Sunday, January 07, 2007
With a couple hours and all day tomorrow to go, I've finished a first amended complaint, as I was ordered by the court to do or face dismissal. It took some work,and made my vacation on maui more complicated - the island doesn't have a lot of free computers, but it's done except for the proofreading printing and filing.
IN THE SUPERIOR COURT FOR MARION COUNTY INDIANA
Joell Palmer,
Plaintiff,
v. Cause No. 49D04-06 10-CT-044113
Judge Cynthia Ayers
Marion County, State of
Indiana, J. Bradley King,
Todd Rokita, Kristi Robertson,
Doris Anne Sadler, Beth White, John Doe
#1-4,Jane Doe 1-3, Securatex,
Jack Cottey,
Defendants.
FIRST AMENDED COMPLAINT
Comes now Plaintiff Joell Palmer by counsel and for his first AMENDED complaint for damages, injunctive and declaratory relief states as follows.
1. Suit was filed October 27, 2006. Defense counsel moved, and the court ordered, for a more definitive statement. This first amended complaint is in response to that order. The first section restates the original complaint. A second section, paragraphs 242 et seq., updates events in light of the occurrence of the election.
2. Introduction: This is an action to stop a threat to the integrity of the election process.
3. Time is of the essence.
4. Defendants are attempting to engage in voter fraud, by preventing registered voters without a voting license from voting.
5. The result will be that the winners of the upcoming elections cannot be determined, because an unknown number of eligible voters will be prevented from voting.
6. The open door law claim, IC 5-14-1.5-7(g) and the rules of court including TR40(A), provide a statutory basis for expedited handling.
7. A motion for a TRO and preliminary injunction has been filed to prevent irreparable harm.
The rest of it will be posted in a moment at the following link.
IN THE SUPERIOR COURT FOR MARION COUNTY INDIANA
Joell Palmer,
Plaintiff,
v. Cause No. 49D04-06 10-CT-044113
Judge Cynthia Ayers
Marion County, State of
Indiana, J. Bradley King,
Todd Rokita, Kristi Robertson,
Doris Anne Sadler, Beth White, John Doe
#1-4,Jane Doe 1-3, Securatex,
Jack Cottey,
Defendants.
FIRST AMENDED COMPLAINT
Comes now Plaintiff Joell Palmer by counsel and for his first AMENDED complaint for damages, injunctive and declaratory relief states as follows.
1. Suit was filed October 27, 2006. Defense counsel moved, and the court ordered, for a more definitive statement. This first amended complaint is in response to that order. The first section restates the original complaint. A second section, paragraphs 242 et seq., updates events in light of the occurrence of the election.
2. Introduction: This is an action to stop a threat to the integrity of the election process.
3. Time is of the essence.
4. Defendants are attempting to engage in voter fraud, by preventing registered voters without a voting license from voting.
5. The result will be that the winners of the upcoming elections cannot be determined, because an unknown number of eligible voters will be prevented from voting.
6. The open door law claim, IC 5-14-1.5-7(g) and the rules of court including TR40(A), provide a statutory basis for expedited handling.
7. A motion for a TRO and preliminary injunction has been filed to prevent irreparable harm.
The rest of it will be posted in a moment at the following link.
