CASE NO. COMMONWEALTH OF KENTUCKY JEFFERSON CIRCUIT COURT DIVISION 20" 1003398 GARRETT A. DEAN 6630 Sun Ray Drive Louisville, Kentucky 40272 PETITIONERS/MOVANTS and JEFF SOURT KATIE BROPHY 1705 Timber Trace Louisville, Kentucky 40214 and FILED, INCLERKS OFFIC DAUD IN CLERKS OFRCE LNICHOLSON, CLERK JUN 10 2029 eu GER —| DITRAN 5026 South Third Street Louisville, Kentucky 40214 By. v. VERIFIED PETITION TO DISQUALIFY CANDIDATE AND, MOTION FOR SUMMARY PROCEEDINGS CHARLES DAVID YATES RESPONDENT SERVE; Charles David Yates 8101 Bella Woods Drive Louisville, Kentucky 40214 and MICHAEL G. ADAMS, in his official capacity as KENTUCKY SECRETARY OF STATE SERVE: Hon. Daniel J. Cameron AND Hon. Michael G, Adams Kentucky Attorney General Kentucky Secretary of State 700 Capitol Avenue, Suite 118 700 Capitol Avenue, Suite 152 Frankfort, Kentucky 40601 Frankfort, Kentucky 40601 andSTATE BOARD OF ELECTIONS FOR THE COMMONWEALTH OF KENTUCKY SERVE: Jared Dearing AND Hon. Danie! J. Cameron State Board of Elections Kentucky Attorney General 140 Walnut Street 700 Capitol Avenue, Suite 118 Frankfort, Kentucky 40601 Frankfort, Kentucky 40601 and JEFFERSON COUNTY BOARD OF ELECTIONS SERVE: Hon Michael O’Connell AND _ Bobbie Holsclaw Jefferson County Attomey Jefferson County Clerk 600 West Jefferson Street, Suite 2086 527 West Jefferson Street Louisville, Kentucky 40202 Louisville, Kentucky 40202 NOTICE AND REt FO! ARING Please take notice that the undersigned is making the foregoing motion pursuant to Kentucky Revised Statues (KRS) 118.176(2) which mandates that Plaintifi/Movants’ motion be tried summarily and without delay, and requests a hearing on the matter as soon as this Honorable Court can make reasonable accommodations to hear this time-sensitive matter, as absentee voting has already begun and the primary election is fast approaching, on Tuesday, June 23, 2020. Due to the nature of the proceedings, Plaintiff/Movants respectfully request this Honorable Court exercise its discretionary authority pursuant to Kentucky Supreme Court ‘Administrative Order 2020-43(1) to allow the physical attendance of any necessary persons who wish to be present in-person and compel the physical presence of Respondent, CHARLES DAVID YATES, at said hearing. INTRODUCTION Come the Petitioner/Movants, GARRETT A. DEAN, KATIE BROPHY and DI TRAN, individually and jointly by Counsel, pursuant to Kentucky Revised Statues (KRS) Page 2 of 24118.176(2), and for their Verified Petition and Motion for Summary Proceedings seek a determination that the Respondent, CHARLES DAVID YATES, is not a bona fide candidate for the office of State Senator for the 37th Senatorial District and an Order disqualifying him as a candidate and officially strike his name from the ballot. JURISDICTION AND VENUE 1, Pursuant to KRS 118.176(2), this Honorable Court has jurisdiction over a challenge to the bona fides of a candidate for public office; and venue lies in the “judicial circuit in which the candidate whose bona fides is questioned resides.” Id. 2. Petitioner/Movant, GARRETT DEAN, is a resident of the 37th Senatorial District, and a registered voter residing in said Senatorial District, and is thus eligible to vote in the upcoming June 23, 2020 primary election and the November 06, 2020 general election; said Petitioner/Movant resides at 6630 Sun Ray Drive, Louisville, Jefferson County, Kentucky 40272; and has filed as a candidate for State Senator for the 37th Senatorial District for the primary election to be held on June 23, 2020. 3. Petitioner/Movant, KATIE BROPHY, is a resident of the 37th Senatorial District, and a registered voter residing in said Senatorial District, and is thus eligible to vote in the upcoming June 23, 2020 primary election and the November 06, 2020 general election; said Petitioner/Movant resides at 1705 Timber Trace, Louisville, Jefferson County, Kentucky 40214; and has filed as a candidate for State Senator for the 37th Senatorial District for the primary election to be held on June 23, 2020. 4, Petitioner/Movant, DI TRAN, is a resident of the 37th Senatorial District, and a registered voter residing in said Senatorial District and is thus, eligible to vote in the upcoming June 23, 2020 primary election and the November 06, 2020 general election; said Page 3 of 24Petitioner/Movant resides at 5026 South Third Street, Louisville, Jefferson County, Kentucky 40214; and has filed as a candidate for State Senator for the 37th Senatorial District for the primary election to be held on June 23, 2020. 5. Petitioner/Movants are qualified to challenge the candidacy of a candidate pursuant to KRS 118.176 and KRS 116.055. 6. Respondent, CHARLES DAVID YATES, is a resident of Jefferson County in the Commonwealth of Kentucky, and has filed as a candidate for State Senator for the 37th Senatorial District for the primary election to be held on June 23, 2020; and to the Petitioner/Movants’ best knowledge and belief, said Respondent resides at 8101 Bella Woods Drive Louisville, Jefferson County, Kentucky 40214. 7. Co-Respondent, MICHAEL G. ADAMS, is the SECRETARY OF STATE for the Commonwealth of Kentucky and serves as Kentucky's Chief Elections Official; and the Office of the Secretary of State is constitutionally and statutorily charged with the lawful responsibility of supervising the conduct of state elections in the Commonwealth of Kentucky. 8 Co-Respondent, STATE BOARD OF ELECTIONS FOR THE COMMONWEALTH OF KENTUCKY, ensures Kentucky's compliance with state and federal election law; and is charged with specific duties and responsibilities for the conduct of elections for state offices, including State Senators, in the Commonwealth of Kentucky. 9. Co-Respondent, JEFFERSON COUNTY BOARD OF ELECTIONS, is charged with the responsibility of supervising the conduct of elections within the boundaries of Louisville, Jefferson County, Kentucky, including, but not limited to the printing of the ballots for the upcoming June 23, 2020 primary election and the November 06, 2020 general election, canvassing the votes at the primary and general elections; and certifies election day votes to Co- Page 4 of 24Respondent, MICHAEL G. ADAMS, in his official capacity as SECRETARY OF STATE. CAUSE OF ACTION AND MOTION TO DISQUALIFY CHARLES DAVID YATES AS A CANDIDATE FOR KENTUCKY STATE SENATOR FOR THE 37TH SENATORIAL DISTRICT 10. On or about December 17, 2019, Respondent, CHARLES DAVID YATES (hereinafter, “YATES") filed his handwritten “Notification and Declaration” of candidacy in the Office of the Secretary of State of the Commonwealth of Kentucky for the office of State Senator, 37th Senatorial District, attached hereto as Ex1 A. See also, Exhibit B, Press Release dated December 17, 2019. 11. Inhis Notification and Declaration, Respondent YATES, swore under oath that he met “all the statutory and constitutional qualifications . . . and that [he] will not knowingly violate any election law or any law relating to corrupt and fraudulent practice in campaigns or elections in this state, and if finally elected [he] will qualify for the office” pursuant to KRS 118.125(2)(a).' See Exhibit A. 12, Upon filing of his Notification and Declaration, Alison Lundergan Grimes, certified the filing papers of the Respondent YATES, while acting in her official capacity as Secretary of State on December 17, 2019, and it became incumbent upon the Secretary of State to have the candidate’s name printed on the ballot according to the provisions of KRS 118.129. ' *For the purpose of having my name placed on the official primary election ballot as a candidate for nomination by the —-- Party, I, ---- (name in full as desired on the ballot as provided in KRS 118.129), do solemnly swear that my residence address is ---- (street, route, highway, city if applicable, county, state, and zip code), that my mailing address, if different, is - ~~ (post office address), and that I am a registered —--- (party) voter in ------ precinct; that I believe in the principles of the ------ Party, and intend to support its principles and policies; that I meet all the statutory and constitutional qualifications for the office which I am seeking; that if nominated as a candidate of such party at the ensuing election I will accept the nomination and not withdraw for reasons other than those stated in KRS 118.105(3); that I will not knowingly violate any election law or any law relating to corrupt and fraudulent practice in campaigns or elections in this state, and if finally elected I will qualify for the office." KRS 118.125(2\(a). Page 5 of 24See KRS 118.165; KRS 118.125, 13. After the Co-Respondent, MICHAEL G. ADAMS, took office as the SECRETARY OF STATE for the Commonwealth of Kentucky on January 6, 2020, he then became responsible for the final certification of candidates’ names to the County Clerks to appear on the upcoming 2020 primary election ballot by January 20, 2020, the second Monday following the candidate filing deadline, pursuant to KRS 118.215(1)(a). 14, The certification Respondent YATES’ name, as he desired it to appear on the ballot, should not have been issued to Co-Respondent, JEFFERSON COUNTY BOARD OF ELECTIONS, because Respondent YATES committed a clear violation of election law when he falsely claimed his name to be “David Yates,” while under oath, in direct violation of KRS 118.129. Therefore, for the reasons set forth in detail below, Respondent, CHARLES DAVID YATES! Notification and later Certification is invalid as a matter of law and Respondent must be disqualified as he is not a bona fide candidate. 15. Pursuant to KRS 118.176(1), “{aJn action regarding the bona fides of any candidate seeking nomination or election in a primary...may be commenced at any time prior to the regular election.” In the present case, all three (3) opposing candidates have joined together in unity to ask this Honorable Court to find that Respondent, CHARLES DAVID YATES, is not a bona fide? candidate as a matter of law, disqualify him as a candidate in the upcoming primary election; enter an Order directing the Co-Respondent, STATE BOARD OF ELECTIONS FOR THE COMMONWEALTH OF KENTUCKY, and Co-Respondent, JEFFERSON COUNTY BOARD OF ELECTIONS, that the name “David Yates” shall be bona fides (boh-no fi-deez) n. [Latin] (1845) 1. good faith. 2. Roman law. The standard of conduct expected of a reasonable person, esp. in making contracts and similar actions; acting without fraudulent intent or malice. BONA FIDES, Black's Law Dictionary (11th ed. 2019). Page 6 of 24stricken from the written designation of election officers filed with the Board of Elections for the 2020 Primary and General Elections pursuant to KRS 118.176(4) prior to election day on June 23, 2020; and directing MICHAEL G. ADAMS, in his official capacity as KENTUCKY SECRETARY OF STATE to notify the Jefferson County Clerk to ensure that notice is provided to the appropriate precinct election officers who shall see that the notice is conspicuously displayed at the polling place advising votes of the change, and that the votes for Respondent YATES shall not be tabulated or recorded pursuant to KRS 118.212. I. Respondent, CHARLES DAVID YATES, is not a bona fide candidate and must be disqualified for candidacy in the Sune 23, 2020 primary Senatorial District 37 election for his intentional failure to use any form of his first or given name or initial as a matter of law. 16. Respondent, CHARLES DAVID YATES, failed to comply with KRS 118.129(4), which governs the spelling and form of a candidate's name on a ballot when he listed his name to be printed on the 2020 primary election ballot as “David Yates.” See Exhibit As Exhibit C, Candidate Information Packet provided by the Secretary of State. This act was mendaciously taken to gain an unfair advantage on the ballot, and in violation of, Plaintifi/Movants rights under the United States and Kentucky Constitutions, which guarantees the right of freedom for all men to be free from special privileges under the law, the right to equal treatment and specifically requires that elections shall be “free and equal.” See Ferguson v. Rohde, 449 8.W.2d 758, 760 (Ky. Ct. App. 1970). 17. Respondent YATES admittedly acknowledged his legal name to be “CHARLES DAVID YATES,” on the very same affidavit, yet he failed to follow the specific statutory directive as to how a candidate’ full name must be listed on the ballot. Pursuant to KRS 118.129(4), “[e]he candidate's name shall always appear in the following form: first or given name or initial; middle name or names or initials, if desired by the candidate; nickname if Page 7 of 24desired by the candidate; and last or surname in full.” (emphasis added), The statute is explicit and unambiguous, and to require anything less than the literal application and strict, compliance with one of the many options given to each candidate on how to spell and format their name on the ballot would clearly be converse to the legislative intention meant to prevent fraud upon voters by way of a falsification of information provided to them on their ballots. 18, “(T]he use of the word "shall" with reference to some requirements ... is usually indicative that it is mandatory, but it will not be so regarded if the legislative intention appears otherwise.” Stoecklin v. Fennell, 526 S.W.3d 104, 107 (Ky. Ct. App. 2017) (quoting Skaggs v. Fife, 98 S.W.2d 884 (Ky. 1936). Kentucky Courts have historically required strict compliance with election statutes. In Thomas v. Lyons, the Court rejected a “substantial compliance” argument on grounds that such would amount to an unauthorized amendment of the statute. Thomas v. Lyons, 586 S.W.24 711 (Ky. 1979). In Morris v. Jefferson County Clerk, the Kentucky Court similarly rejected the of concept of substantial compliance in the context of election laws, and invalidated the candidacy. Morris v. Jefferson County Clerk, 729 S.W.2d 444 (Ky. 1987). See Barnard v. Stone , 933 S.W.2d 394, 395-96 (Ky.1996) (emphasizing that strong public policy demands candidate integrity and strict adherence to election laws). In Barnard v. Stone, a case where a candidate had only obtained 398 valid signatures, as opposed to the required 400 signatures required for a petition of nomination for a representative in Congress, the Kentucky Supreme Court invalidated his candidacy and ordered his name stricken from the ballot. The Court also gave guidance on the procedures to follow when a candidate’s name cannot be removed from the ballot due to impracticability, as laid out in KRS 118.212(5). Barnard v. Stone, 933 S.W.2d 394, 396 (Ky. 1996); see also Stoecklin v, Fennell, 526 S.W.3d 104, 106 (Ky. Ct. App. 2017); Skaggs v. Fyffe, 98 S.W.2d 884 (Ky. 1936). Page 8 of 2419. The legislature clearly intended the name a candidate places on the ballot to be a simple issue, as they enacted an entire statute directly addressing the legality of a candidate's name for political elections. The law plainly states the first or given name, or initial should “always appear,” and, as a matter of public policy, there are numerous reasons why a candidate's first name or initial should be listed, so as to not undermine the public’s confidence in election process by presenting them with incomplete and inaccurate information. By enacting the specific spelling and form of name statute, the General Assembly clearly intended to preserve the concept of election transparency, free from corrupt or deceptive practices, and ensure the confidence and trust of the general public in the Commonwealth's electoral system — just as they provided a statutory mechanism and remedy for qualified individuals to challenge the bona fides of a candidate in Court in an effort to hold candidates for public office accountable for any failures to adhere to the proscribed, detailed laws. 20. If Respondent YATES is found to have satisfied the requirements, as a matter of law, to be a bona fide candidate and allowed to proceed as a candidate in the upcoming primary, the effect would be tantamount to creating a special exception that would deviate from years of Kentucky election law precedent and further undermine the public trust in what many individuals unfortunately already believe to be a corrupt and dishonest political system. I. Respondent, MICHAEL G. ADAMS, in his official capacity as Secretary of State, abused his discretion in certifying Respondent's name as “David Yates” to the Jefferson County Clerk for inclusion on the baltot for the 2020 primary election, thereby depriving Petitioners/Movants of the rights guaranteed to them under the United States and Kentucky Constitutions. 21. Section 2 of the Kentucky Constitution requires due process to be given at a level determined by the interests at stake through the accuracy of fact finding and legal determinations. By certifying the name as “David Yates” Co-Respondent KENTUCKY, Page 9 of 24SECRETARY OF STATE effectively allowed Respondent YATES to be the one exception to the statutory requirements to become a bona fide candidate for political office — an act which directly infringes upon the Plaintiff/Movants’ right to free and equal elections, as it is abundantly clear that Respondent YATES deliberately failed to designate his first or given name or initial for printing on the ballot in an attempt to gain a political advantage in the primary election. 22. The Kentucky Supreme Court “is deeply respectful of the electoral process and its very fundamental role in the functioning of a true democracy....we cannot ignore that an election may only be considered legitimate when the statutory procedures governing the process are followed and constitutional mandates are respected. When a candidate who is constitutionally unqualified to take office nonetheless presents him or herself as a qualified candidate eligible for election and office, that candidate has not only misled the electorate but also engaged it in a futile endeavor.” Stephenson v. Woodward, 182 S.W.3d 162, 174 (Ky. 2005). 23. The ballots have already been printed, absentee voting has already begun, and we are mere days away from the primary election day. The ballots given to Democratic voters in Senate District 37 clearly show that only “David Yates” appears, without any designation of Respondent YATES’ first or given name of “Charles” or first initial “C.” See Exhibit D, Sample Ballot. 24, “The only purpose the designation might have served would be to help in locating the affiants' places of residence, or to find their names on the registration records, ” Fletcher v. Wilson, 500 S.W.2d 601, 604 (Ky. Ct. App. 1973) (finding that a failure to designate the voting precinct number on the Notification and Declaration form in a county-wide election, although not fatal to the candidacy, would have been helpful for voters in locating the affiants’ places of residence, or to find their names on the registration records). However, the Court specifically Page 10 of 24relied on the fact that “Jessamine is a relatively small county, with a total population of only 17,430,” and in such a small county that help [providing the public with the designation of the candidate’s precinct of residence] was not an urgent matter.” Fletcher v. Wilson, 500 S.W.2d 601, 604 (Ky. Ct. App. 1973). However, even that case can be distinguished from the facts presently before the Court, as the Kentucky State Senate District 37 alone has a population of roughly 120,052, ? with 43,956 of those individuals being registered voters eligible to vote in the 2020 Democratic Primary Election for the 37th State Senatorial District, and the position in question in that case was a county judge seat — not a State Senate Position. 25. Inthe instant case, Respondent YATES failed to include his first or given name, or initial to be printed on the ballot, making it nearly impossible for the common voter to find out his places of residence or name on registration records. Fraudulently concealing any indicator of his first name is synonymous with providing a voter with misleading information - a form of Voter suppression that is a clear violation of Kentucky's election laws. 26. A clear demonstration of the effect of this failure can be seen in searching for “David Yates” on the Jefferson County Property Value Administrator's website. Instead, a voter ‘would have to know to look for the candidate filings on the website for the Secretary of State,* then go back to the PVA website to search his exact address ~ only to find the residence registered to a C. David Yates and Jill M. Yates. See Exhibit E, Deed to Respondent YATES’ Residence. > hitps://staisticalatlas.com/state-upper-legislative-district/Kentucky/State-Senate-District- 37/Overview. * Candidate filings are public record and can be found at http://web.sos.ky.gov/elections/candidatefilings/statewide/. Page 11 of 2427. Taken one step further, if voters were to assume “David” is Respondent YATES’ first name, then a voter would not be able to learn that the Respondent has a business called “C David Yates LLC.” See Exhibit F, Secretary of State Summary for C DAVID YATES LLC (listing “Charles David Yates” as the Manager, Organizer and Registered Agent). Voters would then be unable to find public records related to the Respondent's recent purchase three of (3) residential properties in Jefferson County, Kentucky on January 14, 2020, which may or may not be viewed as questionable in the eyes of voters, as Respondent YATES had declared his candidacy for State Senate less than a month prior. See Exhibit G, Exhibit H, and Exhibit I, Deeds for Property Transfers.* 28. Conversely, a mere search of “David Yates” on the Secretary of State’s Business Organization page only returns “DAVI ‘ORNEY, PLLC,” a com to provide chiropractic and related services,” that is managed by Respondent YATES and his current wife, Lindsey. See Exhibit J, Secretary of State Summary for DAVID YATES, ATTORNEY, PLLC (listing “David Yates” as the Organizer and Registered Agent and “Charles David Yates” as a Manager) and Exhibit K, the company’s Articles of Organization. Moreover, even a search of the name of his law firm as listed on both his firm website and his campaign website, “Law Offices of David Yates, PLLC,” undeniably shows the firm’s name is not actually registered as stated. See Exhibit L, davidyateslaw.com; Exhibit M., voteyates.com website; Voters have an interest in full candidate disclosure, and some may find the fact that these three (3) real estate purchases were made one (1) day affer the Secretary of State issued a Reinstatement Certificate of Existence for C DAVID YATES, LLC on January 13, 2020 to be of interest. See Exhibit N, Certificate of Existence. Page 12 of 24Exhibit O, Secretary of State Website Search (showing no business registered as “Law Offices of David Yates, PLLC”).® 29. Co-Respondent, KENTUCKY SECRETARY OF STATE, should have never certified Respondent YATES’ name, as he desired it to be written on the ballot, on his ‘Nomination papers nor to the Co-Respondent, JEFFERSON COUNTY BOARD OF ELECTIONS, for publication on the ballot in the upcoming primary election. His Nomination Papers were deficient on their face, as Respondent distinctly lists his correct, given name of CHARLES DAVID YATES at the top of the form, and then swore, under oath, that his “name in full” was “David Yates” and then signed said statement, under oath and the penalty of perjury, as “David Yate: 30. The blatant disregard for election law on the part of the Respondent YATES, raises concems as to the motivations behind his actions, and the Court should find these to be farther compelling reasons to find the Respondent is not a bona fide candidate as a matter of law. I. Respondent, CHARLES DAVID YATES, knowingly falsified his name to be listed on the ballot under oath by affidavit in order to gain an advantage on the ballot in violation of KRS 118.129, and he is therefore not a bona fide candidate as a mater of law. 31. As amatter of well settled election law, the Kentucky Revised Statutes dictate the specific procedure in which an individual can place their name on a ballot as a candidate. Adherence to those statutes must be strictly construed in order to meet the goals and objectives of the General Assembly and the conduct of an orderly election. “David Yates” does not only © A Lawyer search on the Kentucky Bar Association website has the Respondent’s name correctly listed as “Charles David Yates” with the same office address as listed on his website, but notably this time he lists his official business name as “David Yates Law.” See Exhi Kentucky Bar Asso Page 13 of 24misrepresent Respondent YATES’ legal or given name, but it completely ignores that Respondent does in fact have a given first name ~ CHARLES. 32. Pursuant to KRS 118.129(4), “All names shall be in substantially the following form: John Lincoln "Jack" Doe; or J. Lincoln "Jack" Doe; or J. L. "Jack" Doe Jr.; or any of the above combinations without the intervening nickname.” Respondent YATES could have listed his desired name in a multitude of ways: Charles David Yates; C. David Yates; C. “David” Yates; Charles D. Yates; C. Yates; Charles Yates; or C. D. Yates. 33. Arreview of Respondent YATES" social media only further supports the assertion. that his intentional act of failing to write his “name in full as desired on ballot as provided in KRS 118.129” and linking the C. or “Charles” to his name was a deliberate act and improper attempt to gain an advantage on the ballot. 34. Respondent YATES has run for political office numerous times in the past, and Plaintiff/Movant’s concede that he is a public figure commonly known as “David Yates” in the local community. Therefore, if he would have used any form of his first or given name, it might have raised some unwanted questions, undesired candidate research or drawn unintended attention to his campaign. 35. Additionally, he would not have been able to re-use the same social media accounts that were already set up with roughly two-thousand (2,000) followers from his campaign for re-election to Louisville Metro Council in November 2018. See Exhibit Q, Vote David Yates for KY Senate Facebook Page. In fact, Respondent YATES has a history of changing the name of his Facebook page for political purposes. See Exhibit R, showing that the page was named “David Yates” upon creation on June 15, 2009, then changed to “Vote David ‘Yates for Metro Council” on June 12, 2018, and finally to “Vote David Yates for KY State Page 14 of 24Senate” on December 17, 2019. In fact, a post from June 17, 2009, almost eleven years ago, distinctly shows an image used during Respondent YATES’ 25th Metro Council District campaign using the same website that he currently uses as his Senate campaign website. While there is no law that the Petitioner/Movants are aware of that states he cannot re-use domains, Facebook Pages, accounts on Twitter or Instagram, etc., it would stand to reason that re-use of the same for re-election for the same position, See Exhibit S, is a much different act than using existing, well-established campaign accounts in the name of “David Yates” that have a history spanning over ten (10) years, as a platform to gain an advantage on the ballot. See generally, Exhibit T; Exhibit U; and Exhibit V, various posts made on Respondent YATES’ Facebook campaign Page. 36. While Plaintiff/Movants can only assume that he likely committed these same violations of election laws with regards to his name in the past, due to continued failure to use his first and given name of “Charles” during official campaigns, it is of paramount importance that Respondent YATES is held accountable for his failure to follow the clear statutory authority in this race ~ a State Senate race, The fact that a candidate for a State Senate election would make such a blatant error rises to the level of material misrepresentation of his identity to voters, and raises significant concems as to the motivations behind the Respondent's clear intent to deceive the public, or at least deny them a meaningful opportunity to fully research the candidates on the ballot, and place the Plaintiff7Movant’s at a political disadvantage during the primary election. 37. Prior Secretary of State, Alison Lundergan Grimes, acknowledged the great responsibility placed on the Secretary of State in terms of certifying election ballots, stating: “One of [the] most solemn duties as Secretary of State is to protect the sanctity of the Page 15 of 24Commonwealth's election ballots, and to safeguard Kentucky's election instruments from being manipulated for political gamesmanship.” See Exhibit W, Press Release from Alison Lundergan Grimes, February 8, 2019. 38. Respondent YATES swore, under oath, that he would not “knowingly violate any election law or any law relating to corrupt and fraudulent practice in campaigns or elections;” and the Plaintiff/Movants implore this Honorable Court to find that Respondent YATES is not a bona fide candidate pursuant to KRS 118.129 and disqualify Respondent YATES as a candidate in the 2020 primary election. 39. Even for argument’s sake, if one were to believe that “David” qualifies as a “nickname” and he was therefore exempt pursuant to KRS 118.129(2), Respondent YATES shall still bear the burden of proving “David” was a bona fide nickname in accordance with the proscribed statutory procedures’ and even then his name would still not comply with the statutory formatting requirements of KRS 118.129(3) which mandates “[a] nickname shall always appear set off in quotation marks and immediately before the last name. Periods shall follow all abbreviations or initials. Additional qualifiers following the last name, such as "J" or “IIT” shall not be separated from the last name by a comma and shall be followed by a period.* 40. A cursory review of the naming section of Black’s Law Dictionary reveals that 7 A candidate's nickname which is found to be, in the discretion of the Secretary of State or the county clerk, as appropriate, a title, rank, degree, job description, or spurious phrase shall be placed on the ballot only if tis the candidate's bona fide nickname, generally used by acquaintances of the candidate in the county of residence to refer to the candidate, and if the nickname is acknowledged, by affidavit, under oath, by five (5) residents of the county in which the candidate resides, to be a bona fide nickname. The candidate shall also acknowledge, by affidavit under oath, that this is his bona fide nickname and is not being used to gain an advantage on the ballot. KRS 118.125(2). * Examples of elected officials who ran for office in the Commonwealth of Kentucky using bona fide nicknames include Eugenia Crittenden Blackburn “Crit” Luallen former Lieutenant ‘Governor, and Albert Benjamin “Happy” Chandler, former Governor. Page 16 of 24“David Yates” may arguably be an alias, but it is certainly not a nickname within the meaning of the statute: 41. DEFINITIONS given name. (16c) An individual's name or names given at birth, as distinguished from a family name. — Also termed personal name; (in the Western tradition) first ‘name; (in the Christian tradition) Christian name. Cf. surname. NAME, Black's Law Dictionary (11th ed. 2019). legal name. (17) A person's full name as recognized in law. + A legal name is usu. acquired at birth or through a court order. There are no rules governing a legal name's length or constitution; it may be a single name (e.g., Prince) or include words not generally used in human names (¢.g., Moon Unit). NAME, Black's Law Dictionary (11th ed. 2019). name n. (bef. 12c) A word or phrase identifying or designating a person or thing and distinguishing that person or thing from others. NAME, Black's Law Dictionary (11th ed. 2019). As opposed to: nickname 7. (15c) 1. A shortened version of a person's name <“Bill” is William's nickname>. 2, A descriptive or alternative name, in addition to or instead of the actual name; specif., an informal name given to someone by friends, family, coworkers, etc., often to suggest what the person looks like or has done . NICKNAME, Black's Law Dictionary (Ith ed. 2019). As opposed to: alias n. (17¢) 1. An assumed or additional name that a person has used or is known by. — Also termed assumed name; fictitious name. Cf. pseudonym. ALIAS, Black's Law Dictionary (11th ed. 2019) (emphasis added). Further supporting that Respondent YATES knowingly committed an intentional act to fraudulently conceal his first or given name in an attempt to gain favor on the ballot, include his handwritten given or first name of, CHARLES DAVID YATES, which appears on his Notification and Declaration in three (3) different places, but for the one place it specifically directs the candidate to write, “Name of candidate in full as desired on the ballot as provided in KRS 118.129” and his signature which reflects the use of his middle name, “David Yates.” Page 17 of 2442, “Disqualification” is defined as (1) Something that incapacitates, disables, or ‘makes one ineligible; esp., a bias or conflict of interest that prevents a judge or juror from impartially hearing a case, or that prevents a lawyer from representing a party; (2) The act of making ineligible; the quality, state, or condition of being ineligible. Cf. recusal; (3) A punishment that may be imposed after an official has been impeached and removed from office, precluding the official from holding another office or enjoying any benefits of having held office.”® Under these definitions, and the “usual, ordinary, and everyday meaning,” it appears that disqualification can be a prevailing condition or circumstance or it can be a discrete act or event, depending on the context in which the term is used. By virtue of the statute and our decisions with respect to statutory construction, and by virtue of the definitions quoted hereinabove, we have no doubt that a judicial decision declaring a candidate not bona fide may bbe embraced in the meaning of “disqualification” where that term appears in a statute, Heleringer v. Brown, 104 S.W.3d 397, 401 (Ky. 2003) (emphasis added). 43. Transparency and accountability in the democratic election process and political system are important to voters, and by not providing voters with a candidate’s correct name, through a material misrepresentation of one’s first name or intentional failure to use a first name on the ballot, voters are misled to rely upon false information, and left unable to adequately research their options prior to casting their vote, should they choose to do so. In fact, the Secretary of State’s FAQ section for individuals interested in becoming candidates specifically lists “The name the candidate wishes to appear on the ballot does not conform to the statutory ° DISQUALIFICATION, Black's Law Dictionary (11th ed. 2019). Page 18 of 24requirements of KRS 118.129” as one of “the most common errors made by candidates seeking ballot access.” (emphasis added). 44. Respondent YATES has a concerning, repeated and ongoing pattern of intentional acts relating to the usage of his “name,” whether for personal or business purposes — or in this case blatant disregard for election law for unfair political advantage — and the Court should find this to be compelling and persuasive authority to make the determination that he not a bona fide candidate as a matter of law. 45. To allow Respondent YATES to proceed as a candidate under the name “David Yates” would amount to an unauthorized amendment to the statute — a statute the legislature enacted specifically to address the issue at hand. If one candidate is allowed to proceed to the primary election, having committed a clear violation of the law, not only does this create a special exception for Respondent YATES, but it undermines the integrity of the entire democratic process. All candidates for public office should be held to the same standard, the election laws should apply to each candidate equally, and Respondent YATES must be held accountable for his failure to follow the terms that are explicitly laid out in the statute. 46. Section 32 of the Kentucky Constitution — Qualifications of Senators and Representatives — states in relevant part*... No person shall be a Senator who, at the time of his election, is not a citizen of Kentucky, has not attained the age of thirty years, and has not resided in this State six years next preceding his election, and the last year thereof in the district for which he may be chosen.” 47. _ Respondent, CHARLES DAVID YATES, cannot be a bona fide candidate as a matter of law, because “David Yates,” as he represents himself to voters on the ballot, is not in "See https://www.sos.ky.gov/elections/BecomingACandidate/Pages/F AQs.aspx. Page 19 of 24fact a real person and does not exist; and pethaps a fact of even more importance, according to the Jefferson County Voter Records, “David Yates” is not a registered voter in the of the 37th Senatorial District, and therefore Respondent YATES he must be disqualified as a candidate in the 2020 primary election. WHEREFORE, Plaintifi/Movants, respectfully move this Honorable Court for the following relief: 1. That this Honorable Court find and declare Respondent, CHARLES DAVID YATES, is not a bona fide candidate for the office of State Senator for the 37th Senatorial District in Louisville, Jefferson County, Kentucky. 2. That a summary proceeding be scheduled and held “without delay” on Petitioner/Movants’ motion herein as required by KRS 118.176(2); 3. That this Honorable Court allow the physical attendance of any necessary persons who wish to be present in-person pursuant to Kentucky Supreme Court Administrative Order 2020-43(1). 4, That a record of the aforesaid proceeding be maintained and “officially reported” as set out in KRS 118.176(2); 5. That pursuant to KRS 118.176(4), this Honorable Court “certify the fact to the Co-Respondent State and Local Boards of Election” that Respondent, CHARLES DAVID YATES, name shall be officially stricken from the written designation of election officers filed with the Boards of Election and/or stricken in a similar fashion from all printed ballots to be used in the upcoming June 23, 2020 election, including all absentee ballots mailed out from the date of said certification of disqualification, as maintained and supervised by Co-Respondent MICHAEL G. ADAMS, in his official capacity as Kentucky Secretary of State, and Co- Page 20 of 24Respondent STATE BOARD OF ELECTIONS FOR THE COMMONWEALTH OF KENTUCKY. and by Co-Respondent JEFFERSON COUNTY BOARD OF ELECTIONS and any and all other relevant bodies/boards/agencies, commissions and/or authorities; 6. That pursuant to KRS 118.212 this Court directs Co-Respondent MICHAEL G. ADAMS, in his official capacity as Kentucky Secretary of State, and Co-Respondent STATE BOARD OF ELECTIONS FOR THE COMMONWEALTH OF KENTUCKY, and by Co- Respondent JEFFERSON COUNTY BOARD OF ELECTIONS that they shall provide a notice to the precinct election officers who shall see that the notice is conspicuously displayed at the polling place advising voters of the change, and that any and all votes for Respondent, CHARLES DAVID YATES, shall not be tabulated or recorded. 7. For leave to amend their Verified Petition to Disqualify Candidate and Motion for Summary Proceedings; and 8. Forany and all other rel including, but not limited to, injunctive relief pursuant to CR 65.04, to which the Petitioner/ Movants her: may appear entitled. Respectfully Submitted, KAITLIN SMITH DEAN Law Office of Kaitlin Smith Dean. 624 West Main Street, Suite 600 Louisville, Kentucky 40202 Phone: (502) 694-0513 Cell: (316) 409-5163 Fax: (502) 324-4604 kaitlin@ksdeanlaw.com Counsel for Petitioner/Movants Page 21 of 24VERIFICATION BY GARRETT A. DEAN 1, GARRETT A. DEAN, the undersigned, declare under penalty of perjury and the laws of the United States and the Commonwealth of Kentucky that I am the Petitioner/Movant in the above-styled cause of action, and that I have read the foregoing Petition/Motion in its entirety, and that all the statements contained therein the said foregoing Petition/Motion are true and Correct to the best of my knowledge and belief. Sanne Baur [O June 2020 GARRETT A. DEAN, PETITIONER/MOVANT DATE COMMONWEALTH OF KENTUCKY) )ss COUNTY OF JEFFERSON Subscribed and swom to before me on this 10th day of June, 2020, by GARRETT A. DEAN, the Petitioner/Movant herein, who did sign and acknowledge same to be his free and voluntary act. ARY PUBLIC, STATE AT LARGE, KY My commission expires: \\= | - AQ, gas las YY NOTARY ID # Page 22 of 24VERIFICATION BY KATIE BROPHY 1, KATIE BROPHY, the undersigned, declare under penalty of perjury and the laws of the United States and the Commonwealth of Kentucky that I am the Petitioner/Movant in the above-styled cause of action, and that I have read the foregoing Petition/Motion in its entirety, and that all the statements contained therein the said foregoing Petition/Motion are true and correct to the best of my knowledge and belief. COMMONWEALTH OF KENTUCKY) )ss COUNTY OF JEFFERSON ‘Subscribed and sworn to before me on this 10th day of June, 2020, by KATIE BROPHY, the Petitioner/Movant herein, who did sign and acknowledge same to be her free and voluntary act. TARY PUBLIC, STATE AT LARGE, KY My commission expires: -\ ~ KY NOTARY ID# Page 23 of 24VERIFICATION BY DI TRAN |, DITRAN, the undersigned, declare under penalty of perjury and the laws of the United States and the Commonwealth of Kentucky that I am the Petitioner/Movant in the above-styled cause of action, and that I have read the foregoing Petition/Motion in its entirety, and that all the ‘Statements contained therein the said foregoing Petition/Motion are true and correct to the best of my know@™g@ pnd belies. LLP 2 30 DI FEL TTIONERIOVANT DATE COMMONWEALTH OF KENTUCKY ) )ss COUNTY OF JEFFERSON ) Subscribed and sworn to before me ‘on this 10th day of June, 2020, by DI TRAN, the Petitioner/Movant hereij a lid sign and acknowledge same to be his free and voluntary act. My commission ex) Page 24 of 24office ot_Stute Sevabae Rasa "Oren soy To. cokers of ‘SECRETARY OF STATE I (County Clerk of Sata as caso ay Bo) ‘COMMO} ‘OF KENTUCKY For the purpose of having my name placed on the official ‘nomination by the Temaccetic Party, |, Navid Nate —EEE \ ati of eanaitate Ul dostod on bala as provided WARS 118129) do solemnly swear that my residenceis__G1O| Bella Weds De. (estonia Adc) Loussyille Tetfecsan KY, Hoult 7 (Giy apace) that my mailing address, if diferent,is 0 KY Fant ice araaay oH Tr and that | am a registered Tlemaccabicn voterin “Dishuek %F (AN). precinct; ‘eam that | believe inthe principles of the Demaac cai Party, and intend to support its principles and policies; that | meet all the statutory and constitutional qualifications forthe office which | am seeking; that if nominated as a candidate of such party at the ensuing election | will coopt the nomination and not withdraw for ‘reasons other than those stated in KRS 118,105(3); that! will not knowingly violate any election law or any law relating to corrupt and fraudulent practice in campaigns of elections inthis state, andi finaly elected | wil qualify forthe offce. Subscribed and sworn to before me by, this 11 day or Decem bor, 20.14 on) {tisdiction from which the candidate seeks nomination; and that we believe _Claaucle.s Daind Yates ‘ame of Candidate = Please Typm or Pri) tobe qualified to fil the office of State. Sema BeBe ¢ Defies, Omg wen cur RA. lorie ‘sive aay Gp ‘rasarnrnaeay ——“f65)” — cr Ky Sas aR c tional ae ‘Subscribed and sworn to before me by, er B Chan ‘and ery 8 James _B. Yate this_ 1AM day of December 20 14. so or APM sete at lange 112512020 ‘Saka atoaoR ORS DBS IST. Comneacn ists) EXHIBIT APouiries 4 "unde Me Guctnar Davi yess pers run rel Be Resuhy Sle Sere Dsti 3 ea. ou Dvd ae sgt tare. 29 245 PHT tp eter 906 LOUISVILLE, KY (WAVE) - Following in his family’s footsteps, Louisville Metre Counetl member David Yates plans on running forthe Kentucky State Senate. if Yates, whom we spoke with as he heatled to Frankfort to file for the set, said he plans on running for District 37 which is currently held by Senator Perry Clark, who also is endorsing Yates. Yates has served on the Metro Counell since 2010 representing the areas of Auburnuale, Pleasure Ridge Patk, Parkridge, Prairie Village, Valley Station, and Waverly Hills. He also served as Couneil President for two years before handling the seat over to Davie James, Yates's grandfather and World War Il veteran, James Yates also served in the Kentucky Senate for 22 years. “ie was accompanyed his grandson ashe fled for the race David Yates i a local attorney and served as an Assistant Attorney General where he Focused on laws to rotect people against sexual predators. He was also the attorney who first represented the victims of sexual abuse at the hands of two former Louisville Metro Police Department officers who were part of the {departments Explorer Program, Yates, who plans to remiain on Metro Council until he wins in 2020, sald he hopes to be able to make a sreater impact on the community by becoming a stete senator. Copyright 2019 WAVE 5 News. All rights reserved. EXHIBIT B(COMMONWEALTH OF KENTUCKY OFFICE OF THE SECRETARY OF STATE MICHAEL G. ADAMS TO: POTENTIAL CANDIDATES. FROM: MICHAEL G. ADAMS, SECRETARY OF STATE. To avoid any delays in the fling of candidate documents to attain ballot access required to fle with the County Clerk, candidates should directly contact the county clerk in their county of residence for fling procedures and requirements. To avoid any delays in the fing of candidate documents to attain ballot access required to fle with the Office of the Secretary of State, the following is provided: 1. Complete all applicable blanks on the filing form. The Office of the Secretary of State will make the necessary copies for distribution. 2. Candidates and signers must have their signatures acknowledged by a Notary Public, if applicable, and the expiration date of the notary’s commission must be stated, 3. All copies of form KREF-001, Statement of Spending Intent and Appointment of Campaign Treasurer, (not applicable to Federal Candidates who must register with the Federal Election Commission) should accompany the filing form. The Office of the Secretary of State provides a duplicate copy to the Kentucky Registry of Election Finance (‘KREF"). 4, Checks should be payable to the Kentucky State Treasurer. Questions relating to campaign finance procedures and requirements should be directed to KREF at 502-573-2226. In addition, the KREF’s website, hitp:/hwww kref ky.qov, provides for the downloading of required reporting forms and a book titled Guide to Campaign Finance. Questions relating to campaign finance matters for federal candidates should be directed to the Federal Election Commission at 1-800-424-9530. Candidate filing forms may be fled in person or by mail atthe folowing address: Office ofthe Secretary of State Election Division Room 148, State Capitol 700 Capital Avenue Frankfort, KY 40601-3493 If our office may be of further assistance to you, please contact our election staff at 502-564- ‘3490 or by email at sos.elections@ky.gov. ELECTION DMISION Kentuki> (sam 7927436 sume cd STATE exPMOL (a) rearese 0 CAPHAL AVENUE. pe eeeeae agers FAC Banu Sior FRANKFORT. KY 40601-3493 eee WEBSITE: worn.208 hy gov EXHIBIT C 1ofSSTATE SENATOR (ODD DISTRICTS) REPUBLICAN and DEMOCRATIC PARTY CANDIDATES PRIMARY ELECTION "Notarized | Candidate's signature and two (2) registered voters of the same ‘Signatures Required: | party from the district or jurisdiction from which candidate seeks nomination, | Earliest date to affix signatures ‘November 6, Earliest date to file November 6, 2019 Latest date to file (4:00 p.m., local time) January 10, 2020) [Filing Form SBE 66 Notification and Declaration] [Filing Form KREF 004 ‘Appointment of Campaign Treasurer and Optional Request for Reporting Exemption} Filing Fee $200.00} [Fling Official Secretary of State] Political Party Definition: A ‘political party” is an affiliation or organization of electors representing a political policy and having a constituted authority for its government and regulation, and whose candidate received at least twenty percent (20%) of the total vote cast at the last preceding election at which presidential electors were voted for. KRS 118.015 (1). Republican and Democratic Party candidates attain primary ballot access by filing with the Secretary of State a Notification and Declaration. ‘As mandated by KRS 118.125, the Notification and Declaration shall be signed by the candidate and by not less than two (2) registered voters of the same party from the district or jurisdiction from which the candidate ‘seeks nomination; shall include a declaration sworn to by the candidate that he or she possesses all the constitutional and statutory requirements of the office for which the candidate has filed; shall be subscribed and sworn to before an officer authorized to administer an oath by the candidate and by two voters making the declaration and signing the candidate's petition for office. Only persons who are qualified under the provisions of KRS 116.055 to vote in any primary election for the candidates for nomination by the party at whose hands he seeks the nomination shall have his name printed on the official ballot of his party for an office to which he is eligible in that primary. Establishing Campaign Account: For information regarding campaign contribution and expenditure reporting requirements received or expended in the year before the year the candidate appears on the ballot, contact the Registry of Election Finance at (502) 573-2226. Please Note: All information contained in this packet is subject to change per Kentucky Revised Statutes. EXHIBIT C 20f5NOTIFICATION AND DECLARATION (Repubtcan and Democratic Candatas Fn or Primary Becton fran ofc che han Goverertestenant Govern) oF {or nomination tothe ‘Tae of Candie — Pas Type POR office of. — Toa saa Disa rar, wn pica) To ——— Ty Ciao Saray a Sita, ws case ay Be) For the purpose of having my name placed on the official primary eloction ballot as a candidate for ‘nomination by the Party. |, Teo ean a as Geared ov Bw POTD RAS TET) 4o solemnly swear that my residence is. Renton nae Ky. i. appre) roo ar that my mailing address, if diferent, is Ky, Pen es hase ei ir and that | am a registered, voter in precinct; Pam that I believe in the principles ofthe, Party, and intend to support its principles and policies; that | meet all the statutory and constitutional qualifications forthe office wich | am seeking; that it ‘nominated as a candidate of such party at the ensuing election, | wil accept the nomination and not withdraw for ‘wasons other than those stated in KRS 118,105(3); that! wll not knowingly violate any election law or any law ‘elating to corrupt and fraudulent practice in campaigns or elections inthis state, and if fnally elected | wil qualify {or the ofce. Sipe Cari) ‘Subscribed and swom to before me by Tare ot Cay this, day of, .20__. ‘oa Siar a aaa Tie Oy (Conran Eaton) We, and, o solemnly swear that we are registred voters and members ofthe same Party and are from the distict oF {urisiction from which the candidate seeks nomination; and that we believe ‘Was ot Caria Paase Type PA tebe quid tothe ofca of aaa Ky Speer aaa Renae Rae) Tein ah vey Spat ear a Suteatbed and swam tbalore maby ae aa tis, ay. 20 ama TT SaaS TROT TRIOS Tamia Ea vt cop Fling fice Kentucky way eer, ae or ctectre 384 6 (0405) PMUCN encopr Canc EXHIBIT C 30f5KENTUCKY REGISTRY OF This Space for Fling Ofer Use Only [This Space for Rely Use Only ELECTION FINANCE 140 Wabut Steet, Frankf. 40601-3240, (602) 573-2226 FAK (02) 5735622 eke yo Heat date stamped, compete te ‘etotng ‘STATEMENT OF SPENDING INTENT eer et wt oo Serta sae AND countyok — Tame Coaiy APPOINTMENT OF CAMPAIGN TREASURER | on. {pate Fe — ne stenere ste en Santon noe ST SST TS oF = moe Pere baa eso Te a Tent unten Geet Pa Uncgres to = 2 oe eT OS a RT OR OTS Tame AST Fa Rs SET OI oT TITS OT INO EXEMPTION. | (or my campsign committee) expect to raze and/or spend more than $3,000 dung the elections) as ndcatd below. HINTEND ‘TORLE ALL CAMPAIGN FINANCE REPORTS crc with the Regitry- | enderstand that wil have campaign nance reports dve a sted below. Ths lemy tent forthe (chal that spp: “iar Scena Ove: 30 an 5 plore the ect) nd 30 days tthe econ several tection fears Ou: 02 and 5 dys bore the bcos and 30 ayer the eto) ‘spel eto tapas Oe: 20 nd ele tection and 30 dys sete ecto) Uespled Term Reprts Due se stove for may ecton Reports Der Gener ton pets Dut) "EXEMPTION OPTION. ory carpaign commie) expect ora andor spend $5000 or law during te ection) inated below which ots eto requests reporting exompton. {understand thet wl have ne campaign fanee reports dn forthe elections inated, ules my campaign ‘cede the $3000 threshold t which me wil Immediately le the eed campatgn France rors ety wih the Regsty Ts my Intent forthe (chock llthat appv "Primary Secon _Ganera clon _Speal con __ nope Term Beton Th ARAENDMENT (To amend candidate, eladion easurer, or depodory eration or prot equent for expen Please Grocty with he agitry.) ley desrbe reason fr amendment or charge ‘cert tht | hove examined the Statement of Spending Intent end Appotntment of Campalgn Tresurer frm ond tothe best of my knowledge ond beteft sue comet and complete. | understand tht adbmasion of ose rroneous, or ncamplte formation may subject me othe penales of 19123990. Condidate's Signature i Treasurers Signature Dote__/_/__ aa On pe, "ine OP Orga An wang Pe Om Ganges vn ace (R EXHIBIT C 40f5STATEMENT OF INTENT AND APPOINTMENT OF CAMPAIGN TREASURER INSTRUCTIONS FIUNG OFFICER INSTRUCTIONS - The Fling Oficer should date/stamp the form In the space provided at the top of the form. Ifa date/stamp device is not used, the Fling Officer must compete the information requested by hand in the spaces provided. State the ‘name ofthe office where form was fed, including the name ofthe county and indicate the date on which the fling was accepted. The Fling Officer should 1) retaln the original form tobe filed with the Cancidate’s fling papers, 2) send a copy tothe Reglstry immediately, ‘and 3) provide the Candidate witha copy. REGISTRY USE ONLY BOX - Ths space is reserved for use by the Registry of Election Finance. 0 not make any marks or enter any Information in this space. ‘GENERAL INSTRUCTIONS - Type or print all entries and provide ll information requested. Candidates are advised that, with very limited exceptions, they may not fle ths form directly withthe Registry. It must be filed withthe Secretary of State or ther County ‘leek only, who wil forward the appropriate copy to the Registry. This form does not constitute the registration of a campaign ‘committe. To register a campaign committe, obtain Form KREF-010 from the Registry and ile it with the Registry. SPECIFICINSTRUCTIONS - ‘SECTION 1. CANDIDATE INFORMATION - This section of the form contains information relating to the candidate. An entry in each field Isrequired. Do not leave any fields blank. Enter the name ofthe candidate as it wll appear on the ballot [SECTION 2. ELECTION INFORMATION - This section contains information relating tothe election. An entry in each fields required. Do rot leave any fields blank. Enter the date of the election for which the candidate ising this form SECTION 3, TREASURER AND DEPOSITORY INFORMATION - This section of the form contain information relating tothe campaign treasurer and campaign depository bank account. An entry In each field is required. Note that a candidate is required to notify the Registry of the death, resignation, or removal of a treasurer and appoint a successor by using this frm or be accountable as his or her ‘own treasurer. If candidate is serving as his or her own treasurer, “Self may be entered inthis fil. SSECTION 4. STATEMENT OF SPENDING INTENT AND REQUEST FOR EXEMPTION, AMENDED INFORMATION, REVOCATION OR CHANGE |W REPORTING EXEMPTION - Pursuant to KRS 121.180(1), this section ofthe form contains options for spending intent and requesting @ reporting exemption based on the amount of money the candidate plans to aise or spend in each election. This section of the Instructions contains important information regarding deadlines fr fling reporting exemptions and possible penalties for exceeding the threshold forthe exemption chosen. For candidates witha January fing deadline - The request for exemption fr the primary nomination must be filed withthe fling officer who receives the candidate's fling papers no later than the fling deadline for the primary. To revoke or change the request for ‘exemption for the primary, the candidate must fle an amended Form KREF 001 no later than 25 days after the fling dealin for the primary. For candidates winning the primary nomination - ifthe candidate has not already filed a request for exemption forthe general ‘lection, it must be filed withthe officer who receives the candidate's fling papers no later than 25 days after the date of the primary. To revoke the request for exemption, the candidate must fle an amended Form KREF 001 no later than 25 days afte the date of the primary, For candidates with an August fling deadline - The request for exemption must be filed withthe officer who receives the ‘candidate's fling papers no later than the fling deadline forthe general election. To revoke or change the request for reporting ‘exemption, the candidate must complete Form KREF 001 no later than 45 days after the fling deadine for the general election. ‘Candidates for county offices, city offices, or school board races may exceed the threshold chosen without ing an amended Form KREF (001. However, the candidate must begin fling all aplicable financial reports due, or be subject to chil penalties for late reporting. All ‘other candidates who fall to revoke or change the reporting exemption chosen, and then exceed the threshold, may be subject to penalties, including civil penalties for late reporting or possible criminal penalties for knowing violations. A candidate who intends to raise or spend over $3,000 is not entitled to a reporting exemption, and is therefore required to ile all reports forthe primary election, {for the general election, of for both elections, or fora special or unexpired term election, a indicated by checking the appropriate bores. If 2 candidate chooses this option, al reports are required, even if no campaign activity has taken place during the reporting period. Whether a candidate is opposed or unopposed in an election does not affect the reporting requirements. A candidate who Intends to rase or spend $3,000 oF less (including the candidate's own money) during each election may request an exemption from all pre- and post-election reporting. When choosing this option, indicate whether the exemption is being requested for the primary ‘lection, the general election, or both, or for a special or unexpired term election. [AMENDMENT - This section ofthe form Is used to Indicate that information as previously fled on a Form KREF O04 has changed. if sing this form to amend candidate, election, treasurer, or depository information, complete 8 new Form KREF 001 in its entirety. In Section 4, check the appropriate box to indicate that the form contains information which i different from that which was originally fled. Briefly describe the reason fr the amendment. (Note: For this type of change the amended Form KREF OO1 must be filed drecty with the Registry) For example, to name @ new campaign treasurer inthe event of the resignation of the former treasure, complete the entire form, include the new treasurer's name, address, and telephone numbers inthe appropriate fields. [SECTION 5. CANDIDATE'S AND TREASURER'S SIGNATURE - After reading the verification statement, the candidate should sign and date the form. By signing the form the candidate acknowledges that he or she has read and understands the verification statement. After reading the verification statement, the treasurer should sign and date the form. By signing the form the treasurer acknowledges that he ‘or she has read and understands the verification statement. EXHIBIT C SofS0133 Directions: To vote, completely fill in the oval as showne Present tne Unio Stas arin Sent a oy Peis BUTTGIEG bows VATES . Loon DELANEY aie BROPHY . Losopn BIDEN lDcTRaN ca fom STEVER | caret A DEAN . fruisi GABBARD Michao! BENNET lMichaal R_ BLOOMBERG JAmy KLOBUCHAR [Bemio SANDERS [Deval PATRICK [Androw YANG [Elizabeth WARREN FUNCOMMITTED™ United States Senator ‘(ote for one) [Mike BROIIER Maggie Jo HILLIARD Jandrow J. MAYNARD [Amy McGRATH [Eric ROTHMULLER [John R. SHARPENSTEEN Bennie J. SMITH Mary Ann TOBIN [demmy C_AUSBROOKS [Charles BOOKER EXHIBIT Dae MB }oo89PGo189 fet aoatae ae Sed Tex il David Yates Sio1 neta Wonds Drive lie Kent D4 DEED ‘THIS DEED made and entered into this 20 day f June, 2013, by and between: ‘Todd A. Greenwell, and Dana M. Greenwell, husband and wife, whose mailing address is 7111 Austinwood Road, Louisville, Kentucky 40214, Parties of the First Part (hereinafter sometimes referred to as “Grantors"), and; . David Yates, and Jill M. Yates, husband and wife, whose mailing address is 8101 Bella Woods Drive, Louisville, KY 40214, Parties of the Second Part, (hereinafter sometimes referred toas “Grantees") WITNESSETH: THAT FOR A VALUABLE CONSIDERATION, being the sum of Four Hundred Sixteen Thousand dollars and Zero cents, ($416,000.00), paid, the receipt of which is hereby acknowledged, Grantors hereby convey unto the Grantees, for their joint lives, with remainder in fee simple to the survivor of them, and with covenant of GENERAL WARRANTY, the following described real estate situated in Jefferson County, Kentucky, together with all improvements thereon, to-wit: 8101 Bella Woods Drive BEING Lot #84, as shown on Plat of Estates of St. Anthony Subdivision, Section 1, of record in Plat Book S1, Pages 5 and S6, in the Office of the Clerk of Jefferson ‘County, Kentucky. Being the same property conveyed to Todd A. Greenwell and Dana M. Greenwell, husband and wife, by Deed dated September 8, 2006 and recorded September 13, 2006, of record in Deed Book 8901, Page $49, in the Office of the County Clerk of ‘Jefferson County, Kentucky. Grantors farther covenant that Grantors are lawfully seized of the estate hereby conveyed, hhave full right and power to convey same, and that said estate is ftee (rom all encumbrances ‘except any and all subsequent taxes which the Grantees hereby assume and agree to pay. PROVIDED HOWEVER, there are excepted any restrictions, stipulations and ‘easements of record affecting said property. EXHIBIT E : 1of3= 1 10089PG0190 Grantor and Grantee hereto slate the consideration reflected in this deed is the full consideration paid forthe property. Grante joins this Deed for the sole pupose of certifying the consideration pursuant to KRS Chapter 382, IN TESTIMONY WHEREOF, Grantor and Grantee hereto have executed this instrument on the day and year first above writen, — Todd A. Greenwell € David LePhlua 7 Hi Bee “By: Todd A, Greenwell, her Attorney in F Ter Attorney In Fact ofrcrt in ee Ba (Oo84 Pa a % STATE OF KENTUCKY ) » 8s. ‘COUNTY OF JEFFERSON ) subscribed, sworn to and Th rong Dent and Consideration Ceres acknowledged before me this 20th ay of lune, 2013 by Say M. Greenwell, by Todd A. Greenwell her Actomey us ‘My commission expires: May 28, 2017 EXHIBIT E : 20f3oS 1008960191 STATEOFKENTUCKY ) ) ss. COUNTY OF JEFFERSON ) ‘The foregoing Deed and Consideration Certificate was subscribed, sworn to and acknowledged before me this 20th day of June, 2013 by vid Yates, and Jill M. Yates, husband and wife. My commission expires: May 28, 2017 ‘THIS INSTRUMENT PREPARED BY: HEBEL & HORNUNG, PS.C. Bee Willem A Merrifield, Zuorney ot Ee 6511 Glenridge Park Place #1 Louisville, Kentucky 40222 (502) 429-9790 END OF DOCUMENT EXHIBIT E - 30f3C DAVID YATES LLC General Information Organization Number 9687310 Name C DAVID YATESLLC Profit or Non-Profit —_P- Profit ‘Company Type KLC- Kentucky Limited Liability Comy Status A Active ae Standing G-Good State Ky File Date 3/6/2008 Organization Dato 3/6/2008 Last Annual Roport 2/28/2020 Principal Office 810) BELLA WOODS DRIVE LOUISVILLE, KY 40214 Managed By Managers Registered Agent ‘CHARLES DAVID YATES 8101 BELLA WOODS DRIVE LOUISVILLE, KY 40214 Current Officers Manager ‘CHARLES DAVID YATES Individuals / Entities listed at time of formation Organizer ‘CHARLES DAVID YATES Images available online Documents fed with the Ofice of the Secretary of State on September 15, 2004 or hereafter ar avatable as scanned Images or POF documens. Documents fled porto September 15, 2004 wil become avaliable as tne images are crested. ‘annual Renoct 2/28/2020 Reinstatement Certificate of 1/43/2990 1:06:02 pM Reinstatement 41/13/2020 Administrative Dissolution 10/9/2017 Annual Report 6/30/2016 ‘Annual Renort 4/27/2015 Se 3/8/2014 10:33:16 PM name/address chanc Ffinclnal Ofte Address 3/8/2014 10:31:47 PM Annual Report 3/8/2014 ‘Annual Report 3/8/2013 Annual Report 4/19/2012 ‘AnnualReport 6/29/2031, ‘Annual Report 4/26/2010 Annual Report 7/33/2008 ‘Articles of Organization (Lic), 3/6/2008 Assumed Names Activity History EXHIBIT F page 2 pages 2 pages i page L page i page 1 page 1 page 1 page 1 page 1 page A page 1 page 2 pages 1 page PDE PDE sift RRER RB RRR Ne i Ni PDE POE PDE DE 1of2ting File Date Annual report Yooaorseam 1/13/2020 Reinstatement Losras om ‘Admin Dis. A. report not in 10/9/2017 ose 6/30/2036 Ar I report, 2:45:00 PM Annual report sede ‘Annual report Tovsarse ow Registered agent address change 3/8/2014 | Principal ofce change tovsacay om Anal report aecs2 aM siigon Annual report 11:04:00 AM Annual report 3138.16 aM s/36/2010 Annet report si32:20 om Annual report ieaoaran 3ye/2008 aad aSaa20m Microfilmed Images EXHIBIT F Effective Date 2/28/2020 10:46:34 AM 1/13/2020 10/9/2017 6/30/2016 2:45:00 PM 4/27/2015, 12:48:27 PM 3/8/2014 10:34:58 PM 3/8/2014 10:33:16 pm 3/8/2014 10:31:47 pm 3/8/2013 8:48:32 AM 4/19/2012 11:04:00 AM 6/29/2011 9:39:18 AM 4/26/2010 7/13/2008 3/6/2008 (Org. Referenced 2of2DEED Book 11600 Page 315 Bobbie Holsclaw Jefferson County Clerk's Office ‘As evidenced by the instrument number shown below, this document hhas beon recorded as a permanent record in the archives of the “Jefferson County Clerk's Off. ‘ie Inereanortoms Bree tse EPPERSON CO, FE 2000 STATE or KY ObED Ta Sa000 marc cnec ea an Serena Seana Imoexne cusnn > BK: D 11600 PG: 318-318 ‘527 W Jefferson St ~ Loulsvile, KY 40202 (602) 574.5700 Website: wen jffersoncounyclerk.org | Emall: counyclerk @jelfersoncountycerk.ory EXHIBIT G lof4+ DEED Book 11600 Page 316 3 ‘When Recorded Renu Ta: Bluegrass Lend Tite, LLC 2000 Warrington Way Suite 230 Louisvile, Ky 40222, TOV-19.6033 DEED ‘THIS DEED, made ad eatered into this 4th day ofJanuzry, 2020, by and between Mf. J Properties LLC, 1 Kentucky Limited Liability Company, Fist Pary, with « mulling addres of $408 Apache Road, Louisville, KY 40207; AND C. David Yates, LLC, « Kentucky Limited Liability Company, Second Party, witha malling address of 8101 Bela Woods rive, Louie, KY 40214; ‘Tae cuteat years tx bilo be seat nef C. David Yates, LLC a: 8101 Bella Woods Drive, Luin, KY 40214; ‘WITNESSETH: ‘THAT, fora valuable consideration of $40,000.0, the receipt of whichis hereby aclnowledge, the Fst ary as BARGAINED AND SOLD and does hereby GRANT AND CONVEY unto Second Paty, is scestors and/or assigns, as their interests my appest forever, the fllowing described propery locates in Jefferson County, Cominonweath of Kentucky: Begining atthe intrection of the Southwest line of Flat Rock Ros, now Bradley Avene, with the ‘Nort line of Birbee Avenue; tence with sald line of Barbe Avenue, Westwardy 126 fet? ches to 8 private alley 10 fet wide thence with the same, Norhwardly end parallel with For Steet, 33 fees, ‘thence Eastwardly and prallel wits Barbee Avenue 86.85 fet oa poet in he Southwest line of Bradley ‘Avenue; thence with seme, Southwardly 44 fet 7-172 inches othe pint of beginning. Being the same property conveyed to Md J Properties, LLC, a Kentucky Limited Liability Company, by Deed dated March 3, 2016 and recorded March f, 2016 of rcord in Deed Book 10571, Page 860, nthe Office ofthe Clerk of Jefferson Coury, Kent). ‘TOHAVE AND TO HOLD the sbovedescribed propery, together with all appurtenances and privileges ‘thereunto belonging, unto Second Party, its successors enor asigns, as thei inarests may appear forever FIRST PARTY does hereby relese and relingish unto the Second Paty, its successors andor asigns, at ‘heir ites: may appear forever, al ofits right tile and intrest in and othe above-described propery, {including al exceptions allowed by lw nd des hereby covensntto and with Second Paty, succassors andor astgns, as ther interests may appear forever, that itis lawfully seized in fee ample te to said ‘ropety and his good right to convey the same asi herein one; that sald propery i fre md clear of al encumbrances of whatsoever nature, except as herein sated, an tat it will WARRANT GENERALLY the tide sald propery. PROVIDED, HOWEVER, that there is expected from the foregoing warany and covenanis of tte and {his conveyance is made subject to any resrctions, easements and conditions of record afecting sal ie ‘Second Party assumes and agrees to pay alla valorem taxes assessed spans! he above described for the cuentfsal year and ll subsequent years the cure tes and assessments Yo be proaied es of {he date of wansfer ofthis Deed, EXHIBIT G 2of47 DEED Book 11600 Page 317 ‘The partes hereto state the consideration reflected inthis Deed isthe FULL CONSIDERATION paid for ‘he property. The Party of the Second Part joins in this Deed forthe sole purpose of certifying the consideration pursuant to KRS 382, IN WITNESS WHEREOF, the Parties have hereunto set their hands, this the day and year fist above writen, FIRSTPARTY: & J Properties LLC, a Kenmucky Limited Lish ily Company 'W. Bangles, Manager STATE OF KENTUCKY ‘COUNTY OF JEFFERSON ‘The foregoing instrument was subscribed, swom to and acknowledged be January, 2020 by Jonathan W. Baughman, Manager of M & 1 Company, Fist Party. EXHIBIT G outaS DEED Book 11600 Page 318 ‘SECOND PARTY: . David Yates, LLC, « Keoucky Limi abt iy By ms STATE OF KENTUCKY COUNTY OF JEFFERSON ‘The foregoing instrument was subscribed, sworn fo nd acknowledged before me on this 1th day of Janay, 2020 by Charles David Yates, Member of C. David Yates, LLC, a Kentucky Limited Lishiity (Compaay, Second Par. CY, Stat at Large My Commision Expire: 1/2) END OF DOCUMENT EXHIBIT G 4of4DEED Book 11600 Page 319 Bobbie Holsclaw Jefferson County Clerk's Office |AS evidenced by the instrument number shown below, this document has been recorded as a permanent record in the archives ofthe Jefferson County Clerk's Off. ‘NERO INST # 2020010023, BATCH # 213238 JEFFERSON CO, KY FEE $50.00 STATE OF KY DEED TAX $85.00, PRESENTED ONC s6a1200 11.2321 te (ipoeer sluesrass uno Te Oe BK: D 11600 PG: 319.322 ‘527 W Jefferson St ~ Louisvile, KY 40202 (602) 574-5700 ‘Website: wow jffersoncountycler org | Emalt countyclerk@jofersoncountyelerk org EXHIBIT H lof4DEED Book 11600 Page 320 3 When Recorded Return To: Bluegrass Land Til, LUC +2000 Warrington Way Suite 230 Louisville, KY 40222 TOU-19.5029, DEED ‘THIS DEED, made and entre into this 14th day of Jenutry, 2020, by and between Haus Vibes LLC, 2 Kentucky Limbed Liability Company, FirstPary, wit amaling dares of 2127 Madison Stet, Pade, KY 42001; AND C. David Yates, LLC, a Kentucky Limited Liability Company, Second Paty, with & ‘maling adres of 8101 Bella Woode Drive, Louivile, KY 402 ‘The curent year’s tx bilo be sent in efoC. David Yate, LLC et: 8101 Bella Woods Drive, Louisville, KY 40214; WITNESSETH: ‘THAT, fora valuable consideration of $85,000.00, te receipt of which s hereby acknowledge, the First, Party fas BARGAINED AND SOLD and does hereby GRANT AND CONVEY unto Second Pary, its succtasors endfor assigns, as bes interests may appear forever, te following described property loested in Jefferson Couney, Commonwealth of Keatcl Beginning onthe Northside of Kenton Avenue (ormetiy T. Stee) 145 fat West of Wilder Avene; runing thence Westward aloog the Noth side of Kenton Avenue, 55 fest; and extending back ‘Northway, ofthe same with between lines parallel with Wilder Avenue, 90 fet the West sie of abd lot binding onthe Eastside ofan alley. Bing the same property conveyed to Brenda L. Nall and Catherine L. Cannon, by Deed dated August 31, 2011 and recorded September 7,201, of reord la Deed Book 9767, Page 880, nthe Office ofthe (Clerc ofeferson County, Kenucky and ‘Thereafter being the same property conveyed to Haus Vibes, LLC, e Kentucky Limited Libility (Company, by Deed dated July 17,2018 and recorded July 17,2018, of record in Deed Book 11199, Page (640, in the Office of the Clek of Tefferzon County, Kenly. ‘TOHAVE AND TO HOLD the sbovedeseribed property, together wth al eppurtenances and privileges ‘hereunto belonging, unto Second Pry, is successors andor ssigns, as their ees may appear forever FIRST PARTY docs hereby release and relingish unto the Second Party, ts suscestors andlor assigns = their imerests nay appear forever, ll fits rgh, il and intrest in an tothe above-deseribed property, Including al exceptions allowed by lw, and does hereby covenant o and with Second Party, its sueeessor andor assigns a thee interests muy appear freve, that cis lawflly seized In fee simple te wo sald ‘Property ands good righ to convey the same asi herein done; that sald property is fee and clear of all, encumbrances of whatsoever nature, except as herein stated, and that ft will WARRANT GENERALLY the tile to sid propery. PROVIDED, HOWEVER, that there is expected from the foregoing warrany and covenants of tide and this conveyace is made subject o any resbetions, easements and conditions of record affecting sd tle EXHIBIT H 20f4DEED Book 11600 Page 321 ‘Second Panty assumes and agrees to pay all od valorem taxes assessed egunst the above described property forthe curent fiscal year and al subsequent years, the current taxes and assessments tobe prorated as of the date of tansfer ofthis Deed. ‘The parties hereto state the consideration reflected inthis Deed isthe FULL CONSIDERATION paid for the property. The Paty of the Second Part Joins in this Deed forthe sole purpose of certfVng the consideration pursuant to KRS 382. IN WITNESS WHEREOF, the Parties have hereunto set their hands, this the day and year first above writen, FIRST PARTY: Has Vibes LLC, a Kentucky Limited Lilly STATE OF KENTUCKY ‘Company otal C. Reasor— (Reston, Manager COUNTY OF Cun ‘Th foregoing insuument was subscribed, swom to and acknowledged before meonthis_\}_day of, January, 2020 by Marsha C. Reason, Manager of Haus Vibes LLC, a Kentucky Limited Liability Company omg KENTUCKY, State at Large My Coramission Expires: 02/23/2029 EXHIBIT H 30f4DEED Book 11600 Page 322 ‘SECOND PARTY: (C-David Yates, LLC, a Kentucky Ltd Labi iy ‘STATE OF KENTUCKY ‘COUNTY OF JEFFERSON ‘The foregoing instrument was subscribed, sworn 10 and acknowledged before me on this 1th day of Jaauny, 2020 by Charles David Yates, Member of C. David Yates, LLC, a Kentucky Limited Lisbity ‘Company, Second Party END OF DOCUMENT EXHIBIT H 4o0f4DEED Book 11600 Page 323 Bobbie Holsclaw Jefferson County Clerk's Office [AS evidenced by the instrument numbor shown below, this document has been recorded as a permanent recordin the archives of the Jefferson County Clarks Office. EEA Ing szomormoe Barcne nase Serreneon GOK Fe 000 Stare or tr O89 TAK seno Mae Rete Soe iepante Epeanemnce uae 600 ‘527 W Jefferson St~ Louisvile, KY 40202 (502) 74-5700 Website: wu jeffersoncountycierkorg | Ema: counyclerk @jetfersoncountycerk. org EXHIBIT I lof4DEED Book 11600 Page 324 ‘When Recorded Return To: Bloegress Land Title, LLC 2000 Warrington Wey Suite 230 ‘Louisville, KY 40722 Lou.19-9024 DEED ‘THIS DEED, made and entered into this 14th day of January, 2020, by and between David R. Deleiy- Seale single man, Party, ailing ‘The current year's tax bill to be sent in clo C. David Yates, LLC at: $101 Bella Woods Drive, Louisville, Ky 40214; |WITNESSETH: ‘THAT, fora valuabie consideration of $68,000.00, the receipt of which is hereby acknowledged, the Fist ‘any has BARGAINED AND SOLD and does hereby GRANT AND CONVEY unto Second Paty, bis or ‘ber rs and asigns forever, the following deseibed property located in Jefferson County, Commonwealth of Kentucky: ‘Being Lot 176, Lawnviow Addition to the City of Louisville, County of Jefferson, and Ste of Kentucky, Plat of which i of recordin Plt and Subdivision Book 1, Page 177, i the Office ofthe Clerk of the ‘County Cour of Jefferson County, Kentucky. ‘BEING the same property conveyed to David R Deleury-Schal single, by Deed dated August 29,2014 ‘nd recorded September 2, 2014, of record in Deed Book 10291, Page 822, in the Office ofthe Cotaty (Clerk of Jefferson County, Keatucky, ‘TO HAVE AND TO HOLD the above-described property, together with all appurtsaances end privileges ‘thereunto belonging, unto Second Paty, for and daring their oit ives, FIRST PARTY docs hereby release and relingush unto the Second Pary, his or her heirs and assigns forever, al oftheir right, the and interest in and to the above-described property, including all exceptions allowed by lw, and does hereby covensn! to and with Second Party, his or here and asigns forever, that ‘hey ae lawfully seized in fe simple tte to suid property and has good right to convey the sume as is herein done; tbat suid propety is fre and clear af all encumbrances of whataoever nature, except as herein ‘ated, and that they wil WARRANT GENERALLY the te to suid property. PROVIDED, HOWEVER, that there is expected from the foregoing waranty and covenans of tite and ‘his conveyance is made subject to any restrictions, eascmcals and condition Of record affeting sid te, Scond Paty assumes and agecs to pay all ad valorem taxes assosod against the above described property for the current fiscal year and all subsequent years, the current axes and assessments to be prorated ws of ‘the dat of transfer of thie Deed. ‘The partes hereto state the consideration reflected inthis Dood isthe FULL CONSIDERATION paid for the property. The Party of the Second Part joins in this Deed forthe tole purpose of certifying the ‘consideration purruant to KRS 342, EXHIBIT I 2of4DEED Book 11600 Page 325 IN WITNESS WHEREOF, the Parties have hereunto set their hands, this the day and year fit above writen, FIRSTPARTY: Geet Dealt bay onrrEgcoe COUN OF ‘The foregoing instrament was subscribed, sworn to and acknowledged before me on this_(Q)_day of ———n ERE a 2 oar aie a State at Large ee ed Saye eer iy Comin beara Le EXHIBIT I a4DEED Book 11600 Page 326 STATE OF KENTUCKY ‘COUNTY OF JEFFERSON ‘The foregoing instrument was subscribed, sworn to and acknowledged before me om this Mh day of January, 2020 by Charles David Yates, Member of C. David Yates, LLC, a Kentueky Limited Listy ‘Company Second Pary. (459) 26671611 END OF DOCUMENT EXHIBIT I 4of4DAVID YATES, ATTORNEY, PLLC General Information Organization Number 0731508 Name DAVID YATES, ATTORNEY, PLLC Profitor Non-Profit P= Profit Company Type KLC- Kentucky Limited Lisbilty Company Status AcActive ‘Standing G-Good State Ky File Date 6/9/2008 Organization Date 6/9/2009 Last Annual Report 3/20/2020 Principal Office 111 WEST WASHINGTON ST SUITE 400 LOUISVILLE, KY 40202 Managed By Members gistored Agent DAVID YATES 111 W, WASHINGTON STSTE 400 LOUISVILLE, KY 40202 Current Officers Manager ‘CHARLES DAVID YATES Manager ‘Lindsey Diane Yates Individuals / Entities listed at time of formation Organizer PAVID YATES Images available online Documents fed with he Ofice of the Secretary of State on September 15, 2004 or thereafter are avaliable as scanned ‘mages or PF documents. Documents fled prior to September 15, 2004 will become avalabe asthe images ae Creal, anual ferare Sasso Tose RE Seated ASeEE | S/S420193:16:96 9M i pope BRE BuocaalOfice Ades: syayq191:14:59°M 1 poge PRE 5/31/2019 1 page PDE ‘Annual Report 4/11/2018 1 page ‘PDE Annual Report 9/11/2017 1 page ‘BOE ‘Annual Report 9/13/2016 L page ‘PDE ‘Annual Report 4/27/2015 1 page PDE BEOSGRERLAGERL | 7/20/20168:27:21 AM 1 page BRE oame/address change Reoistered Agent 7/18/2014 8:26:20 AM 1 page PDE name/address change ‘Annual Report 7/18/2014 1 page ‘PDE Annual Report 2/27/2013 1 page ‘POF ‘anual Recor sraeaois Tpese BBE Sanat ice. 6/29/2011 9:28:04 AM 1 page ‘PDE fia tenors somos pase one sual Senor srira0%0 tpese Bear EXHIBIT J lof2Articles of Organization (LLC) 6/9/2009 Assumed Names Activity History Fung File Date aoe nee. Annual report i3u/2019, Registered agent address change?/3/2019 Principal office change Suan senate sae ‘Annual report gfia/2017, ‘Annual report g/aote, tee eer, Registered agent address changey/18/2014 Registered agent address cchangez/ 28/2014 | ter Bee srt ot ie _ tkeraspm ‘Annual report gyz972011 Principal office change siz ‘Anal report s/ayr2o10, ws om, Microfilmed Images EXHIBIT J 1 page iff Effective Date 3/20/2020 10:03:56 aM 5/31/2019 3:18:31 PM. 5/31/2019 1:16:36 PM. 5/31/2019 1:14:59 PM. 4/11j2018 9:11:36 AM 9/11/2017 3:32:07 PM 9/13/2016 2:08:55 PM 4/27/2015 12:43:23 PM 7/18/2014 8:27:21 AM 7/18/2014 8:26:20 AM 7/18/2014 8:21:57 AM 2/27/2013 2:23:33 PM. 8/22/2012 12:07:38 PM 6/29/2011 9:31:54 AM 6/29/2011 9:28:04 AM 6/13/2010 6/9/2009 (rg. Referenced 20f20731804.08 “Ws ARTICLES OF ORGANIZATION {here DAVID YATES, ATTORNEY, PLLC efeespeeoio The undersigned organizer, desing to form a protessanii nied tablty fampany under the Kentucky Limited Ublity Company Ack, hereby stator The ng: 1 Te name of he proesonal nied Eby company: DAVID YATES, ATTORNEY, PLLC, ad 2. The name and adéress of the Ita registered agent I DAVID YATES: 1623 ALANWOOD ROAD LOUISVILLE, KENTUCKY 40214 3. The address ofthe inal principal offce ofthe professional Imited labity ‘company is 1823 ALANWOOD ROAD LOUISVILLE, KENTUCKY 40214 ‘4. ‘The professionel imited laity company is to be manages by ts members. 5. The company is organized to provide chiropractic and related services, The effective date ofthe begining of existence ofthe Company is the date on which these Amtcies of Orgarzator are received by and fed vith tre Kentucky Secretary of States Ofte. IN WITNESS WHEREOF, the undersigned has duly executed Artces of ‘Organtzation tis 4 day of Sune, 2009. Da ‘SONSENNT OF AGENT 1, DAVID YATES, consent to serve af ‘Agent of he above tied abay company. EXHIBIT Kthrough voluntary company may be able to negotiations, we will le @ recover any PIP benefits they lowsvit to aggressively force paid to you. {fir resolution through our ivi justice system, MORE FAQS (HTTPS://DAVIDYATESLAW.COM/FAQS) Licensed in Kentucky ° Admitted to all Kentucky State and Federal Courts home (/home) | contact (/conto!) Low Offices of David Yates, PLC 111 W. Washington Street, Suite 400, Louisville KY 40202, tel (502) 882-5179 (tel:+ 15028825179) | fax (502) 882-5190 ‘he information provided on this website does not, ond isnot inended to, constitute legal advice; Instead, all information, con 3, and materials avoilable on ths site are for general informational purposes only. © 2019 Low Offices of David Yates, PLLC EXHIBIT LCareer As an Assistant Attorney General, David represented the Commonwealth of Kentucky before the Kentucky Court of Appeals and Supreme Court and was appointed to Megan's Law Team, a special taskforce designed to improve protection of the public from sexual predators through legislation and prosecution. David was later retained by the United Auto Workers Union Legal Plan where he practiced primarily in consumer protection litigation. David manages his own general litigation law firm, the Law Offices of David Yates, PLLC. He is arelentless fighter for both his clients and his community. David is a proven strong voice for our community. EXHIBIT MEXHIBIT N (o687310.06 cata Ane Commonwealth of Kentucky | sey Sern o Michael G. Adams, Secretary of Stal ise "i470, soaccem reese ons Certificate of Existence a est regio ————————— |, MichaetG. Adams, Secretary of Stat ofthe Commonwealth of Kentucky, do hereby certify that according to the records in the Offic of the Secretary of State, DAVID YATES LLC ‘as eliminate all the grounds for dissolution, pai all fees and penalties owed to the Secretary of State and met all other requirements for reinstatement. The ‘Secretary of tate hereby cancels the certificate of dissolution issued on October 9, 2017. The effective date of reinstatement is January 13,202 further certify that € DAVID YATES LLC is limited ability uly organized and existing under the laws ofthe Commonwealth of Kentucky, ‘whose date of organization is March 6, 2008, and whose period of duration is perpetual IN WITNESS WHEREOF, [have hereunto set my hand and afised my (Otticial Seal at Frankfort, Kentucky, this 13" day of January, 2020. lof3Muli-page document. Select page: 1 2 KENTucKY Depanrucur oF REVENUE BislaN OF comPonaton rex seinGH srReey, STATON SZ Pre Sisneerzo FRAEORT RENUCNY 40602163 Fre sresotcose ono vares i.e Notce Oa: sana 1,2000 Srot wet a nGODS pave KvSS0%9 Nos ara tous? iy wane we Late of G04 Sung Rone ~ Arona sumuny ‘Yovroquni eer toed stand, you erty sh good standing we Danwerernef Reverse ee our Wo vested he loves ormaton 2 peepee ante Grr teense 4 Yastes coms ond Lt sre neue. rou we exe on ag 4 Younove no catandeg x asessnens were Ono Calton ove ‘Spy operant acs Ths tc wisi curator 3 ays om ne nate dt stove Oerr''rvvvovovrvwtlre Topo St? | Btiontiy Stein of Suaainesennite see ott 2 Raney aes aa ne Sieg memmetencteratanemetes Seeders » Eenianretity a ommomeageyermme {StSRAaber esta Season ee etree ee 4000 oy yourave any questoes garg renee. plate conse me Thane you Jom FOR wary, aevanes Era ea lipauy go Broce Sante ea" ss “page document. Select page: | 2 EXHIBIT N Zot8Multipage document. Select page: | 2 conaeats oT Commonwealth of Kentucky 0687310.06 — Fling te $4500" Alison Lundergan Grimes, Secretary of § ems sre al o_O ce tg cee ae “Secromary of State Reinstatement Application amd |e Recovt $1500 renteteare | Reinstatement Annual Report RST oh Tortie yous 247 trough apaonely oe Leeamiadoaes ee icaiggmeaemramnmaata Se ‘Sonne wane Sa ine =e Eno peony ‘iersenamoogs cree tousvate ra ‘Seames DAVO YATES il carom noc ptm Rr rern et 1% C BAND VATE LAC lie Seaway of Sata 2 romea ts raneemen ewan RRS ZB 28 Denton Poe Rona} wn'h Rate once Ruane anna LP LAz 9 Malti-page document. Select page: | 2 EXHIBIT N eoswc0e0 Welcome astra Opantabn Seach Name Availability Search Enter name (minimum of 4 characters required) or organization number below ‘A maximum of 250 names will be returned [aw orice of Dav Yates, PLLC Please note: Searches may be performed by keying the entire business name or a portion of the business name. Search Results (No matches) ‘The name is available. No companies were found which match your request. ‘we ses ygoutseaevipahanamnov EXHIBIT O‘The Kentucky Bar Association does not certify any lawyer identified here as a specalist or an expert nN addition, non-disciplinary information about any lawyers listed on this website is provided by the lawyers listed. The Kentucky Bar Association does not review, investigate, or evaluate the accuracy or completeness of that information provided, Therefore, the Kentucky Bar Association does not warrant the accuracy or validity of this information, and hereby disclaims any liability to any person for any loss ‘or damage caused by errors or omissions in this directory. All bar complaints, investigations of complaints and private reprimands are confidential. As such, the Kentucky Bar Association is not able to confirm or deny that a complaint has been filed against an attorney, that an attorney is being investigated for an alleged violation of the Kentucky Rules of Professional Conduct, or that an attorney has received a private reprimand. Every effort has been made to keep the disciplinary information contained in this website accurate and current, but itis provided with no warranty of any kind, Last updated: 2/6/2020 Charles David Yates OFFICIAL ADDRESS INFORMATION David Yates Law (502) 882-5179 (Phone) 111. W Washington St 4th FL (502) 882-5190 (Fax} Louisville Kentucky 40202 United States [Map] County: Jefferson OTHER INFORMATION Date of Admission: 10/9/2006 status: Active Public Discipline History: No record of public discipline Practice Information pursuant to SCR 3.023: | am engaged in the Private Practice of Law, and | am currently covered by a policy of professional liability Insurance with minimum limits of $100,000.00 per claim and $300,000.00 aggregate for all claims during the policy term. EXHIBIT P-Vote David Yates for KY State Senate te Home About tbLke 3) Folow share ei © Send Message Photos videos Photos Community cect Posts Invite your tends tote th Page Events 2.208 people tke is A 2.223 pea fow mis Community im a: “ About sees © Sena message Vetevates com Poiiteran EXHIBIT QPage Transparency for Vote David Yates for KY State Senate Summary Page History People Who Menage This Page Organizations That Manage This Page Page History Name changes can help you see if the Page's purpose has changed over time. f Page ‘merges have occurred, that means that the Page has combined its followers with another Page. (% Changed name to Vote David Yates for KY State Serato: ( Change name o Vote David Yates for Metre Counei! \© Page created - David Ys Find Support or Report Page8 ‘ Fl @ Vote David Yates for KY State Senate. +++ ‘al David is up for re-election this November and needs your help to continue to deiver fer our community, you, your family, your friend or business are in Distrct 25 anc want to help David by putting @ “Vote Yates" sign infront of your property please comment | below with your address so we can deliver one to you! ‘Vote Yates" signs ate oidered and are expected to be in soon. Look at he Distric picture below to determine if you are in District 25! David appreciates all of your help and suppor: ard vill keep working for you O08 22 Commants 56 Shares Dime Deonmen > share ‘Most Retevant > Couneil District 25 David Yates (02) 574-1125 EXHIBIT S.Vote David Yates for KY State Senate +++ METRO COUNCIL WWW.VOTEYATES.COM EXHIBIT T2 Lax 1060010 eo) <> Ge pealeaatere Ron erey iy CeLouisville Metro Council District 25 (Vote for One) David YATES DEM @ EXHIBIT VKentucky Secretary of State Alison Lundergan Grimes Grimes Statement on 2019 Candidate Certification Kentucky Secretary of State sent this bulletin at 02/08/2019 04:24 PM EST Commonwealth of Kentucky Office of the Secretary of State February 8, 2019 Lillie Ruschett 502.782.7407 FOR IMMEDIATE RELEASE Lilliee, Ruschell@ky,gov Grimes Statement on 2019 Candidate Certification FRANKFORT, Ky. (Feb. 8, 2019) — On Monday, Secretary of State Alison Lundergan Grimes will certify candidates’ names for the printing of the 2019 Primary Election ballot. "We are so excited for the number of candidates that will appear on the ballot this election cycle, said Grimes. Legal names of candidates will be certified on Monday, Feb. 11 for the 2019 Primary Election ballot. "One of my most solemn duties as Secretary of State is to protect the sanctity of the ‘Commonwealth's election ballots, and to safeguard Kentucky's election instruments from being manipulated for political gamesmanship,” said Grimes, Kentucky's chief election offical. “After receiving a written complaint from a candidate for Secretary of State, | revie terials fled with my office by another candidate, who sought to have his name appear on the primary election ballot ‘accompanied by the purported nickname "Trump!" Pursuant to the statutory authority granted to the Secretary of State by KRS 118.129(2), the Secretary of State's Office determined that the candidate in question offered this so-called nickname in an improper attempt to gain an advantage on the ballot. Accordingly, the name of the candidate in question, Carl Nett, as reflected by the signature on his candidate filing papers, will be certified to appear on the ballot. EXHIBIT W