ANDY MARTIN seeks emergency hearing in Board of Elections civil rights lawsuit
Andy Martin’s federal civil rights suit charges that “objectors” to petitions of independent candidates at the State Board of Elections are acting for undisclosed persons, and that “attorneys” for those objectors do not have an actual attorney-client relationship with their “clients.” Martin says secret third parties are paying the legal bills. Martin is also adding Brian Sheahan, a sleazy lawyer for the Republican Party, as a defendant. Sheahan was involved in a sex scandal that led to his defeat in the February primary.
Martin plans to amend his lawsuit to accuse the State Board of Elections of failing to give candidates adequate notice of election objections and, in his case, that Philip Krasny conducted a secret (ex parte) Board hearing.
IN THE CIRCUIT COURT
FOR THE SEVENTH JUDICIAL CIRCUIT OF ILLINOIS
SPRINGFIELD, ILLINOIS
IN CHANCERY
CASE NO. 2010 CH 786
ANDY MARTIN,
Plaintiff,
vs.
DONNA HEFFERNAN, et al.,
Defendants.
NOTICE OF HEARING [DRAFT]
PLEASE TAKE NOTICE that on ___day, July ___, 2010, at ___ A.M., I will appear before the Honorable Peter C. Cavanaugh, sitting in his Courtroom at the Sangamon County Complex, 200 S. Ninth Street, Springfield, Illinois 62701, and present the accompanying motions:
1. Motion for Temporary Restraining Order and Preliminary Injunction
2. Motion for Leave to File Amended Complaint (all parties/add Krasny, Sheahan as defendants)
3. Motion to confirm service of process on Andrew Finko
Dated: July 14, 2010
Respectfully submitted,
ANDY MARTIN
NATIONAL LITIGATION CENTER
P. O. Box 1851
New York, NY 10150-1851
Toll-free tel. (866) 706-2639
Toll-free fax (866) 707-2639
E-mail: AndyMart20@aol.com (text only)
Additional courtesy copy requested to:
ANDY MARTIN
REGIONAL LITIGATION SUPPORT
30 E. Huron Street, Suite 4406
Chicago, IL 60611-4723
SERVICE OF NOTICES IS RESPECTFULLY
REQUESTED BY FAX OR E-MAIL
Additional e-mail address available
upon request
CERTIFICATE OF SERVICE
I certify I have served, the defendants at the fax numbers or addresses known for them:
Donna/Andrew Heffernan: 3931 Scoville Ave., Stickney, IL 60402
John Fogarty: fax (773) 681-7147
Sharon Meroni: One Surrey Lane, Barrington Hills, IL 60010
Andrew Finko: fax (773) 453-3266
Robert Sherman: 778 Stonebridge Lane, Buffalo Grove, IL 60089
State Board of Elections: (217) 782-5959; (312) 814-6485
Mark Kirk: fax (847) 559-2940
Philip Krasny: fax (State Board of Elections)
Brien Sheahan: fax (630) (866) 796-5676
on July 14, 2010
ANDY MARTIN
IN THE CIRCUIT COURT
FOR THE SEVENTH JUDICIAL CIRCUIT OF ILLINOIS
SPRINGFIELD, ILLINOIS
IN CHANCERY
CASE NO. 2010 CH 786
ANDY MARTIN,
Plaintiff,
vs.
DONNA HEFFERNAN, et al.,
Defendants.
MOTION FOR TEMPORARY RESTRAINING
ORDER AND PRELIMINARY INJUNCTION
Plaintiff moves the Court for a temporary restraining order and preliminary injunction as follows:
1. The standards for entering a preliminary injunction are well known: (i) balance of the hardships; (ii) likelihood of prevailing; (iii) irreparable injury and (iv) the public interest. Plaintiff meets all of these tests. This lawsuit is a federal civil rights claim filed in state court, see ¶ 1 (a) of the Complaint. Therefore, the Court follows Illinois procedure but may apply and enforce federal remedies.
2. The defendants are guilty of committing federal civil rights violations against all independent/third party candidates in Illinois. The defendant attorneys are filing “straw” complaints on behalf of fictitious “clients” who are not in fact paying their fees and when the attorneys are in fact being paid by surreptitious parties in order to disrupt the federal electoral process. This is a classic case of the type of Illinois political fraud that has made Illinois politics the laughingstock of the nation. The defendants’ conduct violates federal law as well as Illinois common law maintenance.
3. Plaintiff seeks to bar and enjoin fraudulent
“objections” which are “strike” filings which being orchestrated behind the scenes by undisclosed principals. As to defendant Meroni, she has frankly admitted that she has no interest in statutory compliance and is seeking imaginary relief based on her delusional system.
4. The conduct of the defendants amounts to bad faith and harassment in violation of federal civil rights laws.
5. Defendants State Board of Elections (SBE) and Krasny has failed to provide Plaintiff with adequate notice, and have conducted secret ex parte hearings without notice to Plaintiff, all in violation of federal civil rights laws. Plaintiff has yet to be served with any objections.
WHEREFORE, Plaintiff asks that the Court enjoin the individual defendants from prosecuting their “objections” to Plaintiff’s nominating petitions until after a trial on the merits in this Court of the federal civil rights violations and for such other relief as may be necessary and proper to enjoin the SBE from proceeding further with the individual defendants’ claims.
This motion will be supplemented by a Memorandum of law as soon as possible.
Dated: July 14, 2010
Respectfully submitted,
ANDY MARTIN
NATIONAL LITIGATION CENTER
P. O. Box 1851
New York, NY 10150-1851
Toll-free tel. (866) 706-2639
Toll-free fax (866) 707-2639
E-mail: AndyMart20@aol.com (text only)
Additional courtesy copy requested to:
ANDY MARTIN
REGIONAL LITIGATION SUPPORT
30 E. Huron Street, Suite 4406
Chicago, IL 60611-4723
SERVICE OF NOTICES IS RESPECTFULLY
REQUESTED BY FAX OR E-MAIL
Additional e-mail address available
upon request
CERTIFICATE OF SERVICE
I certify I have served, the defendants at the fax numbers or addresses known for them:
Donna/Andrew Heffernan: 3931 Scoville Ave., Stickney, IL 60402
John Fogarty: fax (773) 681-7147
Sharon Meroni: One Surrey Lane, Barrington Hills, IL 60010
Andrew Finko: fax (773) 453-3266
Robert Sherman: 778 Stonebridge Lane, Buffalo Grove, IL 60089
State Board of Elections: (217) 782-5959; (312) 814-6485
Mark Kirk: fax (847) 559-2940
Philip Krasny: fax (State Board of Elections)
Brien Sheahan: fax (630) (866) 796-5676
on July 14, 2010
ANDY MARTIN
Andy Martin’s federal civil rights suit charges that “objectors” to petitions of independent candidates at the State Board of Elections are acting for undisclosed persons, and that “attorneys” for those objectors do not have an actual attorney-client relationship with their “clients.” Martin says secret third parties are paying the legal bills. Martin is also adding Brian Sheahan, a sleazy lawyer for the Republican Party, as a defendant. Sheahan was involved in a sex scandal that led to his defeat in the February primary.
Martin plans to amend his lawsuit to accuse the State Board of Elections of failing to give candidates adequate notice of election objections and, in his case, that Philip Krasny conducted a secret (ex parte) Board hearing.
IN THE CIRCUIT COURT
FOR THE SEVENTH JUDICIAL CIRCUIT OF ILLINOIS
SPRINGFIELD, ILLINOIS
IN CHANCERY
CASE NO. 2010 CH 786
ANDY MARTIN,
Plaintiff,
vs.
DONNA HEFFERNAN, et al.,
Defendants.
NOTICE OF HEARING [DRAFT]
PLEASE TAKE NOTICE that on ___day, July ___, 2010, at ___ A.M., I will appear before the Honorable Peter C. Cavanaugh, sitting in his Courtroom at the Sangamon County Complex, 200 S. Ninth Street, Springfield, Illinois 62701, and present the accompanying motions:
1. Motion for Temporary Restraining Order and Preliminary Injunction
2. Motion for Leave to File Amended Complaint (all parties/add Krasny, Sheahan as defendants)
3. Motion to confirm service of process on Andrew Finko
Dated: July 14, 2010
Respectfully submitted,
ANDY MARTIN
NATIONAL LITIGATION CENTER
P. O. Box 1851
New York, NY 10150-1851
Toll-free tel. (866) 706-2639
Toll-free fax (866) 707-2639
E-mail: AndyMart20@aol.com (text only)
Additional courtesy copy requested to:
ANDY MARTIN
REGIONAL LITIGATION SUPPORT
30 E. Huron Street, Suite 4406
Chicago, IL 60611-4723
SERVICE OF NOTICES IS RESPECTFULLY
REQUESTED BY FAX OR E-MAIL
Additional e-mail address available
upon request
CERTIFICATE OF SERVICE
I certify I have served, the defendants at the fax numbers or addresses known for them:
Donna/Andrew Heffernan: 3931 Scoville Ave., Stickney, IL 60402
John Fogarty: fax (773) 681-7147
Sharon Meroni: One Surrey Lane, Barrington Hills, IL 60010
Andrew Finko: fax (773) 453-3266
Robert Sherman: 778 Stonebridge Lane, Buffalo Grove, IL 60089
State Board of Elections: (217) 782-5959; (312) 814-6485
Mark Kirk: fax (847) 559-2940
Philip Krasny: fax (State Board of Elections)
Brien Sheahan: fax (630) (866) 796-5676
on July 14, 2010
ANDY MARTIN
IN THE CIRCUIT COURT
FOR THE SEVENTH JUDICIAL CIRCUIT OF ILLINOIS
SPRINGFIELD, ILLINOIS
IN CHANCERY
CASE NO. 2010 CH 786
ANDY MARTIN,
Plaintiff,
vs.
DONNA HEFFERNAN, et al.,
Defendants.
MOTION FOR TEMPORARY RESTRAINING
ORDER AND PRELIMINARY INJUNCTION
Plaintiff moves the Court for a temporary restraining order and preliminary injunction as follows:
1. The standards for entering a preliminary injunction are well known: (i) balance of the hardships; (ii) likelihood of prevailing; (iii) irreparable injury and (iv) the public interest. Plaintiff meets all of these tests. This lawsuit is a federal civil rights claim filed in state court, see ¶ 1 (a) of the Complaint. Therefore, the Court follows Illinois procedure but may apply and enforce federal remedies.
2. The defendants are guilty of committing federal civil rights violations against all independent/third party candidates in Illinois. The defendant attorneys are filing “straw” complaints on behalf of fictitious “clients” who are not in fact paying their fees and when the attorneys are in fact being paid by surreptitious parties in order to disrupt the federal electoral process. This is a classic case of the type of Illinois political fraud that has made Illinois politics the laughingstock of the nation. The defendants’ conduct violates federal law as well as Illinois common law maintenance.
3. Plaintiff seeks to bar and enjoin fraudulent
“objections” which are “strike” filings which being orchestrated behind the scenes by undisclosed principals. As to defendant Meroni, she has frankly admitted that she has no interest in statutory compliance and is seeking imaginary relief based on her delusional system.
4. The conduct of the defendants amounts to bad faith and harassment in violation of federal civil rights laws.
5. Defendants State Board of Elections (SBE) and Krasny has failed to provide Plaintiff with adequate notice, and have conducted secret ex parte hearings without notice to Plaintiff, all in violation of federal civil rights laws. Plaintiff has yet to be served with any objections.
WHEREFORE, Plaintiff asks that the Court enjoin the individual defendants from prosecuting their “objections” to Plaintiff’s nominating petitions until after a trial on the merits in this Court of the federal civil rights violations and for such other relief as may be necessary and proper to enjoin the SBE from proceeding further with the individual defendants’ claims.
This motion will be supplemented by a Memorandum of law as soon as possible.
Dated: July 14, 2010
Respectfully submitted,
ANDY MARTIN
NATIONAL LITIGATION CENTER
P. O. Box 1851
New York, NY 10150-1851
Toll-free tel. (866) 706-2639
Toll-free fax (866) 707-2639
E-mail: AndyMart20@aol.com (text only)
Additional courtesy copy requested to:
ANDY MARTIN
REGIONAL LITIGATION SUPPORT
30 E. Huron Street, Suite 4406
Chicago, IL 60611-4723
SERVICE OF NOTICES IS RESPECTFULLY
REQUESTED BY FAX OR E-MAIL
Additional e-mail address available
upon request
CERTIFICATE OF SERVICE
I certify I have served, the defendants at the fax numbers or addresses known for them:
Donna/Andrew Heffernan: 3931 Scoville Ave., Stickney, IL 60402
John Fogarty: fax (773) 681-7147
Sharon Meroni: One Surrey Lane, Barrington Hills, IL 60010
Andrew Finko: fax (773) 453-3266
Robert Sherman: 778 Stonebridge Lane, Buffalo Grove, IL 60089
State Board of Elections: (217) 782-5959; (312) 814-6485
Mark Kirk: fax (847) 559-2940
Philip Krasny: fax (State Board of Elections)
Brien Sheahan: fax (630) (866) 796-5676
on July 14, 2010
ANDY MARTIN
Labels: Andy Martin, Brien Sheahan, civil rights lawsuit, election fraud
posted by Andy Martin | 10:24 PM
1 Comments:
Weren't you involved in a animal sex scandal that led to your defeat in the February primary?
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