~21-oe - moritzlaw.osu.edumoritzlaw.osu.edu/electionlaw/litigation/documents/nelsonroe.pdf ·...

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UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF OHIO EASTERN DIVISION LIBERTARIAN PARTY OF OHIO, et al., Plaintiffs, Case No.2: 13-cv-953 v. Judge Michael H. Watson HUSTED, et al., Defendants. / DECLARATION OF NELSON ROE (pursuant to 28 U.S.C. § 1746) I, Nelson Roe, do hereby declare under penalty of perjury that the following is true and correct: 1. I am above the age of 18, of sound mind, a United States citizen, and reside in Guernsey County, Ohio. 2. I am a registered voter in Ohio, a member of the Libertarian Party of Ohio (LPO), and am eligible to run in the LPO's 2014 primary for Ohio's House of Representatives. 3. On October 25, 2013, I officially filed for the LPO's 2014 primary for Ohio's House of Representatives District #97 by filing my nominating petition with, and paying the qualifying fee to, the Muskingum County Board of Elections. 4. The Muskingum County Board of Elections accepted by nominating petition and qualifying fee that same day. date: J J //1 /;)013 ! I ~21-oe .Nelson Roe 1 Case: 2:13-cv-00953-MHW-TPK Doc #: 23 Filed: 12/02/13 Page: 1 of 12 PAGEID #: 234

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UNITED STATES DISTRICT COURTSOUTHERN DISTRICT OF OHIO

EASTERN DIVISION

LIBERTARIAN PARTY OF OHIO,et al.,

Plaintiffs, Case No.2: 13-cv-953

v. Judge Michael H. Watson

HUSTED, et al.,

Defendants. /

DECLARATION OF NELSON ROE(pursuant to 28 U.S.C. § 1746)

I, Nelson Roe, do hereby declare under penalty of perjury that the following is true and

correct:

1. I am above the age of 18, of sound mind, a United States citizen, and reside in Guernsey

County, Ohio.

2. I am a registered voter in Ohio, a member of the Libertarian Party of Ohio (LPO), and am

eligible to run in the LPO's 2014 primary for Ohio's House of Representatives.

3. On October 25, 2013, I officially filed for the LPO's 2014 primary for Ohio's House of

Representatives District #97 by filing my nominating petition with, and paying the qualifying fee

to, the Muskingum County Board of Elections.

4. The Muskingum County Board of Elections accepted by nominating petition and

qualifying fee that same day.

date: J J //1 /;)013! I

~21-oe.Nelson Roe

1

Case: 2:13-cv-00953-MHW-TPK Doc #: 23 Filed: 12/02/13 Page: 1 of 12 PAGEID #: 234

FormNo. 2-F Prescribed by Secretaryof State (07-13)

DECLARATION OF CANDIDACYPARTY PRIMARY ELECTION FOR DISTRICT OFFICE

State Senator or State Representative

To be filed with the Board of Elections of the most populous county or part county of the district not later than 4p.m. of the 90th day before the day of the primary election.

Revised Code 3513.05, .07, .08, .09, .10, .191,3501.38

NOTE - THE CANDIDATE MUST FILL IN, SIGN AND DATE THIS DECLARATIONBEFORE PETITIONS ARE CIRCULATED.

I, !v'~ISo n £: -g 0 e.. , the undersigned, hereby declare under penalty(Name of Candidate) I

of election falsification that my voting residence address is lD 4;;;, cg 0 Co A f 'R0 l"I 01(Street and Number, if any, or Rural Route Number)

_C_A'--rY'_b_r-...,I_J_'1-:::\-e.. , Ohio Lj3? ;2 5 , and I am a qualified elector.(City or Village) (Zip Code)

I hereby declare' that I desire to be a candidate for nomination to the office of 5t~tE-

Be.ptese.n tAT, ve... as a member of the L: be..~tY-'\rl-A () PatjY from the

9 fJ j;:b St At e... R(..ple.se.rJ~I('v'e.. District for the: (check one) ~ full term or(Numberof District) (State Representativeor State Senate)

D unexpired term ending , at the primary election to be held onI_:th- rYl

the __ UJ day of I I (-\jI hereby declare that, if elected to this office or position, I will qualify therefor, and I will support and

abide by the principles enunciated by the L; bt...\"\ 'A (' i"An Party.

Dated this ~ (oib.-day of Sep-\- ern~ E::\ , ;) 0/3

LZ~ £, Bok?-

,~Oty .

(Signature of Candidate)

WHOEVER COMMITS ELECTION FALSIFICATION IS GUlL TV OF A FELONY OF THE FIFTH DEGREE

PETITION FOR CANDIDATE

(This petition shall be circulated only by a member ofthe same political party as stated above by the candidate)

We, the undersigned qualified electors of the State of Ohio, whose voting residence is in the county,

city, village, or township, set opposite our names, and members of the L,' butAC I\qn Party,

hereby certify that N~\501"\ E. 12t0 e. , whose declaration of candidacy is filed(Name of Candidate)

herewith, is in our opinion, well qualified to perform the duties of the office or position to which the

person desires to be elected.

Signatures on this petition should be from only one county and must be written in ink. Signatures on thispetition shall be of persons who are of the same political party as stated above by the candidate.

SIGNATUREVOTING RESIDENCE ADDRESS

STREET AND NUMBER CITY, VILLAGE, ORTOWNSHIP

COUNTY DATE OFSIGNING

Case: 2:13-cv-00953-MHW-TPK Doc #: 23 Filed: 12/02/13 Page: 2 of 12 PAGEID #: 235

SIGNATUREVOTING RESIDENCE ADDRESS

STREET AND NUMBER CITY, VlLLAGE, ORTOWNSHIP

COUNTY DATE OFSIGNING

8.

9.

10.

11.

12.

tenter nop .

CIRCULATOR STATEMENT - Must be completed and signed by circulator.

I, ;V'e.l 50 Y1 E. ~ oe.. , declare under penalty of election falsification that I reside(printed Name of Circulator) , t '

at the address appearing below my signature; that I am a member of the L I be-I A (' I A (l Party;that I am the circulator of the foregoing petition containing f g signatures; that I witnessed

(Number)the affixing of every signature; that all signers were to the best of my knowledge and belief qualified tosign; and that every signature is to the best of my knowledge and belief the signature of the personwhose signature it purports to be or of an attorney in fact acting pursuant to section 3501.382 of theRevised Code.

(Signature of Circulator)

WHOEVER COMMITS ELECTIONFALSIFICATION IS GUILTY OF AFELONY OF THE FIFTH DEGREE

(permanent residence address)

Cf\~b\;o\~~(_.Oh;o L-}31""J'J5(City or V~agi, State and Zip Code)

•...(!).0

S(!)

~

Case: 2:13-cv-00953-MHW-TPK Doc #: 23 Filed: 12/02/13 Page: 3 of 12 PAGEID #: 236

Voting Residence Address Street City, Village, or Date of

Name and Number Township County Signing

Sarah E. Burris 64160 Coal Rd, Cambridge Center Township Guernsey 9/30/2013

Deborah E. Burris 64160 Coal Rd, Cambridge Center Township Guernsey 9/30/2013

William J. Cunningham 121 Old National Road Old Washington Guernsey 9/30/2013

Dena Jo Patterson 135 Old National Road Old Washington Guernsey 9/30/2013

Jeremy S. Wilkinson 63613 Institute Road Lore City Guernsey 9/30/2013

Cassandra Smith 119 Old National Road Old Washington Guernsey 9/30/2013

Mark D. Patterson 135 Old National Road Old Washington Guernsey 9/30/2013

Tiffany Xanders 65581 Sundew Road, Lore City Center Township Guernsey 9/30/2013

Jeremy Xanders 65581 Sundew Road, Lore City Center Township Guernsey 9/30/2013

John T. Vandyne Jr. 13370 Zane Road, Lore City Center Township Guernsey 10/1/2013

Sheri Vandyne 13370 Zane Road, Lore City Center Township Guernsey 10/1/2013

Monica Bowman 64149 Lily Lane, Cambridge Center Township Guernsey 10/1/2013

Marva Lea Bowman 64147 Lily Lane, Cambridge Center Township Guernsey 10/1/2013

James Richard Bowman 64147 Lily Lane, Cambridge Center Township Guernsey 10/1/2013

Nathann Francis 448 Nth Fifth St Cambridge Guernsey 10/2/2013

Nathan Vaughn 1009 N 7th Street Cambridge Guernsey 10/2/2013

Beth Vaughn 1009 N 7th Street Cambridge Guernsey 10/2/2013

James Green 615 N 9th St Cambridge Guernsey 10/2/2013

Case: 2:13-cv-00953-MHW-TPK Doc #: 23 Filed: 12/02/13 Page: 4 of 12 PAGEID #: 237

FormNo. 2-F Prescribed by Secretaryof State (07-13)

DECLARATION OF CANDIDACYPARTY PRIMARY ELECTION FOR DISTRICT OFFICE

State Senator or State Representative

To be filed with the Board of Elections ofthe most populous county or part county of the district not later than 4p.m. of the 90th day before the day of the primary election.

Revised Code 3513.05, .07, .08, .09, .10, .191,3501.38

NOTE - THE CANDIDATE MUST FILL IN, SIGN AND DATE THIS DECLARATIONBEFORE PETITIONS ARE CIRCULATED.

I, IIe.1 SO n £ K 0e... , the undersigned, hereby declare under penalty(Name of Candidate) I 17 ~

of election falsification that my voting residence address is t.o4;2<60 Cor; llQ "la'1(Street andNumber, if any, or Rural RouteNumber)

Ctl '(V1. b"~J.~ €. , Oh io 4 3 '7;;;'S , and I am a qualified elector.(City or Village) (Zip Code)

I hereby declare that I desire to be a candidate for nomination to the office of 5tAte....Reerese..n+Ah'v~ as a member of the L'be...,tAr'I',qrl Party from the

97.±h SrJ4te Repre se.f1iA if v~ District for the: (check one) rifull term or(Numberof District) (State Representativeor State Senate)

D unexpired term ending , at the primary election to be held on1'h

the (0- day of (YlA <jI hereby declare that, if elected to this office or position, I will qualify therefor, and I will support and

abide by the principles enunciated by the L / 6er+A r,' IQ n Party.+h +-

Datedthis (jf.g""'-dayof Seple.fY\'ce:r , a61'6

1/~ s: ~(Signature of Candidate)

WHOEVER COMMITS ELECTION FALSIFICATION IS GUlL TV OF A FELONY OF THE FIFTH DEGREE

PETITION FOR CANDIDATE

(This petition shall be circulated only by a member of the same political party as stated above by the candidate)

We, the undersigned qualified electors of the State of Ohio, whose voting residence is in the county,

city, village, or township, set opposite our names, and members of the Li be..,-T All A n Party,

hereby certify that /Ve \ SD)'} E. h()~ ,whose declaration of candidacy is filed(Name of Candidate)

herewith, is in our opinion, well qualified to perform the duties of the office or position to which the

person desires to be elected.

Signatures on this petition should be from only one county and must be written in ink. Signatures on thispetition shall be of persons who are of the same political party as stated above by the candidate.

SIGNATUREVOTING RESIDENCE ADDRESS

STREET AND NUMBER CITY, VILLAGE, ORTOWNSHIP

COUNTY DATE OFSIGNING

1.

2.

3.

Case: 2:13-cv-00953-MHW-TPK Doc #: 23 Filed: 12/02/13 Page: 5 of 12 PAGEID #: 238

SIGNATUREVOTING RESIDENCE ADDRESS

STREET AND NUMBER CITY, VILLAGE, ORTOWNSHIP

COUNTY DATE OFSIGNING

10-S -(3

105 1,3

CIRCULATOR STATEMENT - Must be completed and signed by circulator.

I, jl/eISo n £:. 'R ()L ,declare under penalty of election falsification that Ireside(printed Name of Circulator)

at the address appearing below my signature; that I am a member of the Li be..-r- tA (; PI Y) Party;that I am the circulator of the foregoing petition containing ~ signatures; that I witnessed

(Number)the affixing of every signature; that all signers were to the best of my knowledge and belief qualified tosign; and that every signature is to the best of my knowledge and belief the signature of the personwhose signature it purports to be or of an attorney in fact acting pursuant to section 3501.382 of the

Revised Code. ~ E. 7icR....(Signature of Circulator)

to l./;< 3 D Col'i I 'RoA JWHOEVER COMMITS ELECTIONFALSIFICATION IS GUILTY OF AFELONY OF THE FIFTH DEGREE

(Permanent residence address)

CAMb\~o\.~e! ()hl'D L!37:J5(City or V age, State and ZIP Code)

",'+-<= 0o ;>-.•• t)- roU-o~ .---0~ s::•••••roou"C •••••_ 0

= s::o 0= 'p~i::!=~= t)o Q)Vel

I~

I

N

§o~

6:.ao

Case: 2:13-cv-00953-MHW-TPK Doc #: 23 Filed: 12/02/13 Page: 6 of 12 PAGEID #: 239

Voting Residence Address Street and City, Village, or Date ofName Number Township County Signing

Jamie L. Bowman 64149 Lily Lane Cambridge Guernsey 10/2/2013

Larry Lloyd Workman 66999 Fairground Rd Lore City Guernsey 10/3/2013

Kelly J. Sarchet 66923 Fairground Rd Lore City Guernsey 10/3/2013

Mary V. Workman 66999 Fairground Rd Lore City Guernsey 10/3/2013

Candi Dronebarger 131 Old National Rd. Old Washington Guernsey 10/3/2013

Adam G. Dronebarger 131 Old National Rd. Old Washington OH Old Washington Guernsey 10/3/2013

Paul S. Hinkle 62210 Arrowhead Rd 43725 Cambridge Guernsey 10/5/2013

Brandi J. Hinkle 62210 Arrowhead Rd 43725 Cambridge Guernsey 10/5/2013

Aaron T. Roe 61434 Institute Rd Lore City 43755 Lore City Guernsey 10/5/2013

Brenda K Roe 112 Main Street Salesville, Oh 43778 Salesville Guernsey 10/5/2013

Mark H. Roe 112 Main Street Salesville, Oh 43778 Salesville Guernsey 10/5/2013

Ryan Duff 219 Beymer Rd Old Washington Old Washington Guernsey 10/5/2013

Jeff Funk 247 Old National Rd Old Washington Guernsey 10/5/2013

Heath A Beal 64476 Chestnut Lane, Lore City Old Washington Guernsey 10/5/2013

Lawana Beal 64476 Chestnut Lane, Lore City Old Washington Guernsey 10/5/2013

Byesville -Mary Susan Dragosin 242 So. 6th St. Byesville, Oh 43723 Jackson Twp. Guernsey 10/16/2013

Jeffrey L. Dragosin Byesville, Ohio 43723 Byesville, Oh Guernsey 10/16/2013

Debbie Rice 59600 Lost Rd Byesville, Oh Guernsey 10/17/2013

Case: 2:13-cv-00953-MHW-TPK Doc #: 23 Filed: 12/02/13 Page: 7 of 12 PAGEID #: 240

FormNo. 2-F Prescribedby Secretaryof State (07-13)

DECLARATION OF CANDIDACYPARTY PRIMARY ELECTION FOR DISTRICT OFFICE

State Senator or State Representative

To be filed with the Board of Elections of the most populous county or part county of the district not later than 4p.m. ofthe 90th day before the day of the primary election.

Revised Code 3513.05, .07, .08, .09, .10, .191,3501.38

NOTE - THE CANDIDATE MUST FILL IN, SIGN AND DATE THIS DECLARATIONBEFORE PETITIONS ARE CIRCULATED.

T, ;tie-IS-Of) E. Roe, , the undersigned, hereby declare under penalty(Nameof Candidate) D h

of election falsification that my voting residence address is & '-I;;J S'D Co,q I Ii 0A OJ

C ' I (Street and Number, if any, or Rural RouteNumber)A rYi 'orl 0{ g e.. , Ohio 437 d.6 , and T am a qualified elector.

(City crI Village) (Zip Code)

I hereby declare that I desire to be a candidate for nomination to the office of 6tfJte.-_...LB--J-!=:.eprese..n tAi,'ve as a member of the L,' bt.,t,qT' ,'An Party from the

q? ±b-- StAte... R{.ens~t'1irtit·ve. District for the: (check one) ~full term or(Numberof District) (State Representativeor State Senate)

D unexpired term ending , at the primary election to be held on

r. fu..- fYl J Ithe l[} day of --'---'--!.A....:....j-'1-------',- _Q_O_I 7-,--

I hereby declare that, if elected to this office or position, I will qualify therefor, and I will support and

abide by the principles enunciated by the 1-,'be..rtJ4r J 'A (\ Party.

Dated this J {o1:.11 day of () cJo \oe..l , Q D { 3

(Signature of Candidate)

WHOEVER COMMITS ELECTION FALSIFICATION IS GUlL TV OF A FELONY OF THE FIFTH DEGREE

PETITION FOR CANDIDATE

(This petition shallbe circulated only by a member of the same political party as stated above by tbe candidate)

We, the undersigned qualified electors of the State of Ohio, whose voting residence is in the county,

city, village, or township, set opposite our names, and members of the L,'bur7iJ (',An Party,

hereby certify that l'Je \ ~OJ'"l E, Roe..- , whose declaration of candidacy is filed(Nameof Candidate)

herewith, is in our opinion, well qualified to perform the duties of the office or position to which the

person desires to be elected.

Signatures on this petition should be from only one county and must be written in ink. Signatures on thispetition sball be of persons wbo are of tbe same political party as stated above by tbe candidate.

SIGNATUREVOTING RESIDENCE ADDRESS

STREET AND NUMBER CITY, VILLAGE, ORTOWNSHIP

COUNTY DATE OFSIGNING

Case: 2:13-cv-00953-MHW-TPK Doc #: 23 Filed: 12/02/13 Page: 8 of 12 PAGEID #: 241

SIGNATUREVOTING RESIDENCE ADDRESS

STREET AND NUMBER CITY, VILLAGE, ORTOWNSHIP

COUNTY DATE OFSIGNING

CIRCULATOR STATEMENT - Must be completed and signed by circulator.

I, rJf.- \ SDn E. Bo e ,declare under penalty of election falsification that I reside(printed Name of Circulator)

at the address appearing below my signature; that I am a member of the L,' butAf";AVI Party;that I am the circulator of the foregoing petition containing / 8 signatures; that I witnessed

(Number)the affixing of every signature; that all signers were to the best of my knowledge and belief qualified tosign; and that every signature is to the best of my knowledge and belief the signature of the personwhose signature it purports to be or of an attorney in fact acting pursuant to section 3501.382 of theRevised Code.

WHOEVER COMMITS ELECTIONFALSIFICATION IS GUILTY OF AFELONY OF THE FIFTH DEGREE

(Signature of Circulator)

(permanent residence address)

CA~bviJ~ Vhto Lf31a5(City oillage, State and Zip Code)

o~.ao 1

Case: 2:13-cv-00953-MHW-TPK Doc #: 23 Filed: 12/02/13 Page: 9 of 12 PAGEID #: 242

Voting Residence Address City, Village, orName Street and Number Township County Date of Signing

Leigh Ann Lucas 263 Fair St. Quaker City Guernsey 10/18/2013

Andrea L Shaffer 266 S. 2nd St. Byesville Guernsey 10/19/2013

Denise D. Terrell 67946 Wintergreen Rd Lore City, Oh Guernsey 10/19/2013

Charles Howard Dennis 16611 Leatherwood Rd Lore City, Oh Guernsey 10/19/2013

Ryan K. Wayble 62870 Institute Rd. Lore City, Oh Guernsey 10/19/2013

Shanna Kaye Wayble 62870 Institute Rd. Lore City Guernsey 10/19/2013

Dale Edward Wright 13855 Old Glory Rd Lore City Guernsey 10/19/2013

Laverne R. Lucas 220 Smith Ave Quaker City Guernsey 10/19/2013

Karen Sue Prouty 66977 Fairground Rd Lore City Guernsey 10/19/2013

Larry Lee Workman 66999 Fairground Rd Lore City Guernsey 10/19/2013

Charles David Lent 117 Main Street Quaker City Guernsey 10/24/2013

Ronald L Roberson 60286 Kennonsburg Rd. Salesville Guernsey 10/24/2013

Ashley Lenhart 21 West Main Street Quaker City Guernsey 10/24/2013

Lanny Ross Neiswonger 237 Fair St Quaker City Guernsey 10/24/2013

Korina Tracy 237 Fair St Quaker City Guernsey 10/24/2013

Richard Neiswonger 237 Fair St Quaker City Guernsey 10/24/2013

Ryan Eugene Perkins 245 Fair St Quaker City Guernsey 10/24/2013

Vicky L Lent 117 Main St Salesville Guernsey 10/24/2013

Case: 2:13-cv-00953-MHW-TPK Doc #: 23 Filed: 12/02/13 Page: 10 of 12 PAGEID #: 243

Receipt for Cash, Petitions or Resolutions~

Office of the Board of Elections ~---I-J.--.I'-L~"-'----*,","-'----County, Ohio 10 -d7 ,:;:k13Received of ---.!...t ---tJ':.....t-'~~-~~--.!-+==---::___+______:--_A---------,,_____,___----

eclaration of Candidacy Petitions for the office of -L....:.----=5~E..L..!.-=--H::'::F_-, of the ~ party

DNominating Petitions for the office of -=--=:-- _

DLocal Option Petition Filing Fee Paid: In-----\ ~S-I J1)DReferendum Petition Subdivision: ~\L~'~c=~ G\l....\? (ASe-

Dlnitiative Petition Number of Signatures: ::::'-l{Part - Petitions:

DESCRIPTION - PURPOSE, RATE, DATE OF ELECTION, ETC.DTAXLEVy- _DBONDISSUE- _

o CHARTER AMENDMENT - _

DOTHER -

OTHER CASH RECEIVED $ FOR

BOARD OF ELECTIONS, By -----~:;;Af-------\-_\_=-=---=-------------

-------~----------~---------------------~- ----.-- --------- - ------ - --- --- ---

Case: 2:13-cv-00953-MHW-TPK Doc #: 23 Filed: 12/02/13 Page: 11 of 12 PAGEID #: 244

Print Name & Title If Not Candidate

IO/cJ5/131 ,

Date

Form No. 30K - Prescribed by Secretary of State (3-88).R.C. 3517.11(B)

RECEIPT FOR CAMPAIGN FINANCE AND PRACTICES MATERIALNOTIFI :TION OF REPORT DEADLINER

. ,," ~ <1"--' 97' s1:ak erName of Candidate Office Sought

The undersigned hereby acknowledges receipt of the following materials:1. Provisions of the Ohio Revised Code and administrative rules of the Secretary of State relative to

campaign finance and campaign practices;2. Instructions for completing campaign finance reports;3. At least one copy of each campaign finance reporting form requested; and, if applicable,4. A personal financial disclosure statement form to be filed with the Ohio Ethics Commission.

The undersigned candidate hereby acknowledges notification of the deadlines for filing campaign financereports required by R.C. 3517.10(A}. Further notification may be made bq§ cI~Ss ~ (Valid only if signedby candidate.)

Signature

& '-I 'J~0 CoA\ "1~,-,<--oA-~QI.L'-~----",0",---,' A,---,fYL--.::..:~",--,-('--,--,,~ ~<..:.....Jq--=-~ -t-/ --,O~h,-,-,t,--,<-~o_-6-i/-->.<--.i~?...•....d""",,-5 _Street Address ..J Zip Code

Case: 2:13-cv-00953-MHW-TPK Doc #: 23 Filed: 12/02/13 Page: 12 of 12 PAGEID #: 245