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Law Office

ROBERT R LUDGIN
33 Linden Place
Hartford, Connecticut 06106

Post Office Box 261775 (""*> 549-3928


HanfcrO, Connecticut IM> 126-177 S F** (860) 524-S238

January 28,2010

FOR HAND DELIVERY .


Ms. Olga I. Vazquez
Hartford Democratic Registrar of Voters
C City Hall
550 Main Street
Hartford, Connecticut 06103

re: Fifth Assembly District Democratic Primary Petitions

Dear Ms. Vazquez:

I am writing to you on behalf of my clients, the Fifth Assembly District candidates


0 known as.-"Democrats For A New Direction" with the lead name of candidate Mamie Bell,
169 Cleveland Avenue, Hartford, 06120 and including among its candidates Hon. Marie
Lopez Kirkley-Bey, State Representative, of 39 Ashley Street, Hartford 06105.

As I understand the facts concerning the circulation of petitions for the 2010 Hartford
Democratic Town Committee primary, there has been a petition presented by my clients to
your office containing more man the required 323 signatures of electors within the fifth
assembly district, that said petition was filed prior to the January 27th 4:00 p.m. deadline, and
that each and every separate sheet of such petition has been signed by the circulator of the
page, that each circulator was an enrolled party member of the Democratic Party of the City
of Hartford and entitled to vote, that each separate page of the petition contained a statement
as to the authenticity of the signatures thereon and the number of said signatures and that
each page was signed by the circulator thereof under the penalties of false statement and
contained the circulator's address in the town (i.e. Hartford) in which the circulator is an
enrolled party member. Furthermore, I have been advised that each separate sheet of such
petition was acknowledged before an appropriate person as provided in Section 1-29 of our
statutes, namely each circulated petition has been notarized by a judge, a magistrate, a court
clerk or deputy court clerk, a town clerk, a notary public, a justice of the peace or an attorney
Y admitted to the bar of the State of Connecticut.

On the other hand, I have been advised by my clients that a petition was circulated by
another group of fifth assembly district enrolled Democrats including yourself (henceforth
referred to as the "The Olga I. Vazquez Slate"), for them to be placed on the ballot as
Democratic Town Committee candidates but that all of their petition pages contained a total
of only 288 signatures. Furthermore, I have been advised by my client that none of The Olga
Vazquez Slate petition pages has been signed by the circulator and none of them has been
Ms. Olga I. Vazquez, Democratic Registrar of Voters
Page -2-
o
acknowledged by a person authorized to do so pursuant to Section 1-29 of our statutes.
Those two Mings are each a violation of the mandatory requirements of Section 9-410.

Therefore, I hereby demand that you comply with the requirements of Section 9-410
which are that for any sheet of a petition that does not contain the required statement by the
circulator as to the authenticity of signatures or upon which the statement of me circulator is
incomplete in any respect "SHALL BE REJECTED BY THE REGISTRAR" (capitalization
added by me).

Also, note that Section 9-412 of our statutes also provides that "THE REGISTRAR
SHALL REJECT" (capitalization added by me) any page of a petition which does not
contain the certifications required by Section 9-410. Please note that Section 9-412 is the
C\ section that requires you to file the petition pages submitted to your office with the Town
Clerk's Office. However, by reason of the concluding sentence of Section 9-412, any page of
a petition which does not contain the appropriate certifications required by Section 9-410,
should not be filed with the Town Clerk's Office but rather must be rejected bv you.

Should you fail to comply with these statutory requirements referred to above, I plan
on behalf of my clients to make appropriate complaints to the Secretary of The State's Office
and to the State Elections Enforcement Commission. Furthermore, if necessary, we may
consider filing a lawsuit in the Superior Court seeking a writ of mandamus to require you to
comply with the requirements of the statute.

Very truly yours,

RFL/dkr
cc: Hon. Susan Bysiewicz
Secretary of the State
State Capitol, Room 104
V 210 Capitol Avenue
Hartford, Connecticut 06106

Ted Bromley, Esq.


Office of the Secretary of the State
Elections Division
30 Trinity Street
Hartford, Connecticut 06106
Albert P. Lenge, Esq.
Executive Director/General Counsel
State Elections Enforcement Commission
18-20 Trinity Street, Suite 101
Hartford, Connecticut 06106

Mr. John Bazzano, Town Clerk


City of Hartford
550 Main Street
Hartford, Connecticut 06103

John Rose, Jr., Esq.


Corporation Counsel
City of Hartford
550 Main Street
Hartford, Connecticut 06103
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