complaint 11-28-12 6pm

7/30/2019 Complaint 11-28-12 6pm

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STATE OF NEW YORK

SUPREME COURT - ALBANY COUNTY

___________________________________________

ROBERT L. SCHULZ, HENRY L. HAMILTON,

AL BELARDINELLI, ANDREA STUKAS,

JOHN I. MINERD, RITA EDWARDS, CARL EDWARDS,

EVELYN LONGLEY, DENNIS B. SWEENEY,

JAMES M. WALKER, ROBIN G. CARR, ROBERT E. RICE,

JOHN W. WALLACE, TIMOTHY A. CHICHESTER,

ZACHARIAH A. CHICHESTER, EMANUELE

MARINARO, PHILIP POLIZOTTO, KENNETH L.

HOLMES, JULIANNE M. THOMPSON, JOHN RUS VERIFIED COMPLAINT

THOMPSON, CAROL POLINER, JENNA POLINER,

ELEANOR CORCORAN, JAMES CORCORAN, INDEX NO. ___________

KENNETH C. SCHOLZ, VICTORIA POCZKALSKI,EDWARD L. MCCARTY, MICHAEL J. BRITT,

RICHARD C. BARRETT, SHELBY BARRETT, STEVEN

GLICK, CHRISTOPHER J. NICHOLS, LOUINE M. KOLB,

JOHN L. SHELTER, JOHN MARTIN, JOHN L.

BOSWORTH II, MICHAEL R. BELL, JOHN S. HUMPHREY,

JEFFREY L. STEVENS, JOHN C. DEWITT, KAY S.

HOFFMAN, BEVERLY J. HURLEY, BART S. BONNER,

DEBRA THOMPSON, ESTELLA A. HART, LAURA L.

STEVENS, RONALD G.MOORE, DAVID WILLIAM BOWER,

STEPHEN KRAEGER, JANE WOODWARD, SUSAN J.ENGLERT, JAMES P. DELANEY, EDWARD A. GARTZ,

RALPH ERIC SCHNACKENBERG, JULIA S. GAMBINO,

ANDREAS MILONIS, MARK AXINN, DONALD G. HOBEL,

EDWARD D. PETTITT, JANET MARTIN, MYRON D.

ANNIS, MARTHA A. FRANCIS, RITA D. LARSON,

THOMAS J. LARSON, ROBERT ELLISON, JOANNE

WILDER, MARY ANN BUERMAN, TANYA PARROW,

GEORGE G. RADFORD, PATRICIA M. RADFORD,

ANTOINETTE M. BLACK, HARVEY E. DAVIES, JAMES M.

DOOHER, KEVIN T. COTE, ROBERT SPENCER, MYRNA

A. THAYNE, PRISCILLA TAMARO, GEORGE TAMARO,

DAVE CRAWMER, EDWARD M. STEHLIN, MARY ANN

PENNELL, NANCY W. FOSTER, DALTON P. FOSTER,

DONALD R.WHITE, CHAD H. CURRIN, WILBUR W. CARD,

VANESSA PARSONS, HARVEY KASH, GARY L. PERRY,

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DENVER L. JONES, KATHLEEN C. ELLIOTT, VIVIAN Y.

WADLIN, JUDITH M. WHITMORE, JOHN SALVADOR, JR.,

ANTHONY FUTIA, JR., and CHRISTOPHER J. ENGLERT

- Plaintiffs-Petitioners

-against

ANDREW M. CUOMO and all others similarly situated;

DEAN G. SKELOS and all others similarly situated;

JONATHAN LIPPMAN and all others similarly situated;

MICHAEL R. BLOOMBERG and all others similarly situated;

DANNY DONAHUE and all others similarly situated;

JOHN L. STIPO and all others similarly situated;

ED COX and all others similarly situated;

STEPHANIE MINER and all others similarly situated.- Defendants-Respondents

__________________________________________

PLAINTIFFS-PETITIONERS, each and every one listed in the caption above allege:

1. This is an action for declaratory and injunctive relief pursuant to CPLR 3001.

2. The relief requested herein is a judgment and order:

a) declaring it to be a conflict of interest for defendants to be delegates at any New York

State Constitutional Convention, and

b) permanently enjoining defendants and all similarly situated from becoming delegates

at any future New York State Convention, and

c) for such other and further relief as to the court may seem just and proper.

JURISDICTION

3. Section 3001 of the CPLR provides that a court "may render a declaratory judgment" to

resolve "the rights and other legal relations of the parties to a justiciable controversy."

“The supreme court may render a declaratory judgment having the effect of a final judgment as

to the rights and other legal relations of the parties to a justiciable controversy whether or not

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further relief is or could be claimed. If the court declines to render such a judgment it shall state

its grounds.” CIVIL PRACTICE LAW AND RULES, SECTION 3001.

4. The statute is broad in scope. James v. Alderton Dock Yards, Ltd ., 256 N.Y. 298, 305(1931).

5. There is no inherent limitation on the type of declaratory relief available under the

Declaratory Judgment Act, CPLR 3001. Maguire v. Monaghan, 206 Misc. 550, 555, (Sup.

Ct. N.Y. County 1954), afl'd mem., 285 App. Div. 926 (1st Dep't 1955);

6. Plaintiffs have an individual, implied constitutional Right, a legally protected interest, to a

pathway to constitutional change that is not controlled by those who directly or indirectly

wield governmental power over them, i.e., their governmental “Agents.”

7. Plaintiffs have a substantial interest in the determination of this controversy.

8. This Right is in danger of infringement by the defendants.

9. This controversy is definite, substantial, and ripe for final determination. The parties have

adverse interests that collided in 1967, the last time the People voted for a Constitutional

Convention, and resulted in harm, and threaten to do so again as early as 2014.

10. However, neither an actual infringement of rights nor alternate coercive relief are necessary

in a declaratory judgment action. See, e.g., Town of Ramapo v. Village of Spring Valley,

40 Misc. 2d 589, 591 (Sup. Ct. Rockland County 1962) (declaratory relief available to test

validity of contract although it had not been breached), appeal dismissed, 13 N.Y.2d 918,

(1963).

11. A declaration of the Rights of the People and the Obligations of the Government under

Article XIX Section 2 of the New York Constitution in this case will serve a necessary and

useful purpose. Davis Constr. Corp. v. County of Suffolk , 112 Misc. 2d 652, 656, (Sup. Ct.

Suffolk County 1982), aff'd mem., 95 App. Div. 2d 819 (2d Dep't 1983).

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PARTIES

12.

ROBERT L. SCHULZ is a citizen of New York State, residing in Washington County.

13. HENRY HAMILTON is a citizen of New York State, residing in Albany County.

14. AL BELARDINELLI is a citizen of New York State, residing in Broome County.

15. ANDREA STUKAS is a citizen of New York State, residing in Broome County.

16. JOHN I. MINERD is a citizen of New York State, residing in Cattaraugus County.

17. RITA EDWARDS is a citizen of New York State, residing in Cattaraugus County.

18. CARL EDWARDS is a citizen of New York State, residing in Cattaraugus County.

19. EVELYN L. LONGLEY is a citizen of New York State, residing in Cayuga County.

20. DENNIS B. SWEENEY is a citizen of New York State, residing in Chautauqua County.

21. JAMES M. WALKER is a citizen of New York State, residing in Chautauqua County.

22. ROBIN G. CARR is a citizen of New York State, residing in Chautauqua County.

23. ROBERT E. RICE is a citizen of New York State, residing in Chemung County.

24. JOHN W. WALLACE is a citizen of New York State, residing in Columbia County.

25. TIMOTHY A. CHICESTER is a citizen of New York State, residing in Columbia County.

26. ZACHARIAH A. CHICESTER is a citizen of New York State, residing in Columbia

County.

27. EMANUELE MARINARO is a citizen of New York State, residing in Dutchess County.

28. PHILLIP POLIZOTTO is a citizen of New York State, residing in Dutchess County.

29. KENNETH L. HOLMES is a citizen of New York State, residing in Erie County.

30. JULIANNE M. THOMPSON is a citizen of New York State, residing in Erie County.

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31. JOHN RUS THOMPSON is a citizen of New York State, residing in Erie County.

32. CAROL POLINER is a citizen of New York State, residing in Erie County.

33. JENNA M. POLINER is a citizen of New York State, residing in Erie County.

34. ELEANOR CORCORAN is a citizen of New York State, residing in Erie County.

35. JAMES CORCORAN is a citizen of New York State, residing in Erie County.

36. KENNETH C. SCHOLZ is a citizen of New York State, residing in Erie County.

37. VICTORIA POCZKALSKI is a citizen of New York State, residing in Erie County.

38. EDWARD L. MCCARTY is a citizen of New York State, residing in Erie County.

39.

MICHAEL J. BRITT is a citizen of New York State, residing in Erie County.

40. RICHARD C. BARRETT is a citizen of New York State, residing in Herkimer County.

41. SHELBY BARRETT is a citizen in New York State, residing in Herkimer County.

42. STEVEN GLICK is a citizen of New York State, residing in Jefferson County.

43. CHRISTOPHER J. NICHOLS is a citizen of New York State, residing in Jefferson County.

44. LOUINE M. KOLB is a citizen of New York State, residing in Jefferson County.

45. JOHN L. SHELTER is a citizen of New York State, residing in Jefferson County.

46. JOHN MARTIN is a citizen of New York State, residing in Jefferson County.

47. JOHN L. BOSWORTH III is a citizen of New York State, residing in Jefferson County.

48. MICHAEL A. BELL is a citizen of New York State, residing in Jefferson County.

49. JOHN S. HUMPHREY is a citizen of New York State, residing in Jefferson County.

50. JEFFREY L. STEVENS is a citizen of New York State, residing in Jefferson County.

51. JOHN C. DEWITT is a citizen of New York State, residing in Jefferson County.

52. KAY S. HOFFMAN is a citizen of New York State, residing in Jefferson County.

53. BEVERLY J. HURLEY is a citizen of New York State, residing in Jefferson County.

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54. BART S. BONNER is a citizen of New York State, residing in Jefferson County.

55. DEBRA THOMPSON is a citizen of New York State, residing in Jefferson County.

56. ESTELLA A HART is a citizen of New York State, residing in Jefferson County.

57. LAURA L. STEVENS is a citizen of New York State, residing in Jefferson County.

58. RONALD G. MOORE is a citizen of New York State, residing in Kings County.

59. DAVID WILLIAM BOWER is a citizen of New York State, residing in Lewis County.

60. STEPHEN KRAEGER is a citizen of New York State, residing in Lewis County.

61. JANE WOODWARD is a citizen of New York State, residing in Lewis County.

62.

SUSAN ENGLERT is a citizen of New York State, residing in Livingston County.

63. JAMES P. DELANEY is a citizen of New York State, residing in Monroe County.

64. EDWARD A. GARTZ is a citizen of New York State, residing in Monroe County.

65. RALPH ERIK SCHNACKENBERG is a citizen of New York State, residing in

Montgomery County.

66. JULIA S. GAMBINO is a citizen of New York State, residing in Nassau County.

67. ANDREAS MILONIS is a citizen of New York State, residing in Nassau County.

68. MARK AXINN is a citizen of New York State, residing in New York County.

69. DONALD G. HOBEL is a citizen of New York State, residing in Niagara County.

70. EDWARD D. PETTITT is a citizen of New York State, residing in Niagara County.

71. JANET M. MARTIN is a citizen of New York State, residing in Niagara County.

72. MYRON D. ANNIS is a citizen of New York State, residing in Niagara County.

73. MARTHA A. FRANCIS is a citizen of New York State, residing in Niagara County.

74. RITA D. LARSON is a citizen of New York State, residing in Niagara County.

75. THOMAS J. LARSON is a citizen of New York State, residing in Niagara County.

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76. ROBERT ELLISON is a citizen of New York State, residing in Oneida County.

77. JOANN WILDER is a citizen of New York State, residing in Onondaga County.

78. MARY ANN BUERMAN is a citizen of New York State, residing in Onondaga County.

79. TANYA PARROW is a citizen of New York State, residing in Onondaga County.

80. GEORGE G. RADFORD is a citizen of New York State, residing in Onondaga County.

81. PATRICIA M. RADFORD is a citizen of New York State, residing in Onondaga County.

82. ANTOINETTE M. BLACK is a citizen of New York State, residing in Onondaga County.

83. HARVEY E. DAVIES is a citizen of New York State, residing in Onondaga County.

84.

JAMES D. DOOHER is a citizen of New York State, residing in Onondaga County.

85. KEVIN COTE is a citizen of New York State, residing in Orange County.

86. ROBERT SPENCER is a citizen of New York State, residing in Oswego County.

87. MYRNA A. THAYNE is a citizen of New York State, residing in Otsego County.

88. PRISCILLA TAMARO is a citizen of New York State, residing in Otsego County.

89. GEORGE TAMARO is a citizen of New York State, residing in Otsego County.

90. DAVID CRAWMER is a citizen of New York State, residing in Rensselaer County.

91. EDWARD M. STEHLIN is a citizen of New York State, residing in Richmond County.

92. MARY ANN PENNELL is a citizen of New York State, residing in Rockland County.

93. NANCY W. FOSTER is a citizen of New York State, residing in St. Lawrence County.

94. DALTON P. FOSTER is a citizen of New York State, residing in St. Lawrence County.

95. DONALD WHITE is a citizen of New York State, residing in Saratoga County.

96. CHAD H. CURRIN is a citizen of New York State, residing in Schenectady County.

97. WILBUR W. CARD is a citizen of New York State, residing in Steuben County.

98. VANESSA PARSONS is a citizen of New York State, residing in Suffolk County.

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99. HARVEY KASH is a citizen of New York State, residing in Suffolk County.

100. GARY L. PERRY is a citizen of New York State, residing in Tioga County.

101. DENVER L. JONES is a citizen of New York State, residing in Tioga County.

102. KATHLEEN C. ELLIOTT is a citizen of New York State, residing in Tompkins County.

103. VIVIAN Y. WADLIN is a citizen of New York State, residing in Ulster County.

104. JUDITH M. WHITMORE is a citizen of New York State, residing in Warren County.

105. JOHN L. SALVADOR is a citizen of New York State, residing in Warren County.

106. ANTHONY FUTIA, JR is a citizen of New York State, residing in Westchester County.

107. CHRISTOPHER J. ENGLERT is a citizen of New York State, residing in Wyoming

County.

108. Under New York’s Constitutional Republic, and for purposes of this Declaratory Judgment

Action, the Parties listed in paragraphs 12 - 108 above are the “PRINCIPAL.”

109. ANDREW M. CUOMO, and all those similarly situated, are directly or indirectly

employed by the Executive Branch of the State of New York, and are thereby governed in

that capacity by the restrictions, prohibitions, mandates of and principles underlying the

New York State Constitution and its implementing statutes.1

110. DEAN G. SKELOS, and all those similarly situated, are directly or indirectly employed by

the Legislative Branch of the State of New York, and are thereby governed in that capacity

by the restrictions, prohibitions, mandates of and principles underlying the New York State

Constitution and its implementing statutes.2

1ANDREW M. CUOMO is the Governor of New York State, with principal offices located at New York State

Capitol Building, Albany, NY 12224.2DEAN G. SKELOS is the Senate Majority Leader, with principal offices located at Legislative Office Building,

Room 909, Albany NY 12207.

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111. JONATHAN LIPPMAN, and all those similarly situated, are directly or indirectly

employed by the Unified Court System of the State of New York, and are thereby governed

in that capacity by the restrictions, prohibitions, mandates of and principles underlying the


112. MICHAEL R. BLOOMBERG, and all those similarly situated, are directly or indirectly

employed by a public corporation of the State of New York that has both the power to

contact indebtedness and power to collect rentals, charges, rates or fees, for the services or

facilities furnished or supplied by it, and are thereby governed in that capacity by the

restrictions, prohibitions, mandates of and principles underlying the New York State


113. DANNY DONOHUE, and all those similarly situated, are directly or indirectly employed

by a lobbyist organization that is registered with the New York State Joint Commission on

Public Ethics and attempts to further its interests by influencing the governmental decision-

making process in New York State on the state and/or local level, and are thereby governed

in that capacity by the restrictions, prohibitions, mandates of and principles underlying the


114. JOHN STIPO, and all those similarly situated, receive a taxpayer supported pension from

the State of New York and/or one of its public corporations, and are thereby governed in

3 JONATHAN LIPPMAN is the Chief Judge of the State of New York and the Chief Judge of the Court of Appeals

with offices located at 25 Eagle Street, Albany, NY 12207.4MICHAEL R. BLOOMBERG is the Mayor of New York City with principal offices located at City Hall, New

York, NY 10007.5

Danny Donahue is the President of the Civil Service Employees Association, Local 1000, with principal offices

located at 143 Washington Ave., Albany N.Y., 12210.

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that capacity by the restrictions, prohibitions, mandates of and principles underlying the


115. ED COX and STEPHANIE MINER, and all those similarly situated, are directly or

indirectly employed by a major Political Party, capable of designating and placing

candidates on the ballot for election, by the voters of New York State, to public official

positions and to political Party positions, and are thereby governed in that capacity by the

restrictions, prohibitions, mandates of and principles underlying the New York State


116. Under New York’s Constitutional Republic, and for purposes of this Declaratory Judgment

Action, the Parties listed in paragraphs 109 – 115, and all those similarly situated are the

“AGENT” of the PRINCIPAL.

STATEMENT OF FACTS

117. Article XIX of the NY Constitution mandates the following question appear on the

statewide ballot on election day in November, 2017, “Shall there be a convention to revise

the Constitution and amend the same?”

“At the general election to be held in the year nineteen hundred fifty-seven, and every twentieth year

thereafter, and also at such times as the legislature may by law provide, the question “Shall there be

a convention to revise the constitution and amend the same?” shall be submitted to and decided by

the electors of the state;...” NY CONSTITUTION, ARTICLE XIX, SECTION 2

118. The New York State Constitution thus provides a pathway for the PRINCIPAL, the People

of New York State, to begin a process of peaceably putting their inherent, ultimate power

6 JOHN L. STIPO is a retired policeman from the Town of North Castle, County of Westchester.7 ED COX is the Chairman of the Republican Party of New York State, with offices located at 315 State Street,

Albany, NY 12210. STEPHANIE MINER is the Co-Chair of the New York State Democratic Committee with

principal offices located at 118a Fulton Street, Box #410 New York, NY 10038.

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of self-government into their own hands every twenty years by calling a New York State

Constitutional Convention.

119. On information and belief, some legislators have suggested and bills have been introduced

to put the question on the ballot before 2017.

120. Should the People vote for a Constitutional Convention, Article XIX provides that three

delegates be elected from each State Senatorial District and fifteen delegates be elected at

large:

“and in case a majority of the electors voting thereon shall decide in favor of a convention

for such purpose, the electors of every senate district of the state, as then organized, shall elect

three delegates at the next ensuing general election, and the electors of the state voting at the sameelection shall elect fifteen delegates-at-large.” NY CONSTITUTION, ARTICLE XIX, SECTION 2

ARGUMENT

121. In 2017, or before, the free and sovereign People of New York State (the “PRINCIPAL”),

will have the opportunity to call a Constitutional Convention to evaluate the performance

of their “AGENT,” those who directly or indirectly wield governmental power over them,

and to restructure and redefine their relationship with the Agent based upon their

experience, and to do so by amending and revising the New York Constitution through the

Constitution’s constitutional convention process.

122. The PRINCIPAL must now prepare for the upcoming ballot question.

123. An immediate issue faces the PRINCIPAL: the all-important, influencing issue of who the

delegates to the convention should not be must be settled before the question appears on the

ballot.

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124. It would be the ultimate conflict of interest for the AGENT to vote on issues at a

constitutional convention that was called by the PRINCIPAL, the purpose of which is to

revise and amend the Rule Book that is designed to restrict, prohibit and mandate the

activities of the AGENT, that is, the Rule Book that is designed to govern the government.

125. The AGENT is constitutionally restricted from serving as a Delegate at a constitutional

convention, not by a plain reading of the Constitution, but by essential principles

underlying America’s Charter, the Declaration of Independence, and Her State and Federal

Constitutions, including the essential principles of popular sovereignty, self-government

and separation of powers.

126. Should the AGENT sit as Delegates at a Constitutional Convention the AGENT would be

in control of both pathways to constitutional change provided by the Constitution: the

AGENT’S pathway and the PRINCIPAL’S pathway.

127. Besides providing the PRINCIPAL with the opportunity to revise and amend the

Constitution by a People’s Constitutional Convention at least once every twenty years, the

Constitution also provides the AGENT with the opportunity to revise and amend the

Constitution by placing specific amendments on the ballot at any time.

Any amendment or amendments to this constitution may be proposed in the senate andassembly 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

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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.” NY CONSTITUTION, ARTICLE XIX, SECTION 1.

128. This action goes to the very heart of the meaning of “self-government” and the phrase

found in the Declaration of Independence, which Declaration was incorporated in its

entirety in New York’s first Constitution (1777), to wit: “We hold these truths to be self-

evident, that all men are created equal, that they are endowed by their Creator with certain

unalienable rights, that among these are Life, Liberty, and the Pursuit of Happiness -- That

to secure these rights, governments are instituted among men, deriving their just powers

from the consent of the governed, that whenever any form of government becomes

destructive of these ends, it is the right of the people to alter or to abolish it, and to institute

new government, laying its powers in such form as to them shall seem most likely to effect

their safety and happiness.”

129. In October of 1932, former President Calvin Coolidge and Alfred E. Smith (Governor of

New York State and nominee for President in 1928) issued a joint statement of concern for

America. It said: “Unless the people, through a united action, arise and take charge of

their government, they will find that their government has taken charge of them.

Independence and liberty will be gone and the general public will find itself in a condition

of servitude to an aggregation of organized and selfish ambitions.” That was true then and

it is still true.

130. The constitutional will and intent of the sovereign people of New York State to have the

opportunity to take all of their power into their own hands at least once every twenty years,

in order to evaluate the performance of their (governmental) Agents and to restructure and

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redefine their relationship with their government based upon that twenty-year experience,

and to do so by amending and revising the New York Constitution through the

constitutional convention process in accordance with Article XIX of the New York

Constitution, and Article IV, Section 4 of the United States Constitution would be violated

if delegates to the state constitutional convention were, in fact, representing the sovereign

people’s agent, i.e., the government, including defendants and all those similarly situated.

CONCLUSION

131. Plaintiffs respectfully request a final judgment and order:

a)

declaring it to be a conflict of interest for defendants and all those similarly situated

to be delegates at a New York State Constitutional Convention, and

b) permanently enjoining defendants and all similarly situated from becoming

delegates at any future New York State Convention, and

c) for such other and further relief as to the Court may seem just and proper.

DATED: November 17, 2012

ROBERT L. SCHULZ, pro se2458 Ridge Road

Queensbury, NY 12804(518) 656 3578

[email protected]

HENRY L. HAMILTON, pro se3108 East Lydius Street – P.O. Box 13321

Albany, NY 12212(518) 357-2018

[email protected]

AL BELARDINELLI, pro se2800 East Main Street

Endwell, NY 13760

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(607) [email protected]

ANDREA STUKAS, pro se

2800 East Main StreetEndwell, NY 13760(607) 748-2228

JOHN J. MINERD, pro se

12271 Old Oleal Road(716) 560-6867

[email protected]

RITA EDWARDS, pro se1893 N. Main Street

Limestone, NY 14753(716) 925-7123

[email protected]

CARL EDWARDS, pro se1893 N. Main Street

Limestone, NY 14753(716) 925-7123

[email protected]

EVELYN L. LONGLEY, pro se17 Center Street

Auburn, NY 13021(315) 252-1629

[email protected]

DENNIS B. SWEENEY, pro se5939 Button Valley Road

Panama, NY 14767(716) 782-4021

[email protected]

JAMES M. WALKER, pro se3880 E. Ross Mills Rd

Falconer, NY [email protected]

(716) 985-4373

ROBIN G. CARR, pro se

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33 Pullman StreetBrocton, NY 14716


ROBERT E. RICE, pro se

160 Robinwood AvenueElmira Heights, NY 14903(607) 734-8024

[email protected]

JOHN W. WALLACE, pro se143 Longview Drive

Chatham, NY 12037(518) 392-7062

[email protected]

TIMOTHY A. CHICHESTER, pro se260 Spencer Road

Austerlitz, NY 12017

ZACHARIAH A. CHICHESTER, pro se260 Spencer Road

Austerlitz, NY 12017

EMANUELE MARINARO, pro se2779 Rt. 52

Hopewell Junction, NY 12533(845) 227-3717

[email protected]

PHILIP POLIZOTTO, pro se96 Gerald Drive

Poughkeepsie, NY 12601(914) 456-7581

[email protected]

KENNETH HOLMES, pro se6447 Armor Road

Orchard Park, NY 14127(716) 662-2476

JULIANNE M. THOMPSON, pro se

2394 Bedell RoadGrand Island, NY 14072

(716) 444-8908

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[email protected]

JOHN RUS THOMPSON, pro se

2394 Bedell RoadGrand Island, NY 14072(716) 563-9901

[email protected]

CAROL POLINER, pro se4700 Schurr Road

Clarence, NY 14031(716) 544-4157

[email protected]

JENNA M. POLINER, pro se4700 Schurr Road

Clarence, NY 14031(716) 544-4157

[email protected]

ELEANOR CORCORAN, pro se5141 Willow Brook Rd

Clarence, NY 14031(716) 741-1076

[email protected]

JAMES CORCORAN, pro se5141 Willow Brook Drive

Clearance, NY 14031(716) 741-1076

[email protected]

KENNETH C. SCHOLZ, pro se18 Mill Valley Road

E. Amherst, NY(716) 688-5682

[email protected]

VICTORIA POCZKALSKI, pro se42 Layer Avenue

Buffalo, NY 14207(716) 874-4654

[email protected]

7/30/2019 Complaint 11-28-12 6pm


18

EDWARD L. MCCARTY, pro se

7246 S. Abbott RoadHamburg, NY 14075(716) 649-6745

[email protected]

MICHAEL J. BRITT, pro se34 Parkwood Road

Amherset, NY 14226(716) 364-9565

[email protected]

RICHARD C. BARRETT, pro se10243 Roberts Road

Sanquoit, NY 13456(315) 737-5644

[email protected]

SHELBY BARRETT, pro se10243 Roberts Road

Sanquoit, NY 13456(315) 737-5644

[email protected]

STEVEN GLICK, pro se34800 Elm Ridge Road

Philadelphia, NY 13673(315) 767-9414

[email protected]

CHRISTOPHER J. NICHOLS, pro se18591 County Rt. 66

Watertown, NY 13601(315) 767-2782

LOUINE M. KOLB, pro se

207 Ambrose StreetSackets Harbor, NY 13685


7/30/2019 Complaint 11-28-12 6pm


19

JOHN L. SHETLER, pro se

32161 County Route 28Philadelphia, NY 13673(315) 286-2966

[email protected]

JOHN MARTIN, pro se31813 Town Line Road

Philadelphia, NY 13673(315) 767-3523

[email protected]

JOHN L. BOSWORTH II, pro se40390 Vrooman Hill Road

Theresa, NY 13691(315) 778-4190

[email protected]

MICHAEL R. BELL, pro se6417 Gosier Road

Cape Vincent, NY 13618(315) 654-3932

JOHN S. HUMPHREY, pro se

29079 NY State Route 12Watertown, NY 13601

(315) 222-5121 [email protected]

JEFFREY L. STEVENS, pro se

16983 CR 76Adams Center, NY 13606


JOHN C. DEWITT, pro se

5571 Co Rt 120(315) 846-5787

[email protected]

KAY S. HOFFMAN, pro se

7/30/2019 Complaint 11-28-12 6pm


20

1230 Madison AvenueWatertown, NY 13601


BEVERLY J. HURLEY, pro se

332 Arlington Street, Apt. DownWatertown, NY 13601(315) 782-0276

BART S. BONNER, pro se

23967 County Route 67Watertown, NY 13601


DEBRA THOMPSON, pro se

225 Wyoming AvenueWatertown, NY 13601

(315) 782-8956

ESTELLA A. HART, pro se29122 Perch Lake Road

Watertown, NY 13601(315) 629-2601

[email protected]

LAURA L. STEVENS, pro se16983 County Route 76

Adams Center, NY 13606(315) 408-6310

[email protected]

RONALD G. MOORE303 Columbia Street – Apt 5F


DAVID WILLIAM BOWER, pro se

7512 Railroad StreetLowville, NY 13367-1864


STEPHEN KRAEGER, pro se

3922 High Street

7/30/2019 Complaint 11-28-12 6pm


21

Lyons Falls, NY 13368(315) 348-4296

JANE WOODWARD, pro se

7700 W. State StreetLowville, NY 13367(315) 376-6988

SUSAN ENGLERT, pro se

6706 Cleary RoadLivonia, NY 14487


JAMES P. DELANEY, pro se

108 Image WayRochester, NY 14626


EDWARD A. GARTZ, pro se

220 Orchard Creek Rochester, NY 14612


RALPH ERIK SCHNACKENBERG, pro se

182 Logtown RoadFultonville, NY 12072


JULIA S. GAMBINO, pro se

15 Dale RoadFarmingdale, NY 11735

(516) 694-9474

ANDREAS MILONIS, pro se101 Central Park Rd, Apt 9

Plainview, NY 11803(516) 286-9708

MARK N. AXINN

338 East 78th

Street

7/30/2019 Complaint 11-28-12 6pm


22

New York, New York 10075(212) 753-5599

[email protected]

DONALD G. HOBEL, pro se

3767 Moyer RoadWheatfield, NY 14120(716) 693-1823

[email protected]

EDWARD D. PETTITT, pro se3188 Coomer Road

Newfane, NY 14108(716) 471-6001

[email protected]

JANET M. MARTIN, pro se2163 Jagow Road #3

Niagara Falls, NY 14304(716) 731-8107

MYRON D. ANNIS, pro se

61 Gunson Street North Tonawanda, NY 14020


MARTHA A. FRANCIS, pro se

41 Sweeney Court North Tonawanda, NY


RITA D. LARSON, pro se

3700 Lockport RoadWheatfield, NY 14132


THOMAS J. LARSON, pro se

3700 Lockport RoadWheatfield, NY 14132


7/30/2019 Complaint 11-28-12 6pm


23

ROBERT ELLISON, pro se

109 AnnBoonville, NY(315) 778-3165

[email protected]

JOANNE WILDER, pro se8457 Chinkapin Circle

Cicero, NY 13039(315) 247-2256

[email protected]

MARY ANN BUERMAN, pro se5564 Kathan Road

Brewenton, NY 13029(315) 676-4518

[email protected]

TANYA PARROW, pro se4031 E. Lzngerwood Lane

Syracuse, NY 13215(315) 488-7821

[email protected]

GEORGE G. RADFORD, pro se19 The Orchard

Fayetteville, NY 13066(315) 632-4120

[email protected]

PATRICIA M. RADFORD, pro se19 The Orchard

Fayetteville, NY 13066(315) 632-4120

[email protected]

ANTOINETTE M. BLACK, pro se1320 Le Moyne Ave

Syracuse, NY 13208(315) 463-5998

[email protected]

7/30/2019 Complaint 11-28-12 6pm


24

HARVEY E. DAVIES, pro se

160 Manor DriveSyracuse, NY 13214(315) 446-8874

[email protected]

JAMES D. DOOHER, pro se1220 Vilton Drive

Dewitt, NY 12214(315) 446-6168

[email protected]

KEVIN T. COTE, pro se17 Little Brooklyn Rd.

Warwick, NY 10990(845) 987-0084

[email protected]

ROBERT SPENCER, pro se828 Holly Drive, #D45

Fulton, NY 13609(315) 887-5024

[email protected]

MYRNA A. THAYNE, pro se2389 State Highway 205

Mount Vision, NY(607) 432-4117

[email protected]

PRISCILLA TAMARO, pro seP.O. Box 62

Westford, NY 13488(607) 264-8454

GEORGE TAMARO, pro se

P.O. Box 62Westford, NY 13488

(607) 264-8454

DAVE CRAWMER, pro se

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25

21 Indian Pipe DriveWynantskill, NY 12198


EDWARD M. STEHLIN, pro se166 Wright StreetStaten Island, NY


MARY ANN PENNELL, pro se

123 Call Hollow RoadPomona, NY 10970

(845) 354-0557

NANCY W. FOSTER, pro se4 Butternut Ridge

Massena, NY 13662(315) 764-1289

[email protected]

DALTON P. FOSTER, pro se4 Butternut Ridge

Massena, NY 13662(315) 764-1289

[email protected]

DONALD R. WHITE, pro se21 Garnsey Road

Rexford, NY 12148(518) 399-0684

[email protected]

CHAD H. CURRIN, pro se105 Hetcheltown Road

Glenville, NY 12302(518) 542-7959

[email protected]

WILBUR W. CARD, pro se4610 SR 414

Beaver Dams, NY 14812(607) 962-0308

[email protected]

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26

VANESSA PARSONS, pro se

58 Old Country Road #21East Quogue, NY 11942(631) 338-5485

[email protected]

HARVEY KASH, pro se14 C. 2

NDStreet

Huntington Station, NY 11746(631) 470-9600

GARY L. PERRY, pro se

750 Walker Hill Road, pro seWaverly, NY


DENVER L. JONES, pro se

1271 Owego RoadOwego, NY 13827


KATHLEEN C. ELLIOTT, pro se

81 East Main StreetDryden, NY 13053


VIVIAN Y. WADLIN, pro se

38 Bellevue RoadHighland, NY


JUDITH M. WHITMORE, pro se

2458 Ridge RoadQueensbury, NY 12804

[email protected]

JOHN SALVADOR, JR, pro se

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27

37 Alexy LaneLake George, NY 12845


ANTHONY FUTIA, JR., pro se

34 Custis AvenueWhite Plains, NY 10603(914) 948-4368

[email protected]

CHRISTOPHER J. ENGLERT, pro se3647 Middle Reservation Rd

Perry, NY 14530(585) 237-6329

[email protected]

complaint 11-28-12 6pm

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