25.01.2015 Views

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

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

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

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e. Directing that the election be conducted and votes counted as in other such<br />

elections;<br />

£ Providing notice of the election as provided by law and as directed by this<br />

Court; and,<br />

g. Allowing Contestant his costs and attorney's fees and for such other relief<br />

as the Court deems just and equitable.<br />

---------------------------------fcVotlu~m~IHI~------------------------------­<br />

REQUEST FOR RECOUNT BECAUSE OF LESS THAN<br />

ONE PERCENT DIFFERENCE IN VOTE<br />

63. Contestant hereby incorporates by reference each and every allegation contained<br />

in paragraphs 1 through 62 as if fully set forth herein.<br />

64. Contestant was defeated by less than one percent of the votes cast and is,<br />

therefore, entitled to an automatic recount of all votes cast for the election for the office of State<br />

WHEREFORE, Contestant respectfully requests this Court requests to issue its order and<br />

judgment directing a recount for the Democrat primary for State Representative, 40 th Legislative<br />

District, Jackson County, Missouri under Section 115.603 RSMo.<br />

Respectfully submitted,<br />

GUNN, SHANK & S<strong>TO</strong>VER, P.C.<br />

'lip O. Willoughby N .. 4948<br />

Arnold R. Day No. 27<br />

9800 NW Polo Drive, Suite 100<br />

Kansas City, Missouri 64153<br />

Telephone: 816-454-5600<br />

Telecopy: 816-454-3678<br />

Attorneys for Contestant<br />

14

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