) ) ) ) ) ) ) ) ) VERIFIED PETITION TO CONTEST ELECTION 1

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KANSAS CITY BOARD OF <strong>ELECTION</strong>S NOTIFIED 44. On information and belief, the election officials at the Garfield Elementary School polling place notified the supervisors at the Kansas City Board of Election Commissioners about the apparent voting irregularities. 45. On information and belief, officials from the Kansas City Board of Election Commissioners responded to the polling location and advised the on sight election -----------------noflffi~cmhrthart~~rere~t~~~ru~.---------------------------------- UNLAWFUL CONSOLIDATION OF PRECINCTS 46. For the primary election for the 40 th Legislative District, the Election Boards unlawfully consolidated and moved non-adjoining precincts and polling places. Specifically, (a) three precincts and their polling places (WD 2-11, WD 2-12 and WD 2-13) were consolidated with a fourth, out-of-district precinct (WD 2-10), which is in violation of Section 115.115 RSMo. because two of the consolidated precincts (WD 2-12 and WD 2-13) are not adjoined geographically with WD 2-10 (polling place), and (b) precinct WD 2-16 was unlawfully moved and consolidated with precinct WD 2-11, which also are not joined geographically as mandated by Section 115.115 RSMo. One such polling place was improperly moved to the Somali Foundation (St. Mark's Euclid). 47. On information and belief, in at least one precinct in the 40 th Legislative District on Election Day, at least four voters were lined up and ready to vote at the door of the polling place at or before the time of closing of the polls, but they were denied access to the polling place. On information and belief, the 10
official who denied access made derogatory comments about Contestant on Election Day. 48. On information and belief, the Somali adult male acting as an interpreter on Election Day is an employee of a not-for-profit foundation, the Somali Foundation. 49. On information and belief, at least one Supervisor absented himself from his assigned polling placeirrwhiclnmrltiple irregularities occurred for extended periods of time on the primary election day. 50. Some ofthe election supervisors or judges in the precincts referred to in this Petition appeared to be inadequately trained, or they refused or declined to observe the rules imposed upon election officials at polling places. 51. The votes cast under the cloud of all of the irregularities set forth herein, including but not limited to, ballots marked or voted by the interpreter/assistant, ballots cast in the manner and at the specific direction of others, ballots cast in unlawfully consolidated precincts, are illegal and accordingly must be rejected. 52. On the basis of the irregularities set forth herein, the total of all illegal ballots known or observed to have been cast exceed the margin of victory reflected in the official results published by the Election Boards for the office of State Representative 40 th Legislative District. 53. Further, the irregularities in the primary election for the office of State Representative 40 th Legislative District were so pervasive that it is not known, nor can it be determined how many legal ballots and how many illegal ballots 11
Page 1 and 2: . IN THE CIRCUIT COURT OF JACKSON C
Page 3 and 4: 6. That Contestee, John Rizzo, as a
Page 5 and 6: 16. The election authority may cons
Page 7 and 8: judge." But no person other than el
Page 9: precinct, who took no action to rem
Page 13 and 14: the votes cast thereon, (b) directi
Page 15: VERIFICATION STATE OF MISSOURI ) 47

) ) ) ) ) ) ) ) ) VERIFIED PETITION TO CONTEST ELECTION 1

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