“Money laundering” lawsuit filed in Illinois U. S. Senate campaign
NEWS FROM:
ANDY MARTIN /2010
Republican for U. S. Senator
“He works for all
the People of Illinois”
30 E. Huron Street, Suite 4406
Chicago, IL 60611-4723
(312) 440-4124
www.AndyforUSSenator.com
www.AndyforUSSenator.blogspot.com
www.AndyforUSSenator.wordpress.com
www.MarkKirk.us
www.IllinoisHighSpeedTrains.com
FOR IMMEDIATE RELEASE:
ANNOUNCEMENT OF MONDAY NEWS CONFERENCE IN WHEATON
Andy Martin files case seeking disclosure of “Solo Crime Family” source of political funds
“Candidate X” is target of lawsuit alleging possible money laundering in federal election campaign
(WHEATON, IL)(November 9, 2009) Republican U. S. Senate candidate and insurgent “Internet Powerhouse” Andy Martin filed suit today in DuPage County Circuit Court against Candidate “X” and the Solo family. The case was docketed as No. 2009 L 1406. The complaint follows in this document.
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© Copyright by Andy Martin 2009.
UNITED STATES OF AMERICA
IN THE CIRCUIT COURT OF THE EIGHTEENTH JUDICIAL CIRCUIT
IN AND FOR DUPAGE COUNTY, ILLINOIS
No. 2009 L 1406 AT LAW
ANDY MARTIN,
Plaintiff,
v.
GLEN K. SOLO,
3928 N. PARK STREET
WESTMONT, IL 60558
ANDREW SOLO,
3928 N. PARK STREET
WESTMONT, IL 60558
CANDIDATE “X”,
ADDRESS UNKNOWN,
Defendants.
_____________________/
VERIFIED COMPLAINT FOR MONEY DAMAGES AND OTHER RELIEF
Preliminary Statement
Illinois election law permits a variety of unsavory “petition” practices that are barred by federal law. For example, federal election law bars candidates and their campaign treasurers from acting fraudulently or seeking to conceal the true nature of their expenditures by using straw men to act surreptitiously on their behalf.
The practice of financial concealment is generically called “money laundering” and is a violation of federal law.
Some member of the defendant “Solo Family,” referred to as “Solo and Solo” below, appears to be acting as a surrogate for Candidate “X.” In the course of this litigation, Plaintiff will ascertain the identity of candidate X and substitute his or her name as a defendant in this lawsuit.
[COUNT ONE]
[MONEY LAUNDERING – CIVIL RICO]
1. Jurisdiction and venue
a. This court has jurisdiction to hear and determine the matters presented pursuant to People v. Lewis, 295 Ill.App.3rd 587, 693 N.E.2d 916, 920 (Ill.App. 2d Dist. 1998) citing Tafflin v. Levitt, 493 U. S. 455, 110 S. Ct. 792 (1990).
b. Venue is proper in DuPage County. The “Solo” defendants reside in DuPage County.
c. The Code of Civil procedure is to be “liberally construed” to protect the “substantive rights of the parties.” § 735 ILCS 5/1-106.
d. Both the Illinois Constitution and U. S. Constitutions protect the substantive right to be a candidate for federal office, although the U. S. Constitution reserves to the State of Illinois the ministerial duty of actually conducting federal elections.
2. Factual allegations
a. The parties
A. The Plaintiff
1) Plaintiff is a candidate for United States Senator in the February 2, 2010 general primary.
2) Plaintiff has filed petitions with the Illinois State Board of Elections (“SBE”).
3) As part of his pre-filing due diligence prior to filing this lawsuit, Plaintiff contacted Solo and Solo by Federal Express; the defendants have refused to respond to the circumstantial evidence that some unlawful activity is being conducted by one or more of them. Plaintiff has drawn an adverse inference from the silence of these defendants as permitted by Illinois law, see e.g. Gabriel v. Columbia National Bank, 228 Ill.App.3rd 240, 592 N.E.2d 556 (Ill.App. 1st Dist. 1992).
B. The defendants
1) On information and belief (“OIB”) Glen K. Solo is the only person listed as an owner/occupant at the address given by “Andrew Solo” to the SBE.
2) OIB the status of defendant “Andrew Solo” is currently uncertain because he is not listed in any public database as residing at the address that some person furnished to the SBE.
3) OIB Candidate “X” is the person, or campaign committee or Campaign Treasurer of Candidate X, who furnished the cash to Glen/Andrew Solo which was then laundered and paid to the SBE.
4) OIB the relationship between Solo #1 and Solo #2 is currently undefined, and they are referred to as “Solo and Solo” pending further pleading and discovery.
b. The Facts Giving Rise to This Lawsuit
A. On or about November 5, 2009, defendant “Andrew Solo” of “Solo and Solo” copied the nominating petitions of six (6) candidates for United States Senator, see group Exhibit A attached hereto, including Plaintiff’s petitions.
B. Illinois law permits “ambush” attacks on candidate petitions, as well as the use of nominees, pseudonyms, straw men and other deceptive political practices. Federal law prohibits bars these practices.
C. OIB Andrew Solo of “Solo and Solo” was obviously acting for someone else; Solo’s undisclosed principal furnished the consideration for Solo’s payment to the SBE.
D. The purpose of using a “straw man” such as “Andrew Solo” of Solo and Solo is create a layer of secrecy between the candidate who is planning dirty tricks, such as candidate “X,” and the public awareness of that candidate’s political machinations. Such secrecy is permitted by Illinois state law, but barred by federal law for federal candidates. Federal law controls in this state for federal elections.
E. OIB it also appears possible that Candidate “X” may have recruited unsuspecting or unsophisticated straw men to act on candidate X’s behalf, and that Solo and Solo are dupes or victims of candidate X. Obviously, until we know who paid Solo and Solo and these defendants are deposed, it is impossible to plead facts with definitive clarity.
F. OIB Candidate “X” is obviously planning harassment and ambush attacks on up to six (6) candidates for United States Senator, and seeking to disrupt and corrupt the Republican Party primary for that office.
G. OIB Plaintiff is an Illinois corruption fighter of over forty (40) years standing, who has successfully exposed and prosecuted corrupt individuals and public officials, including corrupt judges, including as the catalyst for the legendary “Operation Greylord.” Plaintiff has a moral duty to act, as well as a concrete personal interest in exposing the Solo and Solo/Candidate “X” fraud scheme.
3. Legal claim
a. Money laundering is unlawful as a civil offense pursuant to 18 U.S.C. § 1961 (1)(B), § 1964.
b. Money laundering is defined in 18 U.S.C. § 1956 (a) (1)(3) as a transaction designed “in whole or in part” to either “conceal…the source..of specified unlawful activity…” or “to avoid a transaction reporting requirement under State or Federal law.
c. Under Federal law, federal candidates are required to truthfully disclose the actual nature of their disbursements, and not to use pseudonyms or straw men or subterfuges to conceal the source and nature of their financial activity.
d. Had Candidate “X” simply disclosed his or her activity openly, we would not be in Court. Candidate X sought to conceal his or her activity by using “Solo and Solo” as “front men” for “X’s” activity. This pattern of prevarication constituted money laundering.
e. Candidate “X’s” activity constitutes prohibited activity under federal law even though the target of the fraud was an Illinois state agency and other federal candidates such as Plaintiff.
4. Demand for judgment
Plaintiff sues and demands judgment as follows:
a. A judgment that defendants Solo and Solo must disclosure the source of the cash used by one or both of them to purchase copies of candidate petitions from the SBE.
b. Full disclosure as to the manner in which Candidate “X” disbursed funds from his or her campaign account and paid Solo and Solo for their services and related activity.
c. Ancillary money damages in an amount not to exceed $50,000 on all counts, with the total recovery in this action from all defendants limited to $50,000.
d. Such other relief as may be necessary and proper to do complete justice between the parties.
[COUNT TWO]
[DECLARATORY JUDGMENT]
1-2. Plaintiff repeats and realleges Paragraphs 1-2 of Count One and further pleads:
3. Legal claim
a. This Court has jurisdiction pursuant to Lewis, supra, and Levitt, supra, to permit Plaintiff to seek declaratory relief as to his right to full disclosure of the financial activity of Solo and Solo.
b. The controversy between Solo and Solo and candidate “X,” and Plaintiff, meets the requirements for entry of a declaratory judgment pursuant to § 735 ILCS 5/2-701.
4. Demand for judgment
Plaintiff sues and demands a declaratory judgment and injunctive relief as follows:
a. Declaratory judgment that Plaintiff is entitled to the identity of the person who furnished federal campaign cash to Glen/Andrew Solo and the manner in which said funds were disbursed to one or more of these individuals;
b. Ancillary money damages in an amount not to exceed $50,000 on all counts, with the total recovery in this action from all defendants limited to $50,000.
c. Such other relief as may be necessary and proper to do complete justice between the parties.
Dated: November 9, 2009
Verification
Under penalties as provided by law pursuant to Section 1-109 of the Code of Civil procedure, the undersigned certifies that the factual statements set forth in this instrument are true and correct, except as to matters therein stated to be on information and belief and as to such matters the undersigned certifies as aforesaid that he verily believes the same to be true.
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
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