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

were cast in the entire district comprising the 40 th Legislative District (State
Representative).
54. The facts and points stated above individually and collectively constitute irregularities
of sufficient magnitude to cast doubt on the validity of the initial election between
Contestant and Contestee, thereby requiring a new, district-wide primary election for
the office of State Representative 40 th Legislative District.
55. Contestant respectfully requests leave to produce proofOfthe pomts and facts abovestated.
COUNT!
REQUEST FOR RECOUNT DUE TO IRREGULARITIES
56. Contestant hereby incorporates by reference each and every allegation contained in
paragraphs 1 through 55 as iffully set forth herein.
57. The facts and points above-stated and the proof thereof demonstrate that the
irregularities in the Democrat primary election for State Representative for the 40 th
Legislative District place the result of that election in doubt.
58. There is a prima facie showing of irregularities, which place the result of the election
in doubt.
59. That the actions of the interpreter/campaign volunteer in personally signing the
registration for the voters, handling the ballots of the voters, and even casting the
votes for multiple voters, is a violation of Missouri law and constitute an irregular
election.
WHEREFORE, Contestant respectfully requests this Court, pursuant to Chapter 115,
RSMo., to issue its order (a) directing a full recount of all votes cast, together with an
examination by hand of all ballots in all precincts to determine the validity of such ballots and
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