the trial court for Index No: 6500-2011, to my
demand that it provide "for civilian due process of law" rather than the continued martial due
process of law under statutory direct authority of the POTUS Commander-in-chief over the de
facto Federal and New York State Unified Court System courts under statutory authority of 12
USC §95 and 50 USC App. §5(b) ORDERED to deny "for civilian due process of law"; and
26. Further, Strunk has been outrageously branded a delusional frivolous BIRTHER by orders in the
trial court for Index No: 6500-2011 with the largest fines ever imposed in New York history in
excess of $177,000 and as a full citizen, has been denied free access to the state courts due process
27. Further, Strunk has been denied NBC adjudication in any court that now further emboldens the
traitorous CIA and Federal Bureau of Investigation (FBI) to enlist U.S. Senator KAMALA DEVI
HARRIS born in Oakland California on October 20, 1964 to be Democratic National Committee
(DNC) Vice Presidential candidate along with Chinese Communist Party (CCP) / DNC sinecure
Presidential candidate JOSEPH R. BIDEN whose treachery together with Governor Andrew
Cuomo and too many to be named herein is an act of treason with aiding and abetting foreign
Elections has published instructions for obtaining absentee ballots that currently apply even under
the questionable Virus lockdown imposed by Governor Andrew Cuomo(see Exhibit E); and
29. That on or about July 22, 2020 Claimant contacted the Warren County Board of Elections where
Strunk-Trustee spoke with the Democratic Party Warren County Board of Elections
Commissioner Kimberly Ross to ascertain if masks are mandatory for voting at the 3 November
2020 General Election; to wit she stated that masks are voluntary and if not worn a mask or plastic
visor will be offered to wear while voting in person, and if rejected the Voter may use a machine
30. Further, if a qualified voter is ill or disabled, under election law /state constitution may request an
absentee ballot be mailed for return to the County, and the so-called vote by mail proposal shown
to be outside the New York law must be stopped or modified to prevent fraud and represents an
irreparable harm worthy of action by this Court with time as the essence; and
31. Claimant hereby demands injunctive relief for cause that the State be ordered to
a. CLARIFY FOR ALL POTENTIAL VOTERS THAT BORN A CITIZEN SUGGESTED
BY THE STATE SHOWN AT EXHIBIT C DOES NOT INCLUDE A 14TH
AMENDMENT BORN A CITIZEN INTERPRETATION, ONLY INCLUDES THE PRE
14TH AMENDMENT U.S. CONSTITUTION ARTICLE 2 SECTION 1 CLAUSE 5
NATURAL BORN CITIZEN TERM OF ART THAT REQUIRES A CANDIDATE FOR
POTUS AND OR VPOTUS MUST BE BORN ON SOIL OF CITIZEN PARENTS
ACCORDING TO THE SCOTUS; FINDINGS IN Minor v. Happersett,
88 U.S. (21 Wall.) 162 (1875) and United States v. Wong Kim Ark, 169 U.S. 649 (1898),
and
b. THAT ALL REQUESTS FOR ABSENTEE BALLOTS MAKE SUCH CLARIFICATION
and
c. THAT NOTICE IS PROMINENTLY DISPLAYED AT THE POLLS THAT KAMALA
DEVI HARRIS IS NOT A NATURAL BORN CITIZEN; and
d. Additional different relief as the court deems necessary for justice herein.
10
LOST OPPORTUNITY CLAIM AGAINST THE STATE OF NEW YORK FOR USING
"BORN A CITIZEN" DIS-INFORMATION FROM 2008 THRU 2020 INSTEAD OF
NATURAL-BORN CITIZEN
~ 1XJ This Claim is served and filed within 90 days of accrual on or about 20 August 2020.
By reason of the foregoing, Claimant was damaged in the amount of$ 388,395 and Claimant demands
judgment against the Defendant(s) for said amount.
VERIFICATION
STATE OF NEW YORK )
COUNTY OF WARREN )
Christopher Earl: Strunk, being duly so affirmed, deposes and says that deponent is the Claimant in
the within action; that deponent has read the foregoing Claim and knows the contents thereof; that the
same is true to deponent's own knowledge, except as to matters therein stated to be alleged upon
information and belief, and that as to those matters, deponent believes it to be true.
COLLEEN B. COOK
(\ cu \~ Q1i;U 0
Notary Public, State of New York
warren Co. #01C06045260
Mary Public:staTe6f New York Commission Expires July.24. 20~
11
State of New York Court of Claims
--------
Claimants
v. Claim
with demand by
THE STATE OF NEW YORK Order to Show Cause
for Injunctive Relief
Defendant
Exhibit A
VOTE IN THE GENERAL ELECTION NOVEMBER 3, 2020
- - -
NONPROFIT (
Warren County Board of Elections U.S. POSTAGE
-k LAKE GEORGI
1340 State Rte. 9 Pl·3
Lake George, NY 12845 * -a *
* ~fitcTitfN*MAii
CHRISTOPHERSTRUNK
141 HARRIS AVE
LAKE LUZERNE, NY 12846
IMPORTANT VOTER INFORMATION, FOR MORE INFORMATION VISIT OUR WEBSITE https:Uwww.warrencountyny.gov/bc
State of New York Court of Claims
___________________________________________
Claimants
v. Claim
with demand by
THE STATE OF NEW YORK Order to Show Cause
for Injunctive Relief
Defend ant
Exhibit B
426273 2020 Jun 26 PM1 0:27
L _j
THE ABOVE SPACE IS FOR FILING OFFICE USE ONLY
DEBTOR'S EXACT FULL LEGAL NAME msert only Ollfl d bt or name (1 •oc 1b) - d o no t a bb revm e or com me names
"
1a. ORGANIZATION'S NAME AD HOC NEW YORKER REPUBLICAN COMMITTEE
1c. MAILING ADDRESS 141 HARRIS AVENUE CITY LAKE LUZERNE STATE IPOSTAL CODE COUNTRY
NY 128461721 USA
1d. SEE INSTRUCTIONS IiDD'L INFO RE 118. TYPE OF ORGANIZATION 1f. JURISDICTION OF ORGANIZATION 1g. ORGANIZATIONAL ID #, 1f any
g~~:;~ZATION ASSOCIATION TRUST I STATE OF NEW YORK I NONE
I
lxl NONE
2 ADDITIONAL DEBTORS EXACT FULL LEGAL NAME - msert onIy Q!l!! d b< or name (2 'oc 2b) do noI abb rev1a e or com b me names
2a. ORGANIZATION'S NAME
"
2d. SEE INSTRUCTIONS I:DD'L INFO RE 1 12e. TYPE OF ORGANIZATION 2f. JURISDICTION OF ORGANIZATION 2g. ORGANIZATIONAL ID #, 1f any
g~~:;~ZATION I I I nNONE
3 SECURED PARTY S NAME (or NAME ofTOTAL ASSIGNEE 0 I ASSIGNOR SIP) - 1nsert on Iy Ollll: secure d ,,rty name (3'oc 3b}
3a. ORGANIZATION'S NAME
OR 3b. INDIVIDUAL'S LAST NAME Strunk FIRST NAME Christopher MIDDLE NAME Earl SUFFIX
TRUSTEE
3c. MAILING ADDRESS 141 HARRIS AVENUE CITY LAKE LUZERNE STATE IPOSTAL CODE COUNTRY
NY 128461721 USA
FILING OFFICE COPY- NATIONAL UCC FINANCING STATEMENT (FORM UCC1) (REV. 05/22/02)
Filing Number-202006268275667
426273 2020 Jun 26 PM1 0:27
OR
9b. INDIVIDUAL'S LAST NAME IIRSTNAME I
MIDDLE NAME,SUFFIX
10. MISCELLANEOUS:
11d. SEE INSTRUCTIONS lADD'L INFO RE_ ltte. TYPE OF ORGANIZATION 111. JURISDICTION OF ORGANIZATION 11g. ORGANIZATIONAL 10 #, 1f any
~~~:;~ZATION I I I nNONE
12. XI ADDITIONAL SECURED PARTY'S ~ n ASSIGNOR SIP'S NAME- insert only oo..e name (12a or 12b)
12a. ORGANIZATION'S NAME
OR
12b. INDIVIDUAL'S LAST NAME Van Allen FIRST NAME Harold MIDDLE NAME William SUFFIX
TRUSTEE
12c. MAILING ADDRESS 351 NORTH ROAD CITY HURLEY STATE IPOSTALCODE COUNTRY
NY 12443 USA
13. Th1s FINANCING STATEMENT covers D timber to be cut or 0 as-extracted 16. Additional collateral description:
collateral. or is filed as a 0 fixture filing.
14. Description of real estate:
0
R
I
DebtorisaTRANSMITTING UTILITY
effective 30 years
FILING OFFICE COPY- NATIONAL UCC FINANCING STATEMENT ADDENDUM (FORM UCC1Ad) (REV. 05/22/02)
State of New York Court of Claims
___________________________________________
Claimants
v. Claim
with demand by
THE STATE OF NEW YORK Order to Show Cause
for Injunctive Relief
Defend ant
Exhibit C
9f7/2020 Running for Office 1New Vorl< State Board of Elections
Please refer to the Official Political Calendar for all filing dates.
Additional information may be obtained by calling the New York State Board of Elections at (518) 474-
6220 or you r ~ board of elections.
jOFFICE
President of
the United
c:JDS
II CITIZENSHIPII AGE II~
~~
R=ES=I=
DE=N:=C=Y==========lll STATUTE
114 years In country IUnited
b~
Constltut1on
I
!~===~~===~ = :=Art=·=1=§3=~1
~Y.$. Citizen 30 Resident of state 5 years immediately preceding New York
Governor/ Lt. years election State
Governor Constitution
Attorney Art. IV§ 2
General and Art. V §
Comptroller 1
D
Citizen 7 Resident of state when elected United
Representative years States
in Congress Constitution
Art. I §2
New York Citizen 18 NewYork
years Resident of state for 5 ~ars and resident of
State Senator
State . .
New York
State
district for 12 months immediately preceding ~~n~~~~on
election. (In a redistricting year, may be a resident ·
Assembly
of county for 12 months immediately preceding p bll
the election.) ~c:rs law
§3
These sample forms were prepared by the State Board of Elections. They are all in Acrobat PDF format.
You will need the Adobe (TM) Acrobat Reader to view and print them.
-
Electronic s ignatures are not acceptable.
-- r:
• SAMPLE INDEPENDENT NOMINATING PETJTION (~ 204KB) (print on legal size paper)
• SAMPLE oppoRTUNITY TO BALLOT PETITION ( _. 535KB) (print on legal size paper)
• SAMPLE VILLAGE DESIGNATING PETITION ( 138KB) (print on legal size paper)
• SAMPLE VILLAGE DESIGNATING PETITION- COUNTY 144KB) (to be used if Election is
run by the County Board of Elections) (print on legal size paper)
• SAMPLE VILLAGE INDEPENDENT NOMINATING PETITION (~ ~). (print on legal size
paper)
• SAMPLE VILLAGE INDEPENDENT NOMINATING PETITION - COUNTY(":.. 1431<8) (to be
used If Election is run by the County Board of Elections) (print on legal size paper)
• SAMPLE COVER SHEETS(~~)
• SAMPLE CERTIFICATE OF ACCEPTANCE 6-146 (For Use BY. Candidate)_(~ 73.9KB)
https:ll www.etectlons.ny.gov/RunnlngOflice.html 2113
State of New York Court of Claims
___________________________________________
Claimants
v. Claim
with demand by
THE STATE OF NEW YORK Order to Show Cause
for Injunctive Relief
Defend ant
Exhibit D
OFFICE OF CLERK-RECORDeR
; COUNTY iOF ALAMEDA
OAKLAND, CAUFORNIA
../
{ Tri-V!IHey Office ~
http:/Jwww.acgov.org/alroi{orld~m.IBitttl.htm ,line order
~~T~~~:v,.O~~~~Rl:f: 111111111111111111111111111
Tlis It a.l!Ue and N~Ct ll!J)rOductlon ol tho docwnent ol~ reg18Mred 0000 1103 z
andpt-d on tile I~ llle.onice olttte Alameda Co!lniYC'Mk>RIOOilk!r. ~ 'iJdJJ
MA~ l 0 2019 Mmissa Wilk
• ·-'- ~• • ·-- COUNTYCLERK-IIECOIIDER
Tht•cOII:.tl..,aot"*"f\IMeor.pMtMS4fta:n....,_-..ct6otO.r.r.phl)flttf.th•cW•. ••l•~·..,.e&._t::t.ir•lt•••
COUNTY OF ALAMEDA
OAKLAND, CAUFORNIA
- - - - - - - - - - -- -
Th-Valley Office
http:/lwww.acgoll.org/8Udilor/clerXJbdml8l<th.hlm onlm. order
~~""!~~~~~RE~
This Ia allue .not eXIICI' reprodui:llon olthe dowi!Mill ofllcllltv ~~~~~~d
IIIIIIIIIIBIIIIIIIIIIIIII
and ~)~ewe~ Clll llle In fila ollica of the Alameda ~ Clarii-AeooiiSal.
bAlfiMU~O - -
MAR 'IO 20t9
- -- - - -- -- - -
Claimants
v. Claim
with demand by
THE STATE OF NEW YORK Order to Show Cause
for Injunctive Relief
Defend ant
Exhibit E
917/2020 Absentee Voting 1New York State Board of Elections
• AboutUs
• EAQ.
• ContactUs
• Site Index
Absentee Voting
1. Absent from your county or, if a resident of New York City absent from the five boroughs, on
Election Day.
2. Unable to appear at the polls due to temporary or permanent illness or disability (temporary
illness includes being unable to appear due to risk of contracting or spreading a communicable
disease like COVID-19).
3. Unable to appear because you are the primary care giver of one or more individuals who are ill
or physically disabled.
4. A resident or patient of a Veterans Health Administration Hospital.
5. Detained in jail awaiting Grand Jury action or confined in prison after conviction for an offense
other than a felony.
You may apply for an absentee ballot in any of the following ways:
You can download a PDF verson of the New York State Absentee Ballot Application Form:
https:/lwww.elections.ny.govNotingAbsentee.html 1/3
917/2020 Absentee Voting 1New Yoi'K State Board of Elections
Upon completion, applications must be mailed to your countv board no later than the seventh
day before the election or delivered In person no later than the day before the election.
• By sending a letter to your 9.lli.!J..ty~ of elections. The letter must contain the following
Information:
1. Name and date of birth of the voter
2. the address where you are registered
3. an address where the ballot is to be sent, and
4. the reason for the request.
If you apply by letter, an application form will be mailed with your ballot. The application
form must be completed and returned with your ballot.
If you cannot plclc up your ballot, or will not be able to receive it through the mail, you have the
right to designate someone to pick it up for you. Only that person designated on your application
may pick up and deliver your ballot.
If you are permanently ill or disabled, you have the right to receive an Absentee Ballot for each
subsequent election without further application. Simply file an application with your county board
of elections indicating permanent Illness or physical disability.
You will then automatically receive an absentee ballot for every election until your registration is
canceled.
If you are visually impaired or otherwise disabled, such that your disability requires you to use an
accessible absentee ballot application, you have two accessible options to request a ballot on
this page, either using the Accessible Electronic Ballot Application Portal:
When Ia It due?
You must apply online, postmark, email or fax a completed application or letter request for the General
Election Absentee ballot no later than 7 days (October 27, 2020) before the election. You may apply in-
. person up to the day before the election (November 2, 2020). You may file an application at any time
before the deadlines, but ballots will be mailed out beginning on or about September 18, 2020.
(PLEASE BE AWARE THAT DESPITE THE ABOVE DEADLINES THE POST OFFICE HAS ADVISED
THAT THEY CANNOT GUARANTEE TIMELY DELIVERY OF BALLOTS APPLIED FOR LESS THAN 15
DAYS BEFORE AN ELECnON.)
• Once your receive the ballotj marl< the ballot according to your cnoices for each office following
the instructions on the ballot
• Once you have completed marking your ballot fold it up and place it in the Security Envelope.
(This envelope will have a place for your signature.)
• Sign and date the outside of the Security Envelope.
• Seal the Security Envelope.
https://www.elections.ny.govNotingAbsentee.html 2/3
9/7!2020 Absentee Voting I New York Slate Board of Elections
• Place the Security Envelope in the Return Envelope. (This envelope will have the return address
of your county Board of Elections on the outside and should have a logo that reads, uOfficial
Election Mail"}
• Seal the Return Envelope.
• You may return the ballot in any of the following ways:
1. Put it in the mail ensuring it receives a postmark no later than November 3rd.
2. Bringing it to the County Board of Elections Office no later than November 3rd by 9pm.
3. Bringing it to an early voting poll site between October 24th and November 1st
4. Bringing it to a poll site on November 3rd by 9pm.
When mailing your completed ballot, the USPS recommends that voters allow enough time for ballots to
be returned to the Board, which is generally seven days ahead of the general election. New York
State requires your ballot to be both postmarked by November 3, 2020 and received by our Board by
November 10, 2020. Voters who mail in their ballots on Election Day must be aware of the posted
collection times on collection boxes and at the Postal Service's retail facilities, and that ballots entered
after the last posted collection time will not be postmarked until the following business day.
Even if you request or cast and return an absentee ballot, you may still go to the polls and vote in
person. The Election Law recognizes that plans change. The Board of Elections is required to check the
poll book before canvassing any absentee ballot. If the voter comes to the poll site, on Election Day or
during early voting and votes in person, the absentee ballot is set aside and not counted.
https:/lwww.elections.ny.govNotingAbsentee.html
313
Cuomo Defendant illegally sought mail-in-vote ballot election funds from CCP collaborator
MARK ELLIOT ZUCKERBERG who is the CEO of FACEBOOK (Zuckerberg Facebook
Defendants)- with place for service through the NYS Secretary of State at 1601 WILLOW ROAD MENLO
PARK, CALIFORNIA, 94025 as reported and acknowledged by the New York Times
Exhibit D
12/26/2020 N.Y. Voting Officials Need Money. They Were Told to Go to Zuckerberg. - The New York Times
https://nyti.ms/3kZZEHE
Oct. 2, 2020
ALBANY — After the June primary in New York State unraveled under a mass of problems, elections
officials immediately issued a plea: To stand any chance of handling the five million absentee ballots
expected on Election Day, far more state funding would be needed.
But with no state money in sight, the State Board of Elections had another solution in mind.
It recommended that county boards apply for grants — not from the state, but from a nonprofit
foundation, the Center for Tech and Civic Life, that are backed by a $250 million donation from Mark
Zuckerberg, the chief executive of Facebook, and his wife, Priscilla Chan, who said they were seeking to
“preserve the integrity of our elections.”
The recommendation seemed curious: It was Facebook’s lack of oversight of disinformation in the 2016
election, after all, which led to accusations of electoral meddling and strong condemnations from
Democrats and some Republicans.
Election officials have insisted that they will likely need up to $50 million for extra staff, equipment and
mailings to avoid a repeat of the primary mess, when some congressional races went weeks without
results and tens of thousands of ballots were disqualified.
By far the largest board seeking such help is the New York City Board of Elections, where the worst of
the problems arose in the June primary, and which has already suffered an embarrassing mistake: As
many as 100,000 voters in Brooklyn received faulty absentee ballots this week because of mistake by a
vendor.
The city’s problems drew ridicule from President Trump, who cited them in his unfounded claims that
mail-in voting was susceptible to fraud. Mr. Trump wrote on Twitter this week, “Big Fraud, Unfixable!”
In New York, local boards of elections are largely autonomous, operating independently of mayors or
county executives. And although the boards follow regulations and guidance issued by the State Board
of Elections, there are often disparities in how each county handles Election Day issues.
Yet there seems to be consensus among the local boards that they sorely need financial assistance to
deal with a November election like no other.
Good government groups ridiculed the idea that the state, which has a $175 billion budget, was directing
local election officials to get help from private sources funded by Facebook’s riches.
“Something is seriously wrong with New York State’s democracy when less than two months before this
November’s historic vote, local boards of election are so broke they are pleading for funding from a
charity,” five groups, including the state chapters of Common Cause and the League of Women Voters,
https://www.nytimes.com/2020/10/02/nyregion/voting-absentee-ballots-ny.html 1/4
12/26/2020 N.Y. Voting Officials Need Money. They Were Told to Go to Zuckerberg. - The New York Times
wrote in a letter to the governor in mid-September, asking for $50 million in emergency election funds.
Results from the June primary in New York were delayed for weeks, as a deluge of
absentee ballots overwhelmed elections workers. Victor J. Blue for The New York Times
Gov. Andrew M. Cuomo’s administration, however, was blunt about the unlikelihood of extra state
funding for local boards.
“Unless the advocates want to lend us their money tree, in the absence of additional federal funding
there isn’t any,” Rich Azzopardi, a senior adviser to the governor, said.
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The city board did not seek a specific grant amount, but said any financial support would help backfill a
number of costly improvements, including purchasing $2 million in high-speed scanners for each
borough, staffing up and finding larger counting locations — a necessity for the often arduous process of
tallying absentee ballots.
https://www.nytimes.com/2020/10/02/nyregion/voting-absentee-ballots-ny.html 2/4
12/26/2020 N.Y. Voting Officials Need Money. They Were Told to Go to Zuckerberg. - The New York Times
But in the city and elsewhere in the state, election officials say that additional expenses — hiring
temporary employees, increased postage and printing costs, personal protective equipment for poll
workers — are secondary at this point to making sure the public has confidence in election results and
fairness.
“We have a serious and awesome responsibility to participate in the presidential election process, and
we will do that,” said Michael Ryan, the executive director of the New York City Board of Elections. “And
funding will not be the impediment.”
Officials say they are also struggling to honor a series of executive orders related to the election issued
by Governor Cuomo, who is facing a multibillion budget deficit and has given no indication that local
boards should expect financial help from Albany.
“The state has given a lot of directives and changes, but not a lot of resources to implement them,” said
Jason Schofield, the Republican Party commissioner in Rensselaer County, east of Albany. “It’s easy to
tell people what to do.”
With the state still recovering from the coronavirus crisis and wary of a second wave, Mr. Cuomo has
greatly increased access to absentee voting, allowing all the state’s nearly 13 million registered voters to
request an absentee ballot if they cannot show up at a polling location because of the risk of contracting
coronavirus.
The appeal of vote-by-mail in the middle of a pandemic seems undeniable: On Friday, Mr. Ryan said the
city had already processed about 560,000 ballot applications. Many suburban and upstate counties were
experiencing similar surges. In Onondaga County, which includes Syracuse, officials are girding for
125,000 absentee ballots, about eight times its record for a general election. On Long Island, officials
have already received more than 250,000 requests for absentee ballots.
The expansion of absentee voting to every voter is one of a raft of new election rules and responsibilities
that the governor has recently announced, seemingly determined to answer criticism of the state’s
performance in the primary. They include requiring boards of elections to allow ballots to be dropped at
board offices and polling locations; ordering a redesign of absentee ballots; and requiring boards to
submit staffing plans to the state.
Mr. Cuomo also signed several bills in late August to ease rules surrounding disqualification of ballots,
including allowing those received the day after the election without a postmark to be counted. The
primary saw tens of thousands of disqualified ballots, often for minor issues like missing signatures on
envelopes or envelopes sealed with tape, not saliva; a new law will allow those ballots to be “cured,”
after election officials contact voters.
But each of those changes have also eaten up valuable time and money, election officials say.
The state received $20 million in federal funds that were earmarked for election-related costs driven up
by the pandemic, through the federal CARES Act, though the Cuomo administration said that money had
largely been spent. Mr. Cuomo has repeatedly pleaded for federal help for the state and its localities,
though negotiations on additional coronavirus-related aid is stalled in Washington.
Mr. Cuomo, a third-term Democrat, said he had offered extra staff — including National Guard troops —
to all local boards, often without response.
https://www.nytimes.com/2020/10/02/nyregion/voting-absentee-ballots-ny.html 3/4
12/26/2020 N.Y. Voting Officials Need Money. They Were Told to Go to Zuckerberg. - The New York Times
“It’s a person-power function, staffing function — that’s the main factor in running the election for
them,” Mr. Cuomo said last week. “We have personnel that we can make available, but they have to tell
us what they need and they have to be organized.”
But some election officials acknowledged that they were uncertain how much this election year would
cost.
“I’ll be candid: I don’t think my finance department has figured out what we spent yet,” said Kristen Z.
Stavisky, the Democratic Party’s commissioner of elections in Rockland County, northwest of the city,
noting the “astronomical” cost of postage of thousands of applications and postage-paid return ballots.
“The CARES grant could never cover everything that we’re paying for.”
Nicholas LaLota, the G.O.P. commissioner in Suffolk County on Long Island, echoed that, estimating that
the county would incur about $2 million in expenses in this year’s election, including spending some
$150,000 on things like hand sanitizer and extra pens to keep polling places clean.
An executive order from Mr. Cuomo also required the counties send “an informational mailer to every
Suffolk household that has a voter in it,” something Mr. LaLota said cost $1 million alone in a county with
more than one million registered voters.
“Ultimately, Suffolk County is going to have to pay a rather large bill,” Mr. LaLota said.
Dustin M. Czarny, the Democratic commissioner in Onondaga, said his county had already spent the
$260,000 it received from the federal CARES Act, and had applied to the Center for Tech and Civic Life to
“offset money that we’re already spending.”
The center — which is based in Chicago and has also been backed by Google — said in a statement that
it was “still actively processing grant applications,” but had received about 40 from New York, part of
some 1,100 nationwide.
Late last month, there was good news for Onondaga: It won $280,000 from the Zuckerberg-funded
initiative, something county officials said would allow the temporary hiring of four additional employees,
on top of the six the county had already hired for the sprint to November.
“It’s 12-hour days, 7 to 7, and we’ve pretty much told everyone they are working every Saturday until the
election,” Mr. Czarny said. “And some Sundays, too.”
https://www.nytimes.com/2020/10/02/nyregion/voting-absentee-ballots-ny.html 4/4
Zuckerberg Facebook Defendants throughout select New York County Subdivisions provided a
contract for grant funds to finance the 2020 election using Election Systems & Software and
Dominion Voting Systems Equipment for ballots under illegal mail-in-voting law requirements
subject to a claw back provision violates Election Law
Exhibit E
12/26/2020 COVID-19 Response Grants – Center for Tech and Civic Life
COVID-19 RESPONSE
GRANTS
We provide funding
to U.S. local election
offices to help
ensure they have the
critical resources
they need to safely
serve every voter in
2020.
https://www.techandciviclife.org/our-work/election-officials/grants/ 1/5
12/26/2020 COVID-19 Response Grants – Center for Tech and Civic Life
The Center for Tech and Civic Life (CTCL) has been
thrilled to expand our COVID-19 Response Grant program
to all U.S. local election jurisdictions. Backed by a
generous $250M contribution, CTCL received grant
applications from over 2,500 local election jurisdictions
across the country to help ensure they have the staffing,
training, and equipment necessary so this November
every eligible voter can participate in a safe and timely
way and have their vote counted.
https://www.techandciviclife.org/our-work/election-officials/grants/ 2/5
12/26/2020 COVID-19 Response Grants – Center for Tech and Civic Life
https://www.techandciviclife.org/our-work/election-officials/grants/ 3/5
12/26/2020 COVID-19 Response Grants – Center for Tech and Civic Life
https://www.techandciviclife.org/our-work/election-officials/grants/ 4/5
12/18/2020 How Mark Zuckerberg's Millions Made Election 2020 Go Smoothly : NPR
ELECTIONS
FROM
Detroit election workers count absentee ballots for the 2020 general election at TCF Center on Nov. 4.
Election offices around the U.S. say they couldn't have carried out this year's challenging election without
https://www.npr.org/2020/12/08/943242106/how-private-money-from-facebooks-ceo-saved-the-2020-election 1/14
12/18/2020 How Mark Zuckerberg's Millions Made Election 2020 Go Smoothly : NPR
Bill Turner knew he had a tough job. He took over as acting director of voter
services in Chester County, Pa., in September, just two months before a
divisive presidential election amid a pandemic. Huge voter turnout was
expected, and COVID-19 required election managers like Turner to handle
mail-in ballots on a scale they'd never seen and confront the threat of their
staffers becoming sick.
These challenges had forced many election offices to burn through their
budgets months earlier. Turner had previously served as the county's
emergency manager, experience that seemed apt for overseeing an election
that many observers feared would become a catastrophe.
https://www.npr.org/2020/12/08/943242106/how-private-money-from-facebooks-ceo-saved-the-2020-election 2/14
12/18/2020 How Mark Zuckerberg's Millions Made Election 2020 Go Smoothly : NPR
Mark Zuckerberg, the founder and CEO of Facebook, and Priscilla Chan, his wife, donated $350 million
to a nonprofit that gave grants to election officials around the United States.
Ian Tuttle/Getty Images
With a tight budget and little help from the federal government, Chester
County applied for an election grant from the Center for Tech and Civic Life, a
previously small Chicago-based nonprofit that quickly amassed hundreds of
millions of dollars in donations to help local election offices — most notably,
$350 million from Facebook CEO Mark Zuckerberg and his wife, Priscilla
Chan.
"Honestly, I don't know what we would have done without it," Turner said.
The Center for Tech and Civic Life gave grants to more than 2,500
jurisdictions this year to help departments pay for election administration.
The money arrived as historically underfunded election department budgets
were sapped from unforeseen purchases during the primaries and were forced
to spend money on election workers, postage and printing for the increasing
number of voters who wanted to vote by mail.
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+
−
Jurisdiction Type
County
City/Town/Other
Notes
Eighty-six towns or townships in Michigan and Wisconsin are not shown because there are multiple jurisdictions with the
same name in these states and the source data did not specify which one received a grant. In addition to the local
grants, a few state election administrators, such as those in North Carolina and Pennsylvania, received grants.
Source: Center for Tech and Civic Life, grant applications and agreements from local election officials
Credit: analysis by APM Reports
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The nonprofit gave Chester County $2.5 million for the election, which is more
than the county's 2020 budget for voting services.
Philadelphia
$6M
$5M
$4M
$3M
$2M
$1M
$0M
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Chester County
$1.5M
$1.25M
$1M
$0.75M
$0.5M
$0.25M
$0M
Early Voting Equipment Outreach PPE Staffing/Pay Other
Notes
"Other" requests for funds include the costs of renting a vehicle for a mobile voter-services site in Chester County and
storage and maintenance costs for mail-ballot processing equipment in Philadelphia.
Turner used the grant to buy 14 drop boxes for ballots, pay staff to watch those
sites and purchase body cameras that recorded employees collecting ballots
from the drop boxes. He also spent a large portion of the grant on additional
equipment and people to ensure that ballots were mailed out and counted
quickly. The county processed 150,000 mail ballots for the November election
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in 36 hours. Without the new equipment and personnel, he said, it would have
taken a week or longer.
YouTube
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Election precinct cases containing ballots, election materials and keys to voting machines are held under
guard by the Allegheny County Police at the Allegheny County elections warehouse on Nov. 4 in
Pittsburgh.
Jeff Swensen/Getty Images
The private money was needed in part because the federal government hadn't
provided enough funding. Congress allocated $400 million in March for
election services, but that was just a tenth of what some officials said was
needed.
With little action from Congress, the private sector, led by Zuckerberg and
Chan, stepped up. The couple awarded $400 million to nonprofits for election
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assistance — with most of it going to the Center for Tech and Civic Life.
The full extent of the grants isn't known. The Center for Tech and Civic Life
declined repeated interview requests from APM Reports to discuss the
funding and how it was used. In late October, the group listed the jurisdictions
that received funding on its website but didn't disclose dollar amounts or
funding priorities for each jurisdiction.
Milwaukee
$1M
$0.8M
$0.6M
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$0.4M
$0.2M
$0M
Early Voting Equipment Outreach PPE Staffing/Pay Other
Racine
$0.4M
$0.3M
$0.2M
$0.1M
$0M
Early Voting Equipment Outreach PPE Staffing/Pay Other
Notes
"Other" requests for funds include Racine's request for a mobile precinct and both cities' request for drop boxes and
signage.
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Some jurisdictions received grants that were a small fraction of their election
budgets, while others saw theirs increase several times over. Suddenly,
election administrators who had had to scrounge for resources could "fund
their dream election," according to Howard.
In the weeks since the election, allies of Trump have included the Center for
Tech and Civic Life's grants in their voter fraud conspiracy theories. They have
challenged the legality and neutrality of the grants, claiming that the funding
was aimed at boosting Democratic turnout.
But an APM Reports analysis of voter registration and voter turnout in three
of the five key swing states shows the grant funding had no clear impact on
who turned out to vote. Turnout increased across the U.S. from 2016. The
APM Reports analysis found that counties in Pennsylvania, Georgia and
Arizona that received grants didn't have consistently higher turnout rates than
those that didn't receive money.
An election worker scans mail-in ballots at the Clark County Election Department on Oct. 20 in North Las
Vegas, Nevada.
Ethan Miller/Getty Images
Officials with the Center for Tech and Civic Life and government officials have
defended themselves in court and in written statements by saying the goal was
to ensure safe voting options during the pandemic.
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While some election officials see little difference between private and
government funding for elections, other officials are deeply worried about the
precedent that the private grants may set. They say private donors could have
a personal agenda. For example, Zuckerberg may have wanted to improve his
public image after years of criticism that the misinformation and divisive
rhetoric on Facebook have damaged democracies around the world.
"It's really important that it's a one-time thing," said Rachael Cobb, associate
professor of political science and legal studies at Suffolk University in Boston.
Cobb said the private money was critical for election administration this year,
"but over time, it in and of itself is corrosive." She said continuing to use
private money for such purposes "sullies [the election] in a way that we don't
need it to be sullied at all."
But other election analysts say private funding is the best option if the federal
government isn't going to commit to sustainable long-term funding for
election offices.
They also say the grants helped avert a potential disaster where long lines,
missing mail and slow counting could have led Trump to further question the
integrity of results in Pennsylvania, Georgia and Arizona.
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James Biden who forwarded a letter to Governor Cuomo in New York via his Director of
Scheduling, Annabel Walsh for the purpose to set up a meeting in early April with Governor
Cuomo, along with a Chinese billionaire and therefore top China leader, former Deep State
actors and the Bidens
Exhibit F