om

Chalice tweeted: ... Read the Grand Jury petition challenging Obama HERE -
http://scribd.com/doc/27333027/Motion-t ... -10-SCRIBD. 1

So, we've read it. And have a few comments.

From the motion:

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Motion for Reconsideration:
Introduction
The Petitioner filed to appear before the McHenry County Grand Jury alleging
massive voter fraud in McHenry County and in the State of Illinois relating to the
2008 Primary and General election.

tija
Oops -- petitioner apparently didn't get the memo explaining how her claims are about
ELECTION fraud, not voter fraud.

Motion for Reconsideration:

When before the court on January 20th, the Petitioner came to Court with this
information in a lengthy amended motion, understanding it to be quite detailed as
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one might expect in a memorandum or brief and as prepared for testimony before
the Grand Jury.

Uhm. Not exactly. That "amended motion" was an incoherent stream of consciousness rant, and
not at all the type of memorandum or brief that would be prepared by a competent person
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(attorney or not) for testimony before a high school debate club.

Motion for Reconsideration:

Fully believing she was complying with the prior request of the Court and of the
State‟s Attorney, the Petitioner provided a copy to the State‟s Attorney and Judge
of

Prather.

Interesting. Is this an .. obtuse reference to being told that her "amended motion" was not in
compliance? I don't know - the wording is ... interesting.

Motion for Reconsideration:

ds

1. The Circuit Court has the authority to address the petitioner‟s request. „The
members of the Grand Jury are under supervisory authority of circuit courts.”
(Report of Grand Jury of Marshal County, 438 N.E.2d 1316,
Ill.App.3.Dist.,1982).
ien

Three points:

A). The first sentence finds no support in the second sentence. In other words, even if members

1
Note: A downloadable version of the publicly filed motion is available here -
http://www.scribd.com/doc/27357709/MERONI-v-McHENRY-COUNTY-GRAND-JURY-Motion-to-Reconsider-
Order-of-1-20-10-2-22-10-SCRIBD.
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of the grand jury are under the circuit court's supervisory authority, it does not necessarily follow
that the court has the authority to do what the petitioner wants it to do here. It means only that
the grand jury is subject to the authority of the court.

B). The second sentence is a purported quote from the case Report of Grand Jury of Marshal
County. However, this is a misrepresentation as the quote appears nowhere in the case. The

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closest excerpt is as follows:

"The grand jury is an autonomous body which is part of the apparatus of our
judicial system. In theory, it is controlled by the judiciary by whom it is called
into being. In practice, it is the handmaiden of the prosecutor who serves as its
legal advisor. Its members, however, are under the supervisory authority of our

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circuit courts."

It would not have been wrong for the petitioner to make the general statement - because that
statement is a fair reading of the quoted excerpt above. What *is* wrong, however, is to state
that you are QUOTING from a case when you are not.

C). As a first year law student, you learn quickly to read an entire case before citing it. Even if
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the case has a "great quote" for you - you really HAVE to read the entire case to make sure that
there's no "bad quotes" that hurt your case. I've read the prior pleadings filed by Sharon
Meroni/Chalice Jackson in this case and followed Chalice's twitters and - although her
statements can be rather ... obtuse ... at times, as I understand her arguments, she can only hope
that the Judge doesn't read Report of Grand Jury of Marshal County, because it really only hurts
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her case.

Motion for Reconsideration:

2. The petitioner is desirous of seeing the US Constitution, the Illinois
Constitution and the laws of the State of Illinois being upheld. The petitioner
of

asserts she is a victim of voter fraud.

Rather obtuse double passive intro. How about: "The petitioner seeks to uphold US Constitution,
the Illinois Constitution and the laws of the State of Illinois." (or .. to have the US Constitution ...
upheld.")
ds

Motion for Reconsideration:

3. The petitioner argues that the matters raised in her petition are most
extraordinary and involving due process and miscarriage of justice. “It is only
under most extraordinary circumstances, where necessary to prevent deprivation
of due process or miscarriage of justice, that court should exercise supervisory
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power over grand jury investigation. (Matter of Swan, 415 N.E.2.d 1354,
Ill.App.2.Dist., 1981)

A few points.
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A). Once again petitioner misleads the court by misquoting from Matter of Swan. The ACTUAL
quote is (corrections in italics):

It is, however, only under the most extraordinary circumstances, where necessary
to prevent a deprivation of due process or a miscarriage of justice, that a court

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should exercise its supervisory power over a grand jury investigation.

Are these material changes? No! However, the fact remains that petitioner SAYS she's quoting
from a case, but fails to do so.

B). Here, rather than citing to a case that actually hurts her argument, petitioner cites a case that

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has no relevance to her case - it's inapposite. (See 1-C, above.) In Matter of Swan, the defendant
was found guilty of contempt for failing to provide fingerprints requested by the grand jury. He
argued that this request was unlawful, and that the court should have quashed the request. In
upholding the court's order (and finding of contempt), the court stated as follows:

We agree with respondent's argument that a court has a duty to prevent perversion
of the grand jury process ..., and that the use of information acquired in violation
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of a privilege ...; or otherwise illegally acquired ..., should be suppressed. It is,
however, only under the most extraordinary circumstances, where necessary to
prevent a deprivation of due process or a miscarriage of justice, that a court
should exercise its supervisory power over a grand jury investigation. ... The
grand jury's request for fingertip prints in the present case cannot be considered as
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harassment; the considerations of due process which govern grand jury
proceedings do not give rise to a right to refuse to comply with a subpoena simply
because the witness believes the grand jury already has the information requested.
While repeated requests for information already provided could amount to such a
disregard for due process that a court would exercise its supervisory powers, the
of

facts of this case do not warrant such judicial intervention. The trial court's order
prohibiting further subpoenas directed to defendant except on motion of the State
sufficiently protected him from abuse of the grand jury process.

In other words, the appeals court here affirmed a trial court's right to PROHIBIT the Grand Jury
from issuing more subpoenas (i.e., the trial court's right to limit evidence gathered), while
ds

refusing to find that the trial court should have quashed the subpoena requesting fingerpints.

This case provides no support for the argument that a court may require a grand jury to consider
evidence. As such, it provides no support for petitioner's argument.
ien

Motion for Reconsideration:

4. The petitioner‟s suit is peculiarly within the public‟s interest and the public‟s
right to know”

Agreed. And that's why Sharon Meroni's repeated attempts to hide the fact that she's filed these
cases is beyond ridiculous - as the court held on Feb. 3, 2010.
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Motion for Reconsideration:
5. On February 3, 2010, the petitioner went before Judge Michael Caldwell on a
Motion for a Temporary Restraining Order. During the time the Petitioner was
before Judge Caldwell, he informed her that he had used a portion of the 2 hour
break from the court processes, to review the full file, including the amended
filing. His ruling therefore reflects at least some review of the petitioner‟s

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arguments in the amended motion and he found:

“In the instant case, however, the nature of the case, the allegations
contained in the pleadings and the relief requested has a unique public
interest. The challenge is to the validity of elections and the commission
of fraud in relation to those elections. The mere fact that such a charge has

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been formally made and that the petitioner has moved forward with it in
the public domain is peculiarly within the public‟s interest and the public‟s
right to know what is occurring in the judicial system that could affect the
election system. No more important public question could be raised by
such a suit……

Continuing, Judge Caldwell found that

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“The nature of the case and its importance to the public seriously outweigh
any personal considerations that the plaintiff may have regarding access to
papers filed.. “
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Agreed. And that's why Sharon Meroni's repeated attempts to hide the fact that she's filed these
cases is beyond ridiculous.

A). Interestingly, what petitioner here failed to note is the introductory sentence that precedes
the excerpt above:
of

Feb. 3 Order:
"Every court file is vested with a presumed public interest aspect. Openness in the
operation of the court system insures its fairness."

B). Of course, she failed to quote the following excerpts as well:

ds

Feb. 3 Order:
"The threat that moved the petitioner to action is apparently a current one.
However, the court file and all it contains has been in the public domain since the
suit was filed. Only after the petitioner has come under critical scrutiny has
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the alleged necessity for this protection arisen. It is untimely at best and
insubstantial at worst.

Petitioner also alleges that there e have been certain personal actions taken against
her, i.e., stolen mail, being followed, etc. None of these has been verified to
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have been done by any identified individual or group. The assertion is simply
unwarranted speculation, guess and conjecture."

C). She claims that because Judge Caldwell reviewed the entire file, his ruling necessarily
reflected his thoughts on the merits of her Amended Motion seeking access to the grand jury. By
parsing his Memorandum Opinion and Order, she has made it appear that Judge Caldwell gave

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nodding approval to her objectives and, indeed, the case itself presented a matter of unique
interest to the public. But let's take a look at how Judge Caldwell framed the issue that he ruled
upon:

"Petitioner now comes before the court on a motion to impound the court file
because the threatened release of the court file's information to a group known as

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Politijab will constitute and [sic] unwarranted invasion of her privacy and
harassment and threats of imminent harm."

He goes on to explain that there is a "general common law right of access to public records and
documents, including judicial records," noting that "a presumption in favor of access arises
[citation omitted] and establishes, as a general matter, that court files should be open to the
public for inspection and copying." He continues, describing the balancing test required between
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the public's right to access with the privacy concerns of one who would seek to restrict access. A
"compelling interest" is required to overcome the presumption of access.

The paragraph containing the parsed language is introduced by this sentence:

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"Every court file is vested with a presumed public interest aspect."

Then, immediately following the parsed language Judge Caldwell makes the following
observation:
of

"The petitioner fears unfair, unrestricted and perhaps vitriolic comment in the
public domain, principally on the internet, as a result of the bringing of this
lawsuit. The nature of the case and its importance to the public seriously outweigh
any personal considerations that the plaintiff may have regarding access to the
papers filed in this case and any critical comments that may be made on account
of it."
ds

Taken in its full context, Judge Caldwell's meaning is clear: In a case in which allegations were
leveled that "certain election fraud or frauds had occurred" -- unquestionably a matter of public
interest -- the petitioner herself created the situation in which the public interest outweighed her
interest in maintaining privacy. Even more telling is this observation by Judge Caldwell:
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[T]he court file and all it contains has been in the public domain since the suit was
filed. Only after the petitioner has come under critical scrutiny has the alleged
necessity for this protection arisen. It is untimely at best and insubstantial at
worst.

(emphsasis added)
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Judge Caldwell was not conveying his belief that the case had compelling public significance.
The case obviously lacked merit, as demonstrated by the fact that relief was denied by Judge
Prather. Rather, Judge Caldwell was pointing out the incongruity of alleging a matter of
public concern -- fraud in the electoral process -- and then asking for a private resolution of
that issue once her lawsuit had come under criticism in the public marketplace of ideas.

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Motion for Reconsideration:
6. “The judge of the circuit court may order a special venire to be issued for a
grand jury at any time when he is of the opinion that public justice requires it.”
(705 ILCS 305/19) (from Ch. 78, par. 19) This issue has already been found to be
peculiarly within the public‟s interest and the public‟s right to know” and requires

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an in-depth review of election processes in the state of Illinois.

Sometimes, the stupid (or deliberate misrepresentation?), it burns.

A). Under the statute, a judge MAY order when [S/]HE is of the opinion that public justice
requires it. In other words, (a) a judge has DISCRETION to order if, in the JUDGE's opinion,
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public justice requires a special grand jury.

B). Judge Caldwell found that:

(i) "Every court file is vested with a presumed public interest aspect. Openness in the
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operation of the court system insures its fairness"; and

(ii) "The mere fact that such a charge has been formally made and that the
petitioner has moved forward with it in the public domain is peculiarly within the
public’s interest and the public‟s right to know what is occurring in the judicial system
of

that could affect the election system. No more important public question could be raised
by such a suit."

Maybe it's merely an issue of ignorance/illogic rather than deceit - but there's a big difference
between what information is within the public‟s interest and, thus, should not be sealed, and
when a situation requires, as a matter of public justice, a special grand jury.
ds

Nowhere in Judge Caldwell's order is there anything whatsoever to support the argument that
any factual or legal allegations raised require, in the interest of public justice, a special grand
jury. Nor could he have held such a thing, as he does not govern over grand juries at all. Under
the statute - to which petitioner herself cites - the decision of whether to call a special grand jury
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rests in the sole discretion of the circuit judge (here, Judge Prather).

Judge Caldwell merely held, essentially, that Sharon Meroni made her bed and she will now lie
in it: Having publicly filed her pleadings (described variously as, for example "untimely at best
and insubstantial at worst" and "simply unwarranted speculation, guess and conjecture"), her
files will remain public.
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Stated another way, Caldwell was dealing with the "public‟s interest" in knowing about court
proceedings.

Illinois law permits judges to, within their discretion, convene special juries when public justice
requires it. In that context, "public justice" may be reasonably understood to mean involving the
class of crimes against public justice (such as bribery of judges or jurors, or receiving the bribe.

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perjury, barratry, compounding felonies, misprison of felonies, extortion, suppressing evidence,
obstructing legal process, etc.).

Motion for Reconsideration:

7. The Petitioner was not provided opportunity to have evidence presented in the
amended motion, to be reviewed by Judge Prather.

tija
Yes, and .... ??? A big chunk of the "amended motion" dealt with the issues raised before Judge
Caldwell and, as such, are now moot. I'll have to go back and check, but I don't recall much (or
any) new information - I recall some ramblings about her personal view of "sovereign will" and
about " KISS and McHenry County Wisdoms" and the like. But I don't recall any presentation of
new "evidence" or new legal authority, sufficient to support a reconsideration.

Motion for Reconsideration: oli

8. The Grand Jury is empowered to hear the petitioner‟s complaint about the theft
of her vote. “The Grand Jury has the authority to inquire into and true
presentment make of all such matters and things as shall be given in their charge
or otherwise come of their knowledge touching the present service.” (705 ILCS
P
305/18 ch.78, par.18)

Not sure what she's quoting, but it isn't 705 ILCS 305/18, which provides the required oath that
grand jury foreperson and jurors must take. This statute does not address grand jury power or
authority.
of

Ignorance or deliberate deceit - I cannot judge. But I did a search for that statement anywhere in
the Illinois Code, but received no returns. It's a mystery.

Motion for Reconsideration:

9. The Grand Jury has never been informed of this court action involving them
ds

and therefore without due process, denied knowledge touching their service. They
are the Defendants.

This statement is beyond obtuse. I think she's trying to say that (a) the grand jury members are
the defendants here; and (b) failing to provide them with Petitioner's evidence deprives them of
their due process rights as defendants.
ien

::::faceplant::::

First, given that (a) state attorneys determine what goes before grand juries; and (b) the court has
supervisory authority over the grand jury; and (c) the grand jury (presumably) has no idea what
she seeks to submit to them -- and, thus, could not possibly have done anything wrong in failing
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to consider it .... her attempts to make them defendants is - uhm - illogical in the extreme.

Second, there is no due process violation here where Meroni has made some crazy-ass false
claims of some sort of wrongdoing by the grand jury (i'm still trying to wrap my head around that one),
although she's has provided absolutely no evidence that anyone on the grand jury has committed
any wrongdoing whatsoever.

b.c
Motion for Reconsideration:
10. Because the petitioner named the Grand Jury in her suit, she sent the 12/06/09
petition through the U.S. Mail via the McHenry County Government Center,
addressed to each of the Grand Jury, and fully informed the Court and the States
Attorney of her actions so they could serve the grand jury notice of the court
proceedings involving them. (12/16/09) The Grand Jury was denied access to

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these documents until determination at the hearing on 1/20/10.

And, according to the very case -- People v Parker, 30, N.E 2d 11 (Ill. 1940) -- she later cites
(¶18), such an act is unlawful, and a person who commits such act is guilty of contempt of
court!!!! I wonder if she actually read this case?????

oli
In People v Parker, the Illinois Supreme Court upheld a criminal conviction of contempt (and six
month jail sentence) against a person who sent a letter to the grand jury foreman alleging
corruption against certain other individuals. There, the letter accused a newspaper company and
"a certain political machine" with conspiracy to steal money from the County. The letter included
an offer to appear before the grand jury and produce evidence in support of the accusations. does
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any of this sound remotely familiar?

The court held:

By tempering the tone of his accusations, Parker seeks to escape the rule which
of

forbids communicating with the grand jury, except through recognized lawful
channels. This he cannot do. ...The obvious purpose of communicating with the
foreman of the grand jury was to incite the grand jury into action against those
accused in the letter. The grand jury was invited to call for the production of
evidence which the communication stated was in the possession of the Puritan
Church. This was an unofficial volunteer communication to the grand jury,
ds

inviting them to start, on their own authority, a prosecution against those accused
in the communication. The sending of a communication, such as that set out in the
information, to the foreman of the grand jury constitutes contempt of court.
Wharton on Criminal Practice and Pleading, 8th Ed., sec. 307. ...
ien

In other words, the Illinois Supreme Court has held that actions such as those alleged in this
petition are unlawful, and it has upheld a six month jail sentence against a person who committed
such acts.

And ........ this helps her how ? ? ? ? ? ?

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Motion for Reconsideration:
11. Besides the original petition, and a letter, included in each packet mailed
to the Sitting Grand Jury, were 30 letters from McHenry County residents who
affirmed they are aware of matters related to the original motion and believe it is
worthy for the Grand Jury to investigate.

b.c
See discussion above. Private individual communications with grand juries is unlawful in
Illinois.

Motion for Reconsideration:

12. The Courts have already decided that “grand jury proceedings are not
restrained by technical, procedural, and evidentiary rules governing conduct of
criminal trials.” People [v.] Pinjoli, 581 N.E. 2d 693 Ill App.3.ist., 1991) The

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petitioner argues the grand jury must be unfettered in considering information that
comes to them in the course of their service.

Yeaaayyy! She actually correctly quoted from a case here! Points for accurate quoting.

Of course, she took the case totally out of context. Let's see what the case is about. In People v.
oli
Punjoli, the circuit court dismissed an indictment on the grounds that the state attorney
introduced evidence of the defendant's prior convictions during the grand jury proceedings.
During a trial, the prosecutor may not introduce evidence of prior convictions unless the
defendant testifies.
P
So, in the excerpt quoted by Petitioner, the court notes that grand jury proceedings aren't
governed by the same technical evidentiary rules that apply during trials, then also notes that,
during the grand jury proceedings, the defendant DID in fact testify. Thus, the court held:

It is well settled that grand jury proceedings are not restrained by the technical,
of

procedural, and evidentiary rules governing the conduct of criminal trials ... It is
also well settled that even at trial a defendant's prior conviction may be introduced
for impeachment purposes if he testifies. ... If a defendant can be impeached when
he testifies at trial, we find no basis for saying that he cannot be impeached with a
prior conviction when he testifies before a grand jury.
ds

Here, we find that the trial court erred in dismissing the indictments. The evidence
showed that the defendant testified before the grand jury. As such, the State could
introduce impeachment evidence, including evidence of his prior conviction. ...
Therefore, we conclude that the indictments in case number 90-CF-140 and 90-
CF-141 should be reinstated.
ien

How does this ruling apply to Meroni's presentments? It doesn't. Here, there are no issues as to
whether any evidentiary (or procedural) rules have been violated. Once again, she's taken what
she thinks is a "pithy" quote - out of context.
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Motion for Reconsideration:
13. The Court erred in failing to rule on permitting this information to be
delivered to the intended recipients.

So, as noted above, mailing individual letters to a grand jury is unlawful, subjecting the person to
significant jail time. So -- here, petitioner argues that the Court erred in failing to permit her to

b.c
commit an unlawful act. Now this is a ... "creative" argument.

Oh, and to the extent that she's arguing that she's not "individually" mailing them by providing
them to the Court - but that the Court should order that the state attorney deliver them, see below
for a discussion of People v. Sears - which, although cited in her brief (¶18) - directly refutes that
contention.

tija
Motion for Reconsideration:
14. Besides preventing the delivery of the petitioner‟s mail, likewise the letters
from about 30 other residents, who believe this matter is of significant public
interest, have not been delivered.

See note above.

Motion for Reconsideration:

oli
15. Because the Court has denied the Sitting Grand Jury access to these
documents, as defendants they are deprived the right to information that
“otherwise come of their knowledge touching the present service”
P
There's that odd quote again "otherwise come of their knowledge touching the present service."

I just did a search again through the entire Illinois Code, and that phrase does not exist in the
Westlaw database. Then, I thought, maybe she pulled that from a case - so, I did a search for that
of

phrase through all Illinois cases (which go back to the 1800s in Westlaw). No luck. I'd really like
to know where that quote came from. Westlaw is pretty good about fixing omissions - which
sometime DO happen.

Then, I started parsing the quote into little bits, and come back to 705 ILCS 305/18 - which deals
with the foreman's oath. Maybe this is just another situation where she twists the text of a law to
ds

suit her fancy, then puts it in quotes to make it look official. The grand jury foreman's oath, set
forth in 705 ILCS 305/18, provides as follows:

“You, as foreman of this inquest, do solemnly swear (or affirm, as the case may
be), that you will diligently inquire into and true presentment make of all such
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matters and things as shall be given you in charge, or shall otherwise come to
your knowledge, touching the present service; you shall present no person
through malice, hatred or ill-will; nor shall you leave any unpresented through
fear, favor or affection, or for any fee or reward, or for any hope or promise
thereof; but in all of your presentments, you shall present the truth, the whole
truth, and nothing but the truth, according to the best of your skill and
understanding; so help you God.”
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Is that what she's talking about???? If so, then, ... I'm at a loss. If so, she's somehow twisting the
foreman's oath -- which deals with the foreman's obligation to consider everything given to
him/her, or that otherwise comes to his/her knowledge -- into an obligation imposed on the
Court, to make sure that the foreman gets all information that some random person off the street,
AKA or not, thinks s/he should have.

b.c
There are about 20 notes of cases discussing 705 ILCS 305/18. Not surprisingly, none of them
remotely support this contention. Indeed, the cases interpreting 705 ILCS 305/18 understand it to
require that all foremen (and grand jury members, under a second paragraph) get sworn in.
Indeed, there aren't even cases relying on this code to support a ruling that a foreman failed to
comply with his/her oath.

tija
In short, there's no law -- or logic -- to support the contention that because the law requires that
grand jury members take an oath, courts are obligated to permit individuals to present allegations
for the grand jury's consideration.

I don't know what else to say. It's just ... nonsensical.

Motion for Reconsideration: oli

16. The petitioner is denied access to her right to the Grand Jury‟s review of the
knowledge that touches their service. She asserts she is competent to testify to a
crime against her that she has personal knowledge of.
P
Notably, petitioner fails to cite a scintilla of support for the contention that citizens have a "right"
to have grand juries review issues they deem important.

And - I'd love to know how she interprets that "touch their service" (or, correctly quoted,
"touching the present service." I'm suspecting another .. uhm .. "creative" interpretation. On this
of

one, I won't speculate, but, I will say that there is at least one Illinois case discussing what this
term means, and -- I fail to see how the phrase helps petitioner here.

In People v. McCauley, 256 Ill. 504 (Ill. 1912), a defendant challenged his conviction on several
grounds, including on the grounds that when the grand jury - which had apparently been
dismissed -- was called back to render an indictment. Defendant sought to challenge the
ds

conviction on the ground that the grand jury was not resworn in when it was recalled. As the
Illinois Supreme Court explained, there was no need to swear in the grand jury again, because
when recalled by the court, it was still under the original oath:

"The form of the oath prescribed by the Legislature in [705 ILCS 305/18's
ien

predecessor] is broad enough to cover all of the service that may be rendered by
the grand jury during the term of court for which it is drawn. The oath requires
that the grand jury shall „diligently inquire into and true presentment make of all
such matters and things as shall be given you in charge, or shall otherwise come
to your knowledge, touching the present service.‟ The 'present service’
evidently refers to and means all of the services that may be lawfully required
of the grand jury during its existence as an organized body. . ..."
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In other words, grand jury members must take an oath that they will inquire into all matters given
to them ... (according to the legally-established procedures) during their service as jurors.

In short, petitioner's attempt to create a duty imposed on the court to provide information to the
grand jury finds zero support in either the statute (mis)quoted, or the cases interpreting the

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statute.

Motion for Reconsideration:

17. “It is the duty of grand jury to inquire into offenses which come to its
knowledge whether from court, state‟s attorney, its own members or from any
source, but the proper channel for presenting information to grand jury is the
state‟s attorney and it is improper to communicate directly with the grand jury.”

tija
(People v. Sears, 273 N.E. 2d 380 Ill., 1971) (S.H.A. Const. 1870, art. 2 &8;?art.
6, 1et,; ? S.H.A. Const.1970 art.1, 7; ? S.H>A. ch 14, 5, 6,; ?ch.38, 112-3(a), 112-
4(a); ?ch. 78, 19.Corp. )

Maybe, petitioner is just unfamiliar with the concept of proper use of quotation marks? I.e., if
you purport to be quoting from something, you MUST either quote it exactly as is, or indicate
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what you changed (e.g., use ... when you delete something, use [brackets] when you change a
lower case to upper case, or add a word ... simple things like that.)

The actual quote (corrections in italics) is:

P
It is true that it is the duty of the grand jury to inquire into offenses which shall
come to its knowledge ‘whether from the court, the State's Attorney, its own
members, or from any source’ ... but it is clear from the holding in People v.
Parker, 374 Ill. 524, 30 N.E.2d 11, that the proper channel for presenting
information to the grand jury is the State's Attorney ... and it is improper to
of

communicate directly with the grand jury."

TIP ALERT: So, a corrected, appropriate version of ¶17 would be as follows:

Motion for Reconsideration - CORRECTED:

ds

17. “It is the duty of [] grand jury to inquire into offenses which
come to its knowledge []whether from [] court, [s]tate‟s [a]ttorney,
its own members or from any source,. . . . but . . . the proper
channel for presenting information to [] grand jury is the [s]tate‟s
[a]ttorney . . . and it is improper to communicate directly with the
ien

grand jury.” (People v. Sears, 273 N.E. 2d 380 Ill., 1971) (S.H.A.
Const. 1870, art. 2 &8;?art. 6, 1et,; ? S.H.A. Const.1970 art.1, 7; ?
S.H>A. ch 14, 5, 6,; ?ch.38, 112-3(a), 112-4(a); ?ch. 78, 19.Corp. )

Sometimes, it's the simplest things. Anyway, on to the substance. This is truly priceless.

First, after complaining that she was prevented from submitting her personal letters to the grand
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jury, she cites to this case, which even under her botched quote, clearly states that "the proper
channel for presenting information to the grand jury is the State's Attorney ... and it is improper
to communicate directly with the grand jury."

Second, so -- for much of the last 16 paragraphs, petitioner tries to make the argument that the
court has somehow erred by failing to permit her to present her evidence to the grand jury

b.c
directly. Now, she sites to People v. Sears, a case in which Illinois Supreme Court essentially
affirmed a state's attorney's right to refuse to present evidence when ordered by the court.

In People v. Sears, the Illinois Supreme Court addressed a few issues, including whether a state's
attorney should be held in contempt for failing to comply with court orders to issue subpoenas
requiring witnesses to testify for a specially-convened grand jury. There, the circuit court

tija
ordered the state's attorney to subpoena a bunch of witnesses to testify before the grand jury --
essentially, the court ordered the state's attorney to subpoena every single witness who had
testified to the same/related issues before a federal grand jury. The state attorney refused to do
so. The circuit court held him in contempt of court. He appealed.

And -- on appeal, what did the Illinois Supreme Court do? It reversed the circuit court's finding
of contempt. The Supreme Court did, in fact, recognize the circuit court's jurisdiction and duty to
oli
supervise the grand jury proceedings, and did, in fact, recognize that there may be circumstances
where a court would have jurisdiction to require witnesses to appear before the grand jury.
However, the court held that:

"The preservation of the historic independence of the grand jury, however,

P
requires that such supervisory power be exercised only when failure to do so will
effect a deprivation of due process or result in a miscarriage of justice. It is the
opinion of the majority of members of this court that the circumstances shown
here do not furnish a sufficient basis for the action of the court and the order
holding Sears in contempt for refusing to subpoena the witnesses is therefore
of

reversed."

In other words, this is NOT the kind of case you want to cite when you have a state's attorney
who is refusing to present your "evidence" and you're trying to convince the court to present the
evidence anyway or compel the state's attorney to do so.
ds

Now, yes, a few paragraphs ago, petitioner made the argument that someone was being deprived
of their due process. But, as noted above, it cannot be that the grand jury is being deprived of
their due process, because, even though for some inexplicable reason, Meroni named them as
defendants, there is no court case, or even a state-sanctioned investigation pending against them.
And, to the extent that she's trying to argue that she is being denied due process, as noted above,
ien

she's provided no support whatsoever for the argument that a citizen is denied due process when
she is prevented from having personal contact with the grand jury - or even when she is
prevented from having her claims presented by the state's attorney (or the court) to the grand
jury.
Fr

Page 13
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Motion for Reconsideration:
18. The petitioner has provided evidence to the State‟s attorney and met with him.
He refused to act. The petitioner has also made complaint to the court which has
jurisdiction to rule on this matter. “A citizen should not be permitted to
communicate with a grand jury, but if he possesses any information justifying the
accusation of anyone, he should impart the information to the State‟s attorney,

b.c
and if the State‟s attorney refuses to act, the citizen can make his complaint to a
committing magistrate.” (People v Parker, 30, N.E 2d 11 Ill., 1940)

Yeah, see comments above regarding People v. Parker.

This argument reminds me of the ones made by people complaining that Congress failed to act

tija
on their petitions to challenge Obama's citizenship. The right to petition Congress does not
translate into the right to force a Congressperson to do what a citizen - or group of citizens -
wants the Congressperson to do.

And, here, any right a citizen has to complain to the committing magistrate when a state's
attorney refuses to buy into her theories does not translate into a right to force the magistrate to
agree with the citizen. A right to a hearing is not a right to the desired result.

Motion for Reconsideration:

oli
19. In denying the petitioner‟s request without review of the evidence, the Court
erred. The court did not consider the evidence presented and therefore no review
of the competence of the evidence or of the petitioners claim that she is the victim
P
of a crime. “The Courts inherent power to review proceedings of the grand jury is
limited to determining whether there was any competent evidence presented and
whether indictment was result of prosecutorial misconduct.” (People v Cora, 606
N.E. 2d 455 Ill. App. 1. Dist., 1992)
of

This is a continuation of the argument that "right to a hearing" really means "right to desired
result." And - the argument is just specious.

Here, Petitioner has had multiple hearings. She has not been denied the right to "complain" to the
committing magistrate (although, given her repeated repetitions, some have argued that she's
abused the right). In short, she's been given the opportunity to complain described in People v.
ds

Parker.

She purports to quote from People v Cora, 606 N.E. 2d 455 (Ill. App. Ct. 1992) to support her
contention.
ien

First, I think she's (mis)quoting the following passage:

The cases cited by the defendant ...simply stand for the proposition that a court
has inherent power to review the proceedings of a grand jury. But its review is
limited to determining whether there was any competent evidence presented and
whether the indictment was the result of prosecutorial misconduct.
Fr

Page 14
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Second, her citation to this case to support the argument that the court erred in ruling against
Meroni's initial complaint(s) clearly demonstrates a lack of even basic understanding of .. the
law.

In People v Cora, defendant challenged his indictment on several grounds, including that the

b.c
state's attorney failed to present sufficient evidence to support the indictment. In rejecting this
claim, the court noted that a court does have the power to review grand jury proceedings.
However, the review is limited to (a) determining whether there is any evidence to support the
indictment - not to replace the grand jury's judgment as to the sufficiency of the evidence with its
own; and (b) determining whether the indictment entered was the result of prosecutorial
misconduct.

tija
In short - the case has absolutely nothing to do with the power (or duty) of a judge to accept
evidence offered by a citizen, or to present that "evidence" to the grand jury. It has to do with
whether a court can "overrule" the results of a grand jury proceeding to dismiss an indictment, as
reflected in the court's conclusion: "The defendant is correct that the trial judge had the authority
to review proceedings before a grand jury.... but the defendant is not correct that a judge has
discretion to dismiss an indictment. ...We conclude that the judge was correct as a matter of law
oli
when he denied the motion to dismiss the indictment."

Motion for Reconsideration:

20. Act 725 ILS 5, Section 112-4 specifically addresses Duties of Grand Jury and
the State‟s Attorney. This section does not address other roles of the Grand Jury
P
specifically relating to when the States attorney refuses to act or to inform the jury
of information touching their service.

Petitioner is correct that 725 ILCS 5/112-4 addresses the duties of the Grand Jury and the State's
Attorney. As for "this section does not address other roles of the Grand Jury specifically relating
of

to when the States attorney refuses to act or to inform the jury of information touching their
service," ... uhm ... well, then. Maybe that means that the statute vests the power to determine
what information goes to the grand jury in the state's attorney. There's a term for that ...

The canon of statutory construction is expressio unius est exclusio alterius (the express inclusion
of one is the exclusion of others). Roughly translated, this phrase means that whatever is omitted
ds

is understood to be excluded. The canon is based on the rationale that if the legislature had
intended to include a particular event, power, remedy, etc., it would have done so expressly; if
the legislature did not provide for such an event, power, remedy, etc. it should be assumed that
the legislature meant not to provide for that.
ien

Motion for Reconsideration:

21. There is sufficient substance in the Grand Jury Act and in the Grand Jury
Handbook referring to this role of addressing matters that touches the grand jury‟s
service, authorizing the Court.
“However, the grand jury possesses broad powers of its own to inquire
into crime and corruption in its jurisdiction. It has a right under the law to
make its own investigation unaided by the Court ....
Fr

Page 15
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So, to support her argument that the court is obligated to "aid" the grand jury by presenting her
evidence to them, she cites a handbook saying that the grand jury may work unaided by the
court. ? ? ?

Motion for Reconsideration:

b.c
[quoting from the handbook].
"It has a right under the law to make its own investigation unaided by the
Court and assisted by any prosecuting attorney. ...

...Yet another indication that the legislature INTENDS for the Grand Jury to look to the state's
attorney for assistance in investigating any potential crimes (even though it may investigate
regardless).

tija
Motion for Reconsideration:
[quoting from the handbook].
"On petition signed by the foreperson and eight other grand jurors,
showing good cause for s[a]me...

oli
...Yet another indication that any expanded grand jury investigation must come from the grand
jury - rather than from the judge, or a private citizen.

Motion for Reconsideration:

[quoting from the handbook].
P
"... the Court may appoint an investigator or investigators to assist the
grand jury in its inquiries...

...Yet another indicator that the court MAY - but is not required to appoint an investigator to
assist the grand jury.
of

Motion for Reconsideration:

[quoting from the handbook].
"Included in this power of investigation is the right of the grand jury to
subpoena witnesses and documents. ...
ds

Exactly - the right of the grand jury - NOT the obligation of the court (or state's attorney), and
most certainly, not the right of a private citizen.

Motion for Reconsideration:

23. There is precedence [sic] for the grand jury to receive its own US mailed
documents without the court‟s interference.
ien

Oh really? Where? The precedents petitioner cites says quite the opposite of what she appears to
seek - the cases she cites say that it is unlawful for a private citizen to seek to directly contact
grand juries through letters.

Motion for Reconsideration:

Fr

Page 16
 om
24. Legal precedence [sic] for the use of a Grand Jury as a government oversight:
The petitioner cites precedence of grand juries in the role separate from the courts
in section 3.0 of her original petition filed December 2nd, 2009.

Uhm, this is a motion for reconsideration. The court considered - and rejected - the Dec. 2, 2009
petition. Repeating - by reference - to the prior pleading is just silly.

b.c
Motion for Reconsideration:
Although the grand jury normally operates, of course, in the courthouse and other
judicial auspices, its institutional relationship with the Judicial Branch has
traditionally been, so to speak, at arm‟s length.” (United States v. Williams, 504
U.S. 36 at 48, 1992)

tija
It is currently 29 º and cloudy in Fowlerton Indiana.

And the weather in Fowlerton is at LEAST as relevant to the Motion for Reconsideration as this
second part of ¶ 24 is.

Motion for Reconsideration:

McHenry County area.

Coal Conspiracy Jan 18 1903
oli
25. A few historical Grand Juries involving government oversight from the

McHenry County Corrupt Labor Leaders June 1905

Lorimer Grand Jury May 1909
P
Herrin-Marian Mine Riots Aug 1922
Clean Prison Grand Jury May 1924
McHenry County Bootlegging Grand Jury Sep 1927
Woodstock Police Taping Feb 1993
Tollway Probe Jan 1995
of

Crystal Lake City Manager Grand Jury Aug 1998

First, I am not familiar with those but find her wording interesting. "government oversight" ?
That happens all the time. Does she mean court oversight (as opposed to state's attorney
assistance)? I haven't a clue, but given that I've just read every case she cited and found that,
except for one exception, she misquoted every single case and, without exception, miscontrued
ds

the context of every single case, I'm not inclined to spend time digging through google to
determine what - if anything - those grand jury proceedings have in common with the grand jury
proceedings she's wishing would take place here.

Motion for Reconsideration wrote:

ien

Remedy Sought:
1. Therefore, permit the mail containing the documents including the court
petition, and held by the court be delivered to the grand jury informing them of
this action.

Why would the court permit something that, according to the cases cited by Petitioner, would be
an unlawful act, subjecting her to jail time?
Fr

Page 17
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Motion for Reconsideration:
Remedy Sought:...2. Therefore the Court reconsiders the decision of January 20,
2010, and allows the petitioner to testify before the Grand Jury permitting them to
decide the merits of her claim, or schedules a hearing to determine the
competence of the petitioner‟s evidence.

b.c
So - #1 was written in affirmative terms ("permit the mail ..."). #2 is written as a proposed order
("Court reconsiders ... allows ...).

Anyways ...

So, why would the court do that when the petition provides no factual or legal support indicating

tija
that the court could, within its discretion, override the state's attorney's decision not to present the
information?

And why would the court schedule a hearing to consider the competence of the plaintiff's
evidence when Illinois authority exists indicating that the court is NOT supposed to consider
sufficiency of evidence - that that role is given to the grand jury only? (Yeah, I know, she didn't
cite those cases. .... ... .... )

Motion for Reconsideration:

oli
Remedy Sought:...3. This petitioner should be permitted to testify before the
McHenry County Grand Jury, as is currently, duly and legally in session.
P
Hmm, maybe it's one question for format. This one is written not declaratively, and not as a
proposed order, but - rather - in advocacy form: the petition "should be permitted." ....

Anyways ...
of

So - did I miss a page or two of the brief? Where is the support for an argument that a private
citizen can testify on demand before a sitting grand jury? Didn't one of the cases she cited
involve a situation where the Illinois Supreme Court affirmed a state's attorney's "right" to refuse
to follow a court order to require certain witnesses to testify?

Motion for Reconsideration:

ds

Remedy Sought:...4. The Court should use its discretion over the Sitting Grand
Jury or appoint a Special Grand Jury, and permit the petitioner to testify before
them.

Ahhh, relief! Two consecutive sentences with the same basic form
ien

But, alas, she admits here that the decision to appoint a special grand jury is within the court's
DISCRETION. Thus, she just killed her prior argument that the court erred by failing to do so.

As for permitting her to testify ... see notes above. Where's the authority for that? It's not in
petitioner's motion here....
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Page 18
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Motion for Reconsideration:
Remedy Sought:...5. The Court should award other relief in law and equity as
they deem proper and as held forth in the U.S. and Illinois Constitutions.

Ah, I just knew it was too good to last. "The Court [singular] should award ... as they [plural]
deem proper..."

b.c
Oh well. Always good to end with a "whatever else you can do for me" request. Problem is
that this petition attempts to harness the criminal justice system, of which the grand jury is a part.
Ms. Meroni filed the motion and intends to go before Judge Prather, who currently is on rotation
to and sits on the criminal bench. "Other relief in law and equity" is a catch-all phrase used in
civil complaints as an add-on to the prayer for monetary damages.

tija
Damages and "other relief in law and equity" are not available in criminal cases. The court
cannot "award" anything to the criminal complainant, which is effectively what "Chalice" is.
Moreover, equity has no role whatever in criminal law. Criminal law is strictly statutory.

***

Motion for Reconsideration:

oli
9. The Grand Jury has never been informed of this court action involving them
and therefore without due process, denied knowledge touching their service. They
are the Defendants.
P
This statement is beyond obtuse. I think she's trying to say that (a) the grand jury
members are the defendants here; and (b) failing to provide them with Sharon's evidence
deprives them of their due process rights as defendants.
of

A further note on this point. Sometimes, I'm guilty of focusing on the trees. Here, I evaluated
the text - alone, without looking beyond. The fact is that, as pled, the McHenry County Grand
Jury members are *NOT* the defendants here. There ARE no defendants. Sharon Meroni
PETITIONED the Grand Jury in her Dec. 3 filing, and a review of the pleadings indicates that
there has been no change in parties or status. Her Motion to Reconsider also "PETITIONS" the
McHenry Country Grand Jury.
ds

In short, the Grand Jury members are *not* the defendants in this case. IF she intended that, she
needed to file a different kind of action.

Butterfly Bilderberg:
ien

This petition attempts to harness the criminal justice system, of which the grand jury is a
part. "Chalice" filed the motion and intends to go before Judge Prather, who currently is
on rotation to and sits on the criminal bench. "Other relief in law and equity" is a catch-
all phrase used in civil complaints as an add-on to the prayer for monetary damages.

Damages and "other relief in law and equity" are not available in criminal cases. The
Fr

Page 19
 om
court cannot "award" anything to the criminal complainant, which is effectively what
"Chalice" is. Moreover, equity has no role whatever in criminal law. Criminal law is
strictly statutory.

This (correct) analysis brought me back to reviewing the prior pleadings. The fact is that Meroni
apparently has no concept of the difference between

b.c
alleged Constitutional violations (not criminal/not subject to grand jury review),
alleged civil code violations (not criminal/not subject to grand jury review), and
alleged criminal violations (subject to grand jury review).
Additionally, she mixes up alleged violations of Federal Law (not subject to county grand jury
review) with alleged violations of state law (subject to country grand jury review ONLY if
criminal).

tija
Additionally, She also mixes up the rules applicable to federal grand juries with Illinois rules.

Her pleadings are ... in essence, one major mix up. Doing a complete line-by-line dissection of
the 100+ pages she's filed would be, imho, a bit pointless, but you can see this pattern just by
reviewing a few pages of the first petition.
oli
1. Meroni refers to "voter fraud." (e.g., Pet. at 1) Notably, she doesn't identify which portion of
the Illinois Election Code was violated. And, I've reviewed that code and the things about Obama
that Chalice complains about (sealing documents, etc.) is not a crime under the code.
Additionally violation of Constitutional rights is not a crime - it's a civil issue.
P
2. Meroni seeks an investigation of "all Criminal and Civil actions" (Dec. 3 Pet. at 1). But an
Illinois Grand Jury can only investigate crimes - not civil actions - that occur within their
jurisdiction.

3. Meroni seeks redress from damages from the voter fraud (Pet. at 1). But the proper forum to
of

seek damages is civil court - not a grand jury.

4. Meroni alleges "violation of Petitioner's rights." (Pet. at 3). But the proper forum for
addressing violation of "rights," constitutional or otherwise, is civil court - not a grand jury.

5. Meroni alleges that this "violation" of her rights "occurred in part from Federal corruption and
ds

misdeeds." (Pet. at 3). But an Illinois Grand Jury has no jurisdiction to investigate federal crimes
(or misdeeds).

6. Meroni alleges "severe deficiencies in the current law in securing her constitutional rights."
(Pet. at 3). But, the proper forum for modifying a law is the legislature, not the courts. (Court
ien

review is appropriate if the law actually VIOLATES a Constitutional right; but not to address an
allegation that the law doesn't sufficiently "secure" such rights. Least as I understand "the rules.")

I could go on and on and on and on - because practically every page of her various pleadings
contains similar ... uhm ... demonstrations of basic lack of understanding of these issues.
Fr

Page 20
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She says that she has standing based on her first amendment right to petition the grand
jury, even though her own cited cases show that the Illinois Supreme Court has expressly
held that the first amendment does not entitle an individual to communicate with a grand
jury;

She spends pages and pages discussing federal grand jury power, notwithstanding that

b.c
she is seeking to appear before a state grand jury, with different rules;

etc etc etc etc etc etc etc etc etc etc etc etc etc etc etc etc etc etc etc etc etc etc etc etc etc
etc etc etc etc etc etc etc etc etc etc etc etc etc etc etc etc etc etc etc etc etc etc etc etc etc
etc etc etc etc etc etc..............

tija
Clueless or deliberately obtuse?
Dunno.
What I do know is that the petitions are rife with these types of basic errors in law and logic.

***

To determine whether a crime has been committed during an election cycle, the appropriate
process is to oli
(1) Review the Election Code to determine which prohibited acts are criminal; and
(2) Review each prohibited act carrying a criminal penalty and determine whether you have
evidence that a violation of the provision has occurred.
P
Let's take that step by step ...

1. Review the Election Code to determine which prohibited acts are criminal.
As I stated before, there is a special section in the Illinois Election Code, listing out all the
election-related prohibitions, and identifying whether liability for violation is criminal or civil.
of

So - this is the place to start.

2. Review each prohibited act carrying a criminal penalty and determine whether you have
evidence that a violation of the provision has occurred.
Let's take an example: Voting more than once. Under Illinois law,
ds

Any person who, having voted once, knowingly on the same election day where
the ballot or machine lists any of the same candidates and issues listed on the
ballot or machine previously used for voting by that person, (a) files an
application to vote in the same or another polling place, or (b) accepts a ballot or
enters a voting machine (except to legally give assistance pursuant to the
ien

provisions of this Code), shall be guilty of a Class 3 felony; however, if a person

has delivered a ballot or ballots to an election authority as an absentee voter and
due to a change of circumstances is able to and does vote in the precinct of his
residence on election day, shall not be deemed to be in violation of this Code.

First - see the bolded text above that says a person who violates this provision is "shall be guilty
Fr

Page 21
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of a Class 3 felony"? That means that a violation of this provision is a crime. Ok. Good. We've
located a prohibition that carries a criminal penalty - i.e., a crime.

Now, what's the crime? Well. Back up a second. See the bolded "knowingly" above? Well, most
crimes have two fundamental elements*: mens rea and actus reus, which -- in "real people talk" -
- means mental state (mens rea) and action (actus reus). And every state's criminal code has a

b.c
section in which the various types of mens rea are specifically defined. So - to evaluate whether
the crime of voting more than once has been committed, you have to go find the statute defining
the term "knowingly."

Under Illinois' criminal code, "knowingly" is defined as follows:

tija
(a) [The person acts knowingly of the] nature or attendant circumstances of his or
her conduct, described by the statute defining the offense, when he or she is
consciously aware that his or her conduct is of that nature or that those
circumstances exist. Knowledge of a material fact includes awareness of the
substantial probability that the fact exists.

(b) [The person acts knowingly of the] result of his or her conduct, described by
oli
the statute defining the offense, when he or she is consciously aware that that
result is practically certain to be caused by his conduct.
***
When the law provides that acting knowingly suffices to establish an element of
an offense, that element also is established if a person acts intentionally.
P
Ok, what does "intentionally" mean?

"A person intends, or acts intentionally or with intent, to accomplish a result or

engage in conduct described by the statute defining the offense, when his
of

conscious objective or purpose is to accomplish that result or engage in that

conduct."

Ok ... So, what's all that mean with respect to voting more than once? Well, let's "diagram" the
provision:
ds

Any person who,

having voted once,
knowingly
on the same election day
where the ballot or machine lists any of the same candidates and
ien

issues listed on the ballot or machine previously used for voting by

that person,
(a) files an application to vote in the same or another
polling place, or
(b)
Fr

Page 22
 om
accepts a ballot or
enters a voting machine
(except to legally give assistance pursuant to the
provisions of this Code),
shall be guilty of a Class 3 felony;
however, if a person

b.c
has delivered a ballot or ballots to an election authority as an
absentee voter
and
due to a change of circumstances is
able to and
does vote in the precinct of his residence on election day,

tija
[s/he] shall not be deemed to be in violation of this Code.

Ok, so let's make up a hypo - a type of fact scenario that might lead to a finding of probable
cause by a grand jury that someone violated the prohibition against voting more than once.

oli
Jane Doe voted on November 4, 2008, at 8:00 am at the Dover
Elementary School, which was the polling place for her precinct. During a
3:00 pm call, Ms. Doe told her friend Mabel that she had already voted
that morning at 8:00 am. At 4:00 pm on Nov. 4, Ms. Doe went to the
Agave Elementary School, which was the polling place for the
P
neighboring precinct and, once there, she accepted another ballot (that
was the same ballot she'd used in the morning to vote over at Dover
Elementary School) and, thereafter, entered the voting booth alone.
of

Now, let's try to match up Ms. Doe's actions with the code provisions:

Any person who ... Jane Doe ...

having voted once ... voted on November 4, 2008, at 8:00 am at
the Dover Elementary School, which was the
polling place for her precinct.
ds

knowingly During a 3:00 pm call, Ms. Doe told her friend

Mabel that she had already voted that morning
at 8:00 am (indicating her knowledge of that
vote).
on the same election day At 4:00 pm on Nov. 4 ...
ien

where the ballot or machine lists any of the
same candidates and issues listed on the ballot
or machine previously used for voting by that
person
Fr
... when the same election ballot in use that
morning was still being used at the polling
places, ...

Page 23
 om
(a) files an application to vote in the same or ...
another polling place,
or (b) Ms. Doe went to the Agave Elementary
accepts a ballot or School, which was the polling place for the
enters a voting machine neighboring precinct and, once there, she

b.c
(except to legally give assistance accepted another ballot (that was the same
pursuant to the provisions of this Code) ballot she'd used in the morning to vote over at
Dover Elementary School).

Ok. Now, assuming that there is some competent evidence of each of these elements, and that the
"accuser' presented the evidence logically/in relation to the code provisions -- e.g., ....

tija
-- The 8 am vote (this evidence can likely be obtained from the precinct registration
books that the blue-haired ladies are always handling; and testimony from Mabel about
the 3 pm call (that would be admissible before the grand jury) ...

-- That Ms. Doe knew that she'd voted (testimony from Mabel - admissible before grand
jury) oli
-- That Ms. Doe went to another polling place (neighboring polling registration books
that the blue-haired ladies are always handling)

-- That Ms. Doe accepted a ballot and/or entered a voting booth alone (testimony from
P
someone who saw her do this at Agave Elementary School)

....one might be able to get a grand jury to consider whether a crime had been committed here.
of

***

I am not, and have never been, a criminal defense attorney or prosecutor, but I can still say with
confidence that this is the type of analysis that gets conducted by both types of attorneys in every
single criminal case -- and this is the type of analysis that the state's attorney conducts when
ds

presented with "evidence" of alleged crimes for submission to a grand jury.

Therefore,
IF a person seriously believed that an election-related crime had been committed, and
IF the person actually had information indicating that a crime had been committed, and
IF the person actually wanted to be taken seriously by the state's attorney, a court, and/or a grand
ien

jury,
THEN the person would undertake a logical, fact- and legally-based evaluation of any
complained-of actions and how such actions may constitute a crime. In other words, they'd
conduct the type of exercise outlined above - only with real facts.

In contrast, the Meroni pleadings are replete with obtuse references to some unidentified criminal
Fr

Page 24
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actions (there is no specific crime of "voter fraud" in the IL Election Code), but contains NO
citation to ANY criminal code whatsoever, and contains NO evidence or even allegations of any
actions that might constitute a crime. (And, as discussed above, the pleadings are also replete
with a whole bunch of "stuff" that's utterly irrelevant to grand jury proceedings.)

I can only conclude that:

b.c
She does not actually BELIEVE that an election-related crime had been committed;
and/or
She does not actually HAVE information/evidence indicating that any such crime has been
committed;
and/or
She does not actually WANT to be taken seriously by the state's attorney, the court, or the grand

tija
jury.

P oli
of
ds
ien
Fr

Page 25