Andy Martin says there should be a “housecleaning” at Republican Party headquarters. Martin says illicit Republican Party support for Mark Kirk has created a toxic situation that will lead the entire ticket to defeat in November, 2010. Martin says he is the best candidate for Senator because his leadership role is being challenged by both extreme right-wing and extreme left-wing Republicans who oppose his candidacy. “I’m the man in the middle,” says Martin. “The real Republican.”
ANDY MARTIN
Republican for U. S. Senator/2010
“He Works for the People of Illinois”
Suite 4406, 30 E. Huron Street
Chicago, IL 60611-4723
Toll-free tel. (866) 706-ANDY
Toll-free fax (866) 707-ANDY
Web site: http://www.AndyforUSSenator.com
E-mail: mailto:AndyforIllinois@aol.com
Please donate:
www.AndyforUSSenator.com
Blogs:
www.AndyforUSSenator.com
www.AndyforUSSenator.blogspot.com
www.AndyforUSSenator.wordpress.com
www.MarkKirk.us
August 22, 2009
Pat Brady
Illinois Republican Chairman
205 W. Randolph Street
Chicago, IL 60606
via fax (312) 201-0181
Dear Pat:
I would like to extend my best wishes on your selection as Chairman of the Illinois Republican Party.
I am sure we are going to have our differences in the days ahead, possibly even strong differences of opinion. But we should be able to disagree on an agreeable basis.
Andy McKenna could never do that. McKenna was unalterably opposed to me. In the end McKenna’s hostility towards me cost him his chairmanship. The “Combine” pulled the plug on McKenna’s embarrassing tactics after he forced me to sue for access to the State Fair and national Voter Vault. The Combine was specifically named in my Sangamon County lawsuit. Five days latter, McKenna was unexpectedly and surprisingly gone.
On Thursday, “Republican Day” at the Illinois State Fair, a circuit judge all-but-referred to Republican leaders as “trailer trash." He called the Party’s management a “trailer park.” Pretty strong words from an otherwise reasonable and mild-mannered judge.
People across the state are noticing the mistreatment I am receiving from the Republican Party leadership, all of which supports Mark Kirk. Voters don’t like the gratuitous abuse inflicted on me one bit. Take it from the judge.
But there is a high compliment in all of the abuse directed at me by Mark Kirk’s supporters and the state party. Kirk’s backers are attacking me because I am the only alternative to Kirk in the primary. While so-called “conservative leaders” fuss and fume on the sidelines, the senate primary is a two-man race between “ultra” left-wing Kirk and "ultra" moderate conservative Martin.
I get jabbed from both sides. The extreme but impotent right met in Bloomington recently, in secret, to choose their “conservative” candidate, because they were afraid their inexperienced patsy would look like an embarrassment next to me.
In other words, Kirk’s supporters and the extreme right were using the same tactics for the same reason: both groups are afraid of my campaign for senator. They know I am neither left nor right. I am a Republican.
Kirk’s extreme left-wing supporters know where the threat to their candidate is coming from. It isn’t coming from “conservative leaders.” It is coming from conservative candidate Andy Martin.
At the County Chairman’s meeting in Springfield, out of the blue and without any provocation on my part, the Party’s resident in-house thug Randy Pollard launched into a diatribe against me. Why? Because Pollard is backing Kirk. And Pollard knows what people across the state know. I am the only real challenger to Kirk.
Kirk’s supporters realize I am the man who can, and probably will, defeat Mark Kirk and bring about the eventual collapse of the Combine. I represent a slightly different version of Peter Fitzgerald, updated for 2010 instead of 1998.
Back to the State Fair. The effort by Republican attorneys (Brian Sheahan, etc.) to have me arrested at the Fair especially disgusted the judge. I stood my ground against McKenna’s weenies such as Sheahan, the police backed off, and the judge ruled in my favor. Not bad work, wouldn’t you agree?
If anyone doubted my legal skills, they got a good demonstration in Springfield. Could Mark Kirk walk into a new courtroom and successfully argue a constitutional claim? He went to law school but no one seriously thinks he could be a lawyer.
Illinoisans are looking for my kind of honesty and openness; Democrats, Republicans and independents crave a real, authentic, tough guy as their U.S. Senator. Someone who can and will stare down the Beltway bad guys, the profiteers, the poseurs on both sides of the political spectrum and the patsies who want to apologize for America's greatness and generosity? Mark Kirk? It’s silly, isn’t it? After ten years in Congress, Kirk is an embarrassment to Republicans.
As a result of the outrageous attacks Kirk’s supporters launched on me I will file an amended complaint naming new defendants and seeking money damages for the disruption I endured. There was no reason for the harassment by party leaders. Nevertheless, those attacks appear to have backfired.
The individuals who were harassing me unwittingly proved my case. They proved that Kirk’s supporters are afraid of Andy Martin, and no one else. The other “candidates” were allowed to march in and babble for a few minutes. I was too much of a threat to Kirk for Pollard & Co to allow me to speak to party “leaders.” Mark Kirk brags that he has fought in “two wars.” He sure acts timid when Andy is in town.
Maybe Kirk didn’t really fight in two wars. Maybe he just imagines he’s a great fighter. In fact, Walter Mitty and Mark Kirk even look alike. Look at the decade old picture he uses on his congressional web site.
When the circuit judge heard what Republican leaders had done to me at the State Fair, at the second court hearing in two days, he denounced the party’s machinations to silence my campaign. Kirk’s de facto lawyer, John Fogarty, was not a happy camper when he left the Sangamon County Courthouse. Just ask him. He was a whipped puppy. Kirk was fuming. Kirk and Fogarty will be even more unhappy when the lawsuit is amended.
You are an experienced lawyer and you know that when a judge sees an attorney reneging on a settlement reached just the day before, the judge will become very angry, very quickly. That’s what happened Thursday.
The Republican Party’s “General” Counsel (another Mark Kirk-style war hero?), Brian Sheahan, is another nitwit lawyer who needs to be replaced. Sheahan appears to have ginned up the efforts to insult the judge. Sheahan helped embarrass the party with his ridiculous “criminal complaint” against me. Great lawyer that Sheahan. And now he wants to be elected to the General Assembly? What a joke.
It is time to clean house at Republican Party headquarters and get rid of all of the phonies, hangers-on and do nothings. Get them off the payroll. No state party employee has yet paid a price for losing. Make them pay for the defeats Republicans have endured over the last two elections.
Likewise, why should I have to sue for access to the Voter Vault? Who made the decision to lock me out? As a new chairman you should throw open the doors to the Voter Vault and admit the mistake in denying me access.
Does anyone really think denying me equal access to the Voter Vault is going to “save” Kirk? Is Kirk really that weak? That endangered? Is Kirk so precious he’s made out of porcelain? (I happen to think Kirk is that weak. Do his supporters secretly agree with me? Good question.)
If you or a representative wants to talk settlement, I am all ears. Otherwise, we will keep pursuing the Party in court.
You know that I am a firm supporter of SB 600. Direct election of the State Central Committee would in time change the party, but most of all direct election would democratize the Party. The manner in which you were appointed just a couple of hours after McKenna’s resignation suffers from a lack of legitimacy, precisely because the people who chose you are not directly accountable to the voters.
Want to make a big difference and start off your leadership with a bang? Let’s do a news conference and announce your support for SB 600. Nothing would give you a bigger boost. And boost party unity as well. The Democrats do just fine under the same procedures as SB 600; why are Republican leaders afraid to face the voters?
I realize that you support my opponent for Senator. I respect your personal right to support whom you wish. That doesn’t mean that you and I can’t work together, even closely together. We can.
If you call on me for assistance, I will be there to help. What’s wrong with having forty years of insight and experience on your side, along with an independent, “contrarian” viewpoint?
Now for Kirk. Here’s the bottom line. If you use party resources to rig the primary and nominate Kirk, no one will support him in November, 2010. [If you want e-mails from Republicans promising this boycott, just ask. We have them. You and I know no one has to prod people to be against Kirk.]
Kirk is political dead meat.
Tell Kirk he is now on his own. Cut him loose.
People are increasingly wondering whether the Combine chose “Clunker Kirk” as a foil to elect their real choice, Giannoulias, senator. It sure looks that way. Kirk is probably headed to where he truly belongs, an appointment in the Obama administration.
Andy McKenna did tremendous damage to Kirk’s fragile candidacy. Every time McKenna would undermine me, I would ratchet up my opposition to Mark. McKenna energized Kirk’s opponents. If you step into McKenna’s shoes and make the IRP offices and SCC a Kirk campaign headquarters, you will not help Kirk.
Biased leadership never endows the beneficiary with legitimacy.
I sincerely believe Kirk’s candidacy is doomed, and I sincerely believe his political strategy is completely misguided. Don’t tie your leadership to Kirk’s campaign. You don’t have to be stuck with him. If Kirk can’t win an open, honest primary, he can’t beat the Democrats. Face the facts.
And don’t be fooled by the so-called pollsters. Who was the presidential frontrunner in 2007? Rudy Giuliani. He didn’t even make it to the first primary. Some pollsters.
I stand ready to help you, in public or private. Just ask.
I am hard worker. I am a tough fighter. I have over forty years of broadcasting and media experience. I am an honest man who believes in helping Americans achieve a better life. I want a militarily and financially secure nation. And I have a proven record of producing positive action and standing up against corruption. Does Mark Kirk have my record? Be real. That’s why Kirk trembles every time he hears my name.
Put me to work on your team as your next United States Senator.
Let’s win this one for the Gipper. And let’s send Obama a message he will never forget.
Best wishes,
ANDY MARTIN
AM:sp
Showing posts with label Voter Vault. Show all posts
Showing posts with label Voter Vault. Show all posts
Sunday, August 23, 2009
Monday, August 17, 2009
Sangamon County Circuit Judge sets emergency hearing in GOP “Voter Vault” case, discrimination by Illinois State Fair
Republican U. S. Senate candidate Andy Martin is fighting discrimination and harassment by corrupt “Combine Republicans” who are seeking to thwart his anti-corruption campaign for the U. S. Senate. Mark Kirk is also named as a defendant because of illegal campaign activity by his campaign supporters.
A Sangamon County Circuit Judge sets an emergency hearing in U. S. Senate candidate Andy Martin’s lawsuit again the Republican National Committee and Illinois State Fair
Martin is also asking a Sangamon County, Illinois court to stop censorship by the Illinois State Fair and harassment by the Republican Party’s leadership
Martin also charges that ‘infanticide” opponent Mark Kirk is violating federal and state election laws
NEWS FROM:
ANDY MARTIN /2010
Republican for U. S. Senator
“He works for
the People of Illinois”
Suite 4406
30 E. Huron Street
Chicago, IL 60611-4723
(312) 440-4124
www.AndyforUSSenator.com
www.AndyforUSSenator.blogspot.com
www.AndyforUSSenator.wordpress.com
www.MarkKirk.us
FOR IMMEDIATE RELEASE:
ATTENTION DAYBOOK/ASSIGNMENT EDITORS
ANNOUNCEMENT OF TUESDAY NEWS CONFERENCE IN CHICAGO
MARK KIRK’S SENATE CAMPAIGN FACES CHARGES OF ILLEGAL CAMPAIGN ACTIVITY IN CONJUNCTION WITH ANDY MCKENNA AND “COMBINE REPUBLICANS”
MARTIN IS ASKING A SANGAMON COUNTY COURT TO ORDER THE RNC TO PERMIT HIM TO ACCESS THE PARTY’S “VOTER VAULT”
MARTIN SAYS THE ILLINOIS STATE FAIR UNLAWFULLY TRIES TO STIFLE DEBATE ON “REPUBLICAN DAY,” AUGUST 20TH
(CHICAGO)(August 17, 2009) A Sangamon County Circuit Judge has set an emergency hearing for Wednesday, August 19th on a lawsuit filed by Republican U. S. Senate candidate Andy Martin against the Illinois State Fair and the Republican National Committee [hearing details below]. Martin has set a Chicago news conference for August 18th to explain his accusations.
Insurgent “Internet Powerhouse” Martin charges that the Republican Party is illegally denying him access to the RNC’s “Voter Vault” to thwart his corruption-fighting campaign for the U. S. Senate. Andy claims the Illinois Republican Party’s leadership is controlled by a corrupt bipartisan “Combine.”
Finally, Martin’s case, filed in Sangamon County Circuit Court, Springfield, Illinois, seeks a court order permitting his protesters at the State Fair’s “Republican Day” to reflect the split in the Illinois Party.
The Circuit Court hearing on Martin’s Verified Motion for a Temporary Restraining Order will lead off two days of conservative Republican Springfield-area demonstrations and confrontation by Martin and his supporters.
Wednesday evening Martin is expected to picket Springfield’s historic Pasfield House Inn where Republicans are meeting; Thursday will involve conflicts over “Republican Day” at the Illinois State Fair. [details to follow] Martin is establishing a “Conservative Fighting Camp” to confront his opponent, “infanticide” Senate candidate Mark Kirk.
"There are two Republican Parties in Illinois,” Martin says. “There are the Republicans who live and work on Main Street; conservatives who are raising families and struggling with the economy. And there is the ‘other’ Republican Party of wealthy business leaders, known as the bipartisan ‘Combine’ of corruption that controls the nominal machinery of the Party through dishonest members of the Republican State Central Committee.
“I represent Main Street Republicans; Mark Kirk is the candidate of the Daley Machine-dominated ‘Combine.’
“I am being harassed for exposing Republican, as well as Democratic, corruption in Illinois. But Republicans cannot win in 2010 by being two-faced about crooked government. Unfortunately National Chairman Michael Steel was elected Chairman with help from the ‘Combine.’
“I asked Steele to open the RNC’s Voter Vault database because the Illinois ‘Combine’ is denying me access. The Voter Vault is supposed to be available to Republican candidates on a nondiscriminatory basis. Steele and his counsel refuse to respond. They are kowtowing to the Combine-controlled faction of the Party.
“Likewise, the Illinois State Fair seeks to limit debate and confrontation on what the Fair calls ‘Republican Day.’ I managed to work out protest procedures with the Chicago Police Department on Chicago’s crowded streets and sidewalks without the need to file a lawsuit. The Illinois State Fair is trying to stifle political dissent on state-owned land. The entire State of Illinois is a racketeer influenced corrupt organization. Even the State Fair.
“As for Mr. Steele, he can blab about ‘reform’ all he wants; as long as he is keeping corruption-fighting candidates from accessing the Voter Vault, he is voting with the Chicago Combine and against the People of Illinois,” Martin charges. “The Voter Vault belongs to Republican candidates nationally; it should not be under the control of the corrupt ‘Combine’ in Illinois.”
Martin’s Verified Motion for a Temporary Restraining Order is posted on the Internet as a separate release.
August 18th Chicago news conference details:
WHO:
U. S. Senate candidate and Internet Powerhouse Andy Martin
WHERE:
Sidewalk news conference, SE corner of Huron and Wabash,
Chicago
WHEN:
Tuesday, August 18, 2009 11:00 A.M.
WHAT:
Internet Powerhouse and U. S. Senate candidate Andy Martin will announce that a Sangamon County Circuit Judge has set an emergency hearing for August 19th on his lawsuit to prevent Michael Steele and the Republican National Committee from discriminatory abuse of the RNC’s “Voter Vault.” Martin’s emergency hearing will also consider claims against the Illinois State Fair. Martin says the Fair unconstitutionally seeks to limit dissent at “Republican Day” on August 20th.
MEDIA
CONTACT:
(866) 706-2639; Cell (917) 664-9329 (not always turned on)
WEBSITE:
http://www.AndyforUSSenator.com
AUGUST 19TH SPRINGFIELD HEARING DETAILS:
JUDGE:
Hon. Patrick W. Kelley, Chief Judge
TIME:
1:00 P.M.
ROOM: Courtroom 7B, 200 S. Ninth Street, Springfield
E-MAIL:
AndyforUSSenator@aol.com-
----------------------------
Readers of Obama: The Man Behind The Mask, say the book is still the only gold standard and practical handbook on Barack Obama's unfitness for the presidency. Buy it.Book orders: Amazon.com or http://OrangeStatePress.com. Immediate shipment from Amazon.com or signed copies (delayed for signing) from the publisher are available.
-----------------------------
URGENT APPEAL: The Committee of One Million to Defeat Barack Obama raises money to oppose President Barack Obama's radical agenda and also to support www.BoycottHawaii.com.www.CommitteeofOneMilliontoDefeatBarackObama.com Please give generously. Our ability to fight and defeat Barack Obama's political agenda is directly dependent on the generosity of every American."The Committee of One Million to Defeat Barack Obama has no bundlers, no fat cats and no illegal contributions. Obama is opposed to almost everything America stands for," says Executive Director Andy Martin. "But while Obama has raised a billion dollar slush fund, his opponents lack sufficient resources. Americans can either contribute now, or pay later. If we do not succeed, Obama will."
-----------------------------
Andy Martin is a legendary Chicago muckraker, author, Internet columnist, radio talk show host, broadcaster and media critic. He has over forty years of broadcasting background in radio and television and is the dean of Illinois media and communications. He is currently promoting his best-selling book, Obama: The Man Behind The Mask and producing the new Internet movie "Obama: The Hawai'i years." Andy is the Executive Editor and publisher of www.ContrarianCommentary.com. Martin comments on regional, national and world events with more than four decades of experience. He holds a Juris Doctor degree from the University of Illinois College of Law and is a former adjunct professor of law at the City University of New York.
UPDATES: www.twitter.com/AndyMartinUSAwww.facebook.com/AndyMartin Andy's columns are also posted at ContrarianCommentary.blogspot.com; contrariancommentary.wordpress.com. [NOTE: We frequently correct typographical errors and additions/subtractions on our blogs, where you can find the latest edition of this release.]
MEDIA CONTACT: (866) 706-2639 or CELL (917) 664-9329 (cell not always on)E-MAIL: AndyMart20@aol.com © Copyright by Andy Martin 2009.
A Sangamon County Circuit Judge sets an emergency hearing in U. S. Senate candidate Andy Martin’s lawsuit again the Republican National Committee and Illinois State Fair
Martin is also asking a Sangamon County, Illinois court to stop censorship by the Illinois State Fair and harassment by the Republican Party’s leadership
Martin also charges that ‘infanticide” opponent Mark Kirk is violating federal and state election laws
NEWS FROM:
ANDY MARTIN /2010
Republican for U. S. Senator
“He works for
the People of Illinois”
Suite 4406
30 E. Huron Street
Chicago, IL 60611-4723
(312) 440-4124
www.AndyforUSSenator.com
www.AndyforUSSenator.blogspot.com
www.AndyforUSSenator.wordpress.com
www.MarkKirk.us
FOR IMMEDIATE RELEASE:
ATTENTION DAYBOOK/ASSIGNMENT EDITORS
ANNOUNCEMENT OF TUESDAY NEWS CONFERENCE IN CHICAGO
MARK KIRK’S SENATE CAMPAIGN FACES CHARGES OF ILLEGAL CAMPAIGN ACTIVITY IN CONJUNCTION WITH ANDY MCKENNA AND “COMBINE REPUBLICANS”
MARTIN IS ASKING A SANGAMON COUNTY COURT TO ORDER THE RNC TO PERMIT HIM TO ACCESS THE PARTY’S “VOTER VAULT”
MARTIN SAYS THE ILLINOIS STATE FAIR UNLAWFULLY TRIES TO STIFLE DEBATE ON “REPUBLICAN DAY,” AUGUST 20TH
(CHICAGO)(August 17, 2009) A Sangamon County Circuit Judge has set an emergency hearing for Wednesday, August 19th on a lawsuit filed by Republican U. S. Senate candidate Andy Martin against the Illinois State Fair and the Republican National Committee [hearing details below]. Martin has set a Chicago news conference for August 18th to explain his accusations.
Insurgent “Internet Powerhouse” Martin charges that the Republican Party is illegally denying him access to the RNC’s “Voter Vault” to thwart his corruption-fighting campaign for the U. S. Senate. Andy claims the Illinois Republican Party’s leadership is controlled by a corrupt bipartisan “Combine.”
Finally, Martin’s case, filed in Sangamon County Circuit Court, Springfield, Illinois, seeks a court order permitting his protesters at the State Fair’s “Republican Day” to reflect the split in the Illinois Party.
The Circuit Court hearing on Martin’s Verified Motion for a Temporary Restraining Order will lead off two days of conservative Republican Springfield-area demonstrations and confrontation by Martin and his supporters.
Wednesday evening Martin is expected to picket Springfield’s historic Pasfield House Inn where Republicans are meeting; Thursday will involve conflicts over “Republican Day” at the Illinois State Fair. [details to follow] Martin is establishing a “Conservative Fighting Camp” to confront his opponent, “infanticide” Senate candidate Mark Kirk.
"There are two Republican Parties in Illinois,” Martin says. “There are the Republicans who live and work on Main Street; conservatives who are raising families and struggling with the economy. And there is the ‘other’ Republican Party of wealthy business leaders, known as the bipartisan ‘Combine’ of corruption that controls the nominal machinery of the Party through dishonest members of the Republican State Central Committee.
“I represent Main Street Republicans; Mark Kirk is the candidate of the Daley Machine-dominated ‘Combine.’
“I am being harassed for exposing Republican, as well as Democratic, corruption in Illinois. But Republicans cannot win in 2010 by being two-faced about crooked government. Unfortunately National Chairman Michael Steel was elected Chairman with help from the ‘Combine.’
“I asked Steele to open the RNC’s Voter Vault database because the Illinois ‘Combine’ is denying me access. The Voter Vault is supposed to be available to Republican candidates on a nondiscriminatory basis. Steele and his counsel refuse to respond. They are kowtowing to the Combine-controlled faction of the Party.
“Likewise, the Illinois State Fair seeks to limit debate and confrontation on what the Fair calls ‘Republican Day.’ I managed to work out protest procedures with the Chicago Police Department on Chicago’s crowded streets and sidewalks without the need to file a lawsuit. The Illinois State Fair is trying to stifle political dissent on state-owned land. The entire State of Illinois is a racketeer influenced corrupt organization. Even the State Fair.
“As for Mr. Steele, he can blab about ‘reform’ all he wants; as long as he is keeping corruption-fighting candidates from accessing the Voter Vault, he is voting with the Chicago Combine and against the People of Illinois,” Martin charges. “The Voter Vault belongs to Republican candidates nationally; it should not be under the control of the corrupt ‘Combine’ in Illinois.”
Martin’s Verified Motion for a Temporary Restraining Order is posted on the Internet as a separate release.
August 18th Chicago news conference details:
WHO:
U. S. Senate candidate and Internet Powerhouse Andy Martin
WHERE:
Sidewalk news conference, SE corner of Huron and Wabash,
Chicago
WHEN:
Tuesday, August 18, 2009 11:00 A.M.
WHAT:
Internet Powerhouse and U. S. Senate candidate Andy Martin will announce that a Sangamon County Circuit Judge has set an emergency hearing for August 19th on his lawsuit to prevent Michael Steele and the Republican National Committee from discriminatory abuse of the RNC’s “Voter Vault.” Martin’s emergency hearing will also consider claims against the Illinois State Fair. Martin says the Fair unconstitutionally seeks to limit dissent at “Republican Day” on August 20th.
MEDIA
CONTACT:
(866) 706-2639; Cell (917) 664-9329 (not always turned on)
WEBSITE:
http://www.AndyforUSSenator.com
AUGUST 19TH SPRINGFIELD HEARING DETAILS:
JUDGE:
Hon. Patrick W. Kelley, Chief Judge
TIME:
1:00 P.M.
ROOM: Courtroom 7B, 200 S. Ninth Street, Springfield
E-MAIL:
AndyforUSSenator@aol.com-
----------------------------
Readers of Obama: The Man Behind The Mask, say the book is still the only gold standard and practical handbook on Barack Obama's unfitness for the presidency. Buy it.Book orders: Amazon.com or http://OrangeStatePress.com. Immediate shipment from Amazon.com or signed copies (delayed for signing) from the publisher are available.
-----------------------------
URGENT APPEAL: The Committee of One Million to Defeat Barack Obama raises money to oppose President Barack Obama's radical agenda and also to support www.BoycottHawaii.com.www.CommitteeofOneMilliontoDefeatBarackObama.com Please give generously. Our ability to fight and defeat Barack Obama's political agenda is directly dependent on the generosity of every American."The Committee of One Million to Defeat Barack Obama has no bundlers, no fat cats and no illegal contributions. Obama is opposed to almost everything America stands for," says Executive Director Andy Martin. "But while Obama has raised a billion dollar slush fund, his opponents lack sufficient resources. Americans can either contribute now, or pay later. If we do not succeed, Obama will."
-----------------------------
Andy Martin is a legendary Chicago muckraker, author, Internet columnist, radio talk show host, broadcaster and media critic. He has over forty years of broadcasting background in radio and television and is the dean of Illinois media and communications. He is currently promoting his best-selling book, Obama: The Man Behind The Mask and producing the new Internet movie "Obama: The Hawai'i years." Andy is the Executive Editor and publisher of www.ContrarianCommentary.com. Martin comments on regional, national and world events with more than four decades of experience. He holds a Juris Doctor degree from the University of Illinois College of Law and is a former adjunct professor of law at the City University of New York.
UPDATES: www.twitter.com/AndyMartinUSAwww.facebook.com/AndyMartin Andy's columns are also posted at ContrarianCommentary.blogspot.com; contrariancommentary.wordpress.com. [NOTE: We frequently correct typographical errors and additions/subtractions on our blogs, where you can find the latest edition of this release.]
MEDIA CONTACT: (866) 706-2639 or CELL (917) 664-9329 (cell not always on)E-MAIL: AndyMart20@aol.com © Copyright by Andy Martin 2009.
Andy Martin’s Verified Motion for a Temporary Restraining Order
Republican U. S. Senate candidate Andy Martin has filed a lawsuit in the Circuit Court of Sangamon County, Springfield, Illinois. This is the full text of his emergency motion seeking to bar illegal practices by “Combine Republicans” and the State Fair.
IN THE CIRCUIT COURT
FOR THE SEVENTH JUDICIAL CIRCUIT OF ILLINOIS
SPRINGFIELD, ILLINOIS
IN CHANCERY
CASE NO. 2009 CH 658
ANDY MARTIN,
Plaintiff,
vs.
MICHAEL STEELE, et al.,
Defendants.
VERIFIED MOTION FOR TEMPORARY RESTRAINING
ORDER AND ORDER TO SHOW CAUSE
The Plaintiff asks this Court to issue two (2) separate orders on an emergency basis: (1) a Temporary Restraining Order (“TRO”) barring the Illinois Department of Agriculture (“Agriculture”) or Illinois State fair (“ISF”) or persons acting under Agriculture/ISF from interfering with Plaintiff’s protests at the Illinois State Fair on August 20, 2009; (2) an Order to Show Cause (“OSC”) directing the Republican Party defendants to show cause why Plaintiff should not be granted access to the Republican National Committee’s (“RNC’s”) Voter Vault (“VV”). The TRO and OSC are independent of each other.
1. Factual allegations
The facts governing each of these issues are set forth in the attached Complaint.
A. With regard to the TRO, plaintiff has been in negotiation with Agriculture, but has been unable to reach a written agreement as to the terms and conditions for Plaintiff’s use of the Illinois State Fair Premises (“ISF”) for “Republican Day.”
B. As to the RNC issues, the VV is made available to Republican candidates. But because of the corruption and hostility of the Illinois Republican Party (“IRP”) to “reform Republicans,” the VV is not being made available to Plaintiff to harass him as a candidate for statewide office.
2. Legal standards
A. The legal standards governing a TRO are straightforward, see Wilson v. Hinsdale Elementary, 349 Ill.App.3rd 243, 810 N.E.2d 637, 642 (Court of Appeals, 2d Dist. 2004).
3. Argument
A. The TRO
a. Plaintiff is not seeking unrestricted access to the State Fair. He is seeking access on a specific day which the ISF has designated as “Republican Day.” Thus, the ISF itself has allowed and invited Republicans to attend. The essence of political parties going back to Jeffersonian days is that parties have factions. Plaintiff represents mainstream Republicans; the defendants represent “Combine” Republicans. The term “Combine” was coined to describe Republicans-cum-Democrats who exercise dictatorial political powers over Illinois government on a continuing basis, all of which power is lubricated with corruption, self-interest and political duplicity.
b. The TRO/ISF claims arise under 42 U.S.C. § 1983. If the ISF is going to specifically host a “Republican Day,” then it must make reasonable accommodations for conflicting factions in the Republican Party.
c. The ISF claims it has established a "protest area" at a great distance from the Director's Lawn, while some Republicans will be allowed to meet at the Director’s Lawn. Protests which are removed from the area of actual conflict are not protests at all; they are meaningless and hollow gestures which reflect unconstitutional abridgement of political speech.
d. Plaintiff was able to resolve a much more complex protest issue with the Chicago Police Department, without the need to file a lawsuit. Chicago’s streets and sidewalks are crowded and congested. But the CPD was able to accommodate Plaintiff. The ISF is sticking rigidly to vague rules which seek to render Plaintiff’s protest nugatory.
e. Likewise, one faction of the Republican Day crowd has already been granted use of sound amplification. Plaintiff only seeks to use his own sound amplification at a reasonable level. The “rules” of the ISF are vague and offer unfettered discretion on the ISF to control "sound devices." A grant of unfettered discretion to a state official is unconstitutional. Once again, the ISF is taking a wooden approach to resolving what should have been resolved without a lawsuit.
B. The OSC
a. The Republican Party (RNC) has crated a database called the VV. The VV is made available to Republican candidates, and has been made available repeatedly to Plaintiff’s political opponents, including defendant Mark Kirk.
b. Making the VV available to only one of a number of candidates may violate federal election law, which bars excessive contributions to a single candidate in a primary election, as well as Illinois election law, which may bar use of state funds for a single federal candidate. In addition, the VV has been made available on an unrestricted basis to Republicans. In the most recent statewide primary Plaintiff received almost 35% of the statewide vote, and carried numerous downstate counties.
c. The RNC defendants are seeking to sabotage Plaintiff’s campaign for federal office, and sabotage the rights of downstate voters in particular to be reached through information contained in the VV. Such action by the defendants is inequitable and unlawful.
C. The legal criteria for relief
a. “Certain and Clearly Ascertainable Right”
The defendants themselves have designated a special day as Republican Day. They have invited Republicans to protest, and then sought to render protest meaningless. Do they suggest there is only “one” Republican voice? Or a monolithic party? That is obviously an unreasonable belief under any circumstances. Having invited “Republicans,” the ISF has to accommodate all Republicans. Likewise, the VV has been made to Plaintiff’s opponents; he has the same right of access as his opponents.
b. “Inadequate remedy at law”
There is no adequate remedy for denial of First Amendment Rights. Likewise, the VV is a massive compendium that has been created to assist candidates such as Plaintiff. Because of the constraints of time and cost, it would be impossible for any candidate to duplicate the VV.
c. Irreparable injury
The issue of irreparable injury given that Plaintiff is a candidate for federal office and seeks to demonstrate on only one day, billed as “Republican Day” by the ISF itself, in the area of the Republican congregation at the Director’s Lawn, cannot seriously be questioned, Cooper v. Rockford Newspapers, 50 Ill.App. 3rd 250, 365 N.E.2d 746, 750 (Court of Appeals, 2d Dist 1995) citing Elrod v. Burns, 427 U.S. 347, 373-374, 96 S. Ct. 2673 (1976).
d. “Likelihood of success”
With all due respect, Plaintiff has an excellent likelihood of succeeding on his claims that (1) the ISF has vague and unconstitutional standards for political speech on specific days when the ISF itself invites political speech by scheduling a “Republican Day” and a separate ”Democratic Day,” Elrod. The actions of the RNC/IRP defendants are arbitrary, capricious and violate the rules of the RNC itself. Plaintiff is an intended beneficiary of the RNC’s rules and procedures for VV access. Plaintiff has complied fully with the VV procedural requirements.
Dated: August 15, 2009
VERIFICATION
Under penalties as provided by law pursuant to Section 1-109 of the Code of Civil procedure, the undersigned certifies that the 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 certified as aforesaid that he verily believes the same to e true.
ANDY MARTIN
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 Margaret L. van Dijk, Esq. by fax to (217) 785-4505, and the remaining pro se defendants at fax numbers known for them, (312) 201-0181 (McKenna, Weis and Illinois Republican Party); (217) 753-4712 (Conrad); (202) 863-8820 (Steele and RNC); (202) 863-8654 (Priebus); (202) 225-0837;
and (847) 940-7143 (Kirk).
ANDY MARTIN
IN THE CIRCUIT COURT
FOR THE SEVENTH JUDICIAL CIRCUIT OF ILLINOIS
SPRINGFIELD, ILLINOIS
IN CHANCERY
CASE NO. 2009 CH 658
ANDY MARTIN,
Plaintiff,
vs.
MICHAEL STEELE, et al.,
Defendants.
VERIFIED MOTION FOR TEMPORARY RESTRAINING
ORDER AND ORDER TO SHOW CAUSE
The Plaintiff asks this Court to issue two (2) separate orders on an emergency basis: (1) a Temporary Restraining Order (“TRO”) barring the Illinois Department of Agriculture (“Agriculture”) or Illinois State fair (“ISF”) or persons acting under Agriculture/ISF from interfering with Plaintiff’s protests at the Illinois State Fair on August 20, 2009; (2) an Order to Show Cause (“OSC”) directing the Republican Party defendants to show cause why Plaintiff should not be granted access to the Republican National Committee’s (“RNC’s”) Voter Vault (“VV”). The TRO and OSC are independent of each other.
1. Factual allegations
The facts governing each of these issues are set forth in the attached Complaint.
A. With regard to the TRO, plaintiff has been in negotiation with Agriculture, but has been unable to reach a written agreement as to the terms and conditions for Plaintiff’s use of the Illinois State Fair Premises (“ISF”) for “Republican Day.”
B. As to the RNC issues, the VV is made available to Republican candidates. But because of the corruption and hostility of the Illinois Republican Party (“IRP”) to “reform Republicans,” the VV is not being made available to Plaintiff to harass him as a candidate for statewide office.
2. Legal standards
A. The legal standards governing a TRO are straightforward, see Wilson v. Hinsdale Elementary, 349 Ill.App.3rd 243, 810 N.E.2d 637, 642 (Court of Appeals, 2d Dist. 2004).
3. Argument
A. The TRO
a. Plaintiff is not seeking unrestricted access to the State Fair. He is seeking access on a specific day which the ISF has designated as “Republican Day.” Thus, the ISF itself has allowed and invited Republicans to attend. The essence of political parties going back to Jeffersonian days is that parties have factions. Plaintiff represents mainstream Republicans; the defendants represent “Combine” Republicans. The term “Combine” was coined to describe Republicans-cum-Democrats who exercise dictatorial political powers over Illinois government on a continuing basis, all of which power is lubricated with corruption, self-interest and political duplicity.
b. The TRO/ISF claims arise under 42 U.S.C. § 1983. If the ISF is going to specifically host a “Republican Day,” then it must make reasonable accommodations for conflicting factions in the Republican Party.
c. The ISF claims it has established a "protest area" at a great distance from the Director's Lawn, while some Republicans will be allowed to meet at the Director’s Lawn. Protests which are removed from the area of actual conflict are not protests at all; they are meaningless and hollow gestures which reflect unconstitutional abridgement of political speech.
d. Plaintiff was able to resolve a much more complex protest issue with the Chicago Police Department, without the need to file a lawsuit. Chicago’s streets and sidewalks are crowded and congested. But the CPD was able to accommodate Plaintiff. The ISF is sticking rigidly to vague rules which seek to render Plaintiff’s protest nugatory.
e. Likewise, one faction of the Republican Day crowd has already been granted use of sound amplification. Plaintiff only seeks to use his own sound amplification at a reasonable level. The “rules” of the ISF are vague and offer unfettered discretion on the ISF to control "sound devices." A grant of unfettered discretion to a state official is unconstitutional. Once again, the ISF is taking a wooden approach to resolving what should have been resolved without a lawsuit.
B. The OSC
a. The Republican Party (RNC) has crated a database called the VV. The VV is made available to Republican candidates, and has been made available repeatedly to Plaintiff’s political opponents, including defendant Mark Kirk.
b. Making the VV available to only one of a number of candidates may violate federal election law, which bars excessive contributions to a single candidate in a primary election, as well as Illinois election law, which may bar use of state funds for a single federal candidate. In addition, the VV has been made available on an unrestricted basis to Republicans. In the most recent statewide primary Plaintiff received almost 35% of the statewide vote, and carried numerous downstate counties.
c. The RNC defendants are seeking to sabotage Plaintiff’s campaign for federal office, and sabotage the rights of downstate voters in particular to be reached through information contained in the VV. Such action by the defendants is inequitable and unlawful.
C. The legal criteria for relief
a. “Certain and Clearly Ascertainable Right”
The defendants themselves have designated a special day as Republican Day. They have invited Republicans to protest, and then sought to render protest meaningless. Do they suggest there is only “one” Republican voice? Or a monolithic party? That is obviously an unreasonable belief under any circumstances. Having invited “Republicans,” the ISF has to accommodate all Republicans. Likewise, the VV has been made to Plaintiff’s opponents; he has the same right of access as his opponents.
b. “Inadequate remedy at law”
There is no adequate remedy for denial of First Amendment Rights. Likewise, the VV is a massive compendium that has been created to assist candidates such as Plaintiff. Because of the constraints of time and cost, it would be impossible for any candidate to duplicate the VV.
c. Irreparable injury
The issue of irreparable injury given that Plaintiff is a candidate for federal office and seeks to demonstrate on only one day, billed as “Republican Day” by the ISF itself, in the area of the Republican congregation at the Director’s Lawn, cannot seriously be questioned, Cooper v. Rockford Newspapers, 50 Ill.App. 3rd 250, 365 N.E.2d 746, 750 (Court of Appeals, 2d Dist 1995) citing Elrod v. Burns, 427 U.S. 347, 373-374, 96 S. Ct. 2673 (1976).
d. “Likelihood of success”
With all due respect, Plaintiff has an excellent likelihood of succeeding on his claims that (1) the ISF has vague and unconstitutional standards for political speech on specific days when the ISF itself invites political speech by scheduling a “Republican Day” and a separate ”Democratic Day,” Elrod. The actions of the RNC/IRP defendants are arbitrary, capricious and violate the rules of the RNC itself. Plaintiff is an intended beneficiary of the RNC’s rules and procedures for VV access. Plaintiff has complied fully with the VV procedural requirements.
Dated: August 15, 2009
VERIFICATION
Under penalties as provided by law pursuant to Section 1-109 of the Code of Civil procedure, the undersigned certifies that the 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 certified as aforesaid that he verily believes the same to e true.
ANDY MARTIN
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 Margaret L. van Dijk, Esq. by fax to (217) 785-4505, and the remaining pro se defendants at fax numbers known for them, (312) 201-0181 (McKenna, Weis and Illinois Republican Party); (217) 753-4712 (Conrad); (202) 863-8820 (Steele and RNC); (202) 863-8654 (Priebus); (202) 225-0837;
and (847) 940-7143 (Kirk).
ANDY MARTIN
Saturday, August 15, 2009
Full text of Illinois lawsuit seeking to open Republican National Committee’s “Voter Vault”
IN THE CIRCUIT COURT
FOR THE SEVENTH JUDICIAL CIRCUIT OF ILLINOIS
SPRINGFIELD, ILLINOIS
IN CHANCERY
CASE NO. 2009 CH 658
ANDY MARTIN,
Plaintiff,
vs.
MICHAEL STEELE,
REINCE PRIEBUS,
REPUBLICAN NATIONAL
COMMITTEE,
ANDY MCKENNA,
CURT CONRAD,
JOE WEISS,
ILLINOIS REPUBLICAN
PARTY
THOMAS E. JENNINGS,
ILLINOIS DEPARTMENT
OF AGRICULTURE,
MARK KIRK,
Defendants.
COMPLAINT
COUNT ONE
[EQUITABLE CLAIM]
1. Jurisdiction and venue
a. This court has general common law jurisdiction of the controversy.
b. Substantially all of the operative activity of the defendants concerning the facts of this lawsuit is centered in Sangamon County.
2. The parties
a. Plaintiff Andy Martin (“Plaintiff”) is a candidate for United States Senator. He is a world-respected Internet publisher and columnist, see e.g. ContrarianCommentary.com. Martin is Illinois’ most durable and independent corruption fighter (see www.AndyMartin.com) and has helped send corrupt politicians and judges to jail.
b. Defendant Michael Steele is the Chairman of the Republican National Committee (“RNC”) and the de facto senior decision-making authority on the RNC’s Voter Vault (“VV”).
c. Reince Priebus is the General Counsel to the RNC and a senior legal authority to Steele.
d. Defendant Republican National Committee is the national organization comprised of representatives from each of the fifty states, including Illinois, which owns the VV and ultimately controls access.
e. Defendant Andy McKenna is the Chairman of the Illinois Republican Party (“IRP”). For the past six (6) years McKenna has made himself an antagonist of Plaintiff by seeking to use and abuse his control over the IRP to harass Plaintiff. McKenna uses stooges such as Tolbert Chisum to manipulate and control pliable members of the IRP.
f. Defendants Curt Conrad and Joe Weiss are employees of the IRP.
g. Defendant Illinois Republican Party is an organization created pursuant to the Illinois Election Code and comprised of indirectly elected “committeemen” from each of Illinois’ congressional districts. The election procedure for the IRP committeemen is created pursuant to state law.
h. Defendant Thomas E. Jennings is the Director of the Illinois State Fair (“ISF”), which is operated by defendant Illinois Department of Agriculture, an Illinois state government agency.
i. Defendant Mark Kirk is a campaign opponent of Plaintiff and is engaged in an active civil, and possibly criminal, conspiracy with defendants Steele, Priebus, McKenna, Conrad and Weiss.
3. Factual allegations
a. The Voter Vault Controversy
A. The RNC has created the VV as a powerful election tool (see, e.g. Appendix pp. 1-6).
B. On or about July 30, 2009 Plaintiff’s representative sought access to the VV. (App. P. 9)
C. On August 5, 2009 Plaintiff sent defendant Conrad a formal request for VV access (App. Pp. 7-8).
D. Defendant Weiss sent Plaintiff a form to complete and Plaintiff completed the form and submitted it to the indicated fax number (App. 10-11).
E. Plaintiff heard nothing from the defendants, and on August 11,2009 defendant Conrad said he would "not be pressured into providing VV access.” (App. 12). VV access, of course, is time-sensitive. Conrad wants to delay Plaintiff’s access indefinitely.
F. On August 11, 2009, in light of Conrad’s intransigence, Plaintiff wrote to defendants Steele and Priebus seeking access. These defendants have not responded and are acting in concert and conspiracy with McKenna, Patrick Brady, and others who are subservient to McKenna.
G. Defendant Kirk is being given access to the VV, thereby conferring a very valuable, exclusive “contribution” to Kirk’s campaign in violation of federal election laws. McKenna seeks to make VV available to Kirk, but not to Plaintiff, to assist Kirk because of the hostility of Republican Party voters to Kirk’s extreme liberalism and support for gun control, infanticide and higher taxes through the Obama administration’s “cap and trade” statute.
b. The “Republican Day” Controversy
A. The ISF promotes a “Republican Day” the ISF.
B. Plaintiff was invited to participate in planning for the ISF and, as requested, sent a representative. (App. P. 16).
C. When Plaintiff’s representative appeared at the ISF on August 13th, Plaintiff has been advised by his representative that defendant Conrad said that Conrad was under orders to refuse to deal with Plaintiff or his representatives. In effect, Conrad invited Plaintiff and his supporters to perform a meaningless and burdensome act by driving to Springfield only to be insulted and turned away.
D. Conrad and McKenna are seeking to illegally use IRP funds to promote Kirk as the party’s candidate, when most Illinois Republicans despise Kirk and want nothing to do with him.
c. The “Illinois State fair” controversy
A. The ISF states that it recognizes the need to exercise constitutional freedom (App. p. 17) but then goes around and renders constitutional freedoms meaningless.
B. Plaintiff seeks to demonstrate in the vicinity of the IRP activity near the Governor's Lawn, not in some remote location.
C. The ISF seeks to quarantine Plaintiff and his supporters in an area which is remote from the Governor’s Lawn, thereby rendering his protest meaningless.
D. The ISF restricts “Broadcasting Devices,” (App. P. 18) but imposes no standards on the allowance of audio amplification. Plaintiff has two megaphones that he wishes to use. He has no idea if they meet criteria, or if written criteria exist at all, for the approval of devices. In effect, while claiming to recognize “protest,” the ISF renders protest virtually impossible through vague or nonexistent standards and coerced “demonstration” in remote areas having no connection to the targets of the actual protests.
4. Legal claim
a. The actions of the defendants are inequitable.
b. The Court has broad equitable powers to fashion equitable remedies directing the defendants to provide VV access to Plaintiff as well as barring secret support for Kirk.
5. Demand for judgment
a. Plaintiff seeks money damages as the Court or a jury may impose.
b. Plaintiff seeks any and all declaratory and equitable relief to which he may be entitled.
COUNT TWO
[CIVIL RIGHTS CONSPIRACY]
1-3. Plaintiff repeats and realleges ¶¶ 1-3 of Count One and further pleads:
4. Legal claim
a. The Illinois State Central Committee, also known as the IRP, is created under Illinois State law and is thereby a de facto state actor.
b. McKenna is using the IRP to contribute money indirectly to Kirk through behind-the-scenes assistance which is available to Kirk but not to Plaintiff.
c. McKenna’s conduct and Kirk’s conduct amounts to a conspiracy to violate the Illinois and United States Constitutions, and to rig a primary election with clandestine financial and operational support.
COUNT THREE
[FIRST AMENDMENT]
1-3. Plaintiff repeats and realleges ¶¶ 1-3 of Count One and further pleads:
4. Legal claim
a. The ISF’s restrictions on devices violate the First Amendment. Likewise the ISF’s restrictions on locations where protesters may gather, which are normally in the same vicinity as their opponents but which the ISF seeks to relegate to remote areas, render the First Amendment rights of the plaintiff on Illinois state property meaningless.
b. Plaintiff seeks to demonstrate in the vicinity of the Governor’s Lawn using megaphones and asks the Court to strike down the ISF’s restrictions on peaceful protests as overly broad and vague.
5. Demand for Judgment
Plaintiff seeks declaratory and injunctive relief striking down the ISF’s restrictions on the location of speech, and the manner in which speech may be communicated (through ”devices”).
COUNT FOUR
[PRIMA FACIE TORT]
1-3. Plaintiff repeats and realleges ¶¶ 1-3 of Count One and further pleads:
4. Legal claim
a. Illinois courts have adopted the concept of prima facie tort, see Pendleton v. Time, Inc., 339 Ill.App. 188, 89 N.E.2d 435 (Ill.App. 1st Dist. 1949) as originally recognized in Advance Music v. American Tobacco, 183 Misc. 855, 51 N.Y.S. 692, aff’d 296 N.Y. 79, 70 N.E.2d 401 (N.Y.).
b. The defendants’ ongoing activity is a classic case of prima face tort, because their activity would otherwise be legal and is characterized by a desire to retaliate against, and gratuitously injure and destroy plaintiff because of his honesty, integrity and reform political activity.
5. Demand for Judgment
a. Plaintiff seeks the same relief as sought in Count One.
DATED: August 13, 2009
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
FOR THE SEVENTH JUDICIAL CIRCUIT OF ILLINOIS
SPRINGFIELD, ILLINOIS
IN CHANCERY
CASE NO. 2009 CH 658
ANDY MARTIN,
Plaintiff,
vs.
MICHAEL STEELE,
REINCE PRIEBUS,
REPUBLICAN NATIONAL
COMMITTEE,
ANDY MCKENNA,
CURT CONRAD,
JOE WEISS,
ILLINOIS REPUBLICAN
PARTY
THOMAS E. JENNINGS,
ILLINOIS DEPARTMENT
OF AGRICULTURE,
MARK KIRK,
Defendants.
COMPLAINT
COUNT ONE
[EQUITABLE CLAIM]
1. Jurisdiction and venue
a. This court has general common law jurisdiction of the controversy.
b. Substantially all of the operative activity of the defendants concerning the facts of this lawsuit is centered in Sangamon County.
2. The parties
a. Plaintiff Andy Martin (“Plaintiff”) is a candidate for United States Senator. He is a world-respected Internet publisher and columnist, see e.g. ContrarianCommentary.com. Martin is Illinois’ most durable and independent corruption fighter (see www.AndyMartin.com) and has helped send corrupt politicians and judges to jail.
b. Defendant Michael Steele is the Chairman of the Republican National Committee (“RNC”) and the de facto senior decision-making authority on the RNC’s Voter Vault (“VV”).
c. Reince Priebus is the General Counsel to the RNC and a senior legal authority to Steele.
d. Defendant Republican National Committee is the national organization comprised of representatives from each of the fifty states, including Illinois, which owns the VV and ultimately controls access.
e. Defendant Andy McKenna is the Chairman of the Illinois Republican Party (“IRP”). For the past six (6) years McKenna has made himself an antagonist of Plaintiff by seeking to use and abuse his control over the IRP to harass Plaintiff. McKenna uses stooges such as Tolbert Chisum to manipulate and control pliable members of the IRP.
f. Defendants Curt Conrad and Joe Weiss are employees of the IRP.
g. Defendant Illinois Republican Party is an organization created pursuant to the Illinois Election Code and comprised of indirectly elected “committeemen” from each of Illinois’ congressional districts. The election procedure for the IRP committeemen is created pursuant to state law.
h. Defendant Thomas E. Jennings is the Director of the Illinois State Fair (“ISF”), which is operated by defendant Illinois Department of Agriculture, an Illinois state government agency.
i. Defendant Mark Kirk is a campaign opponent of Plaintiff and is engaged in an active civil, and possibly criminal, conspiracy with defendants Steele, Priebus, McKenna, Conrad and Weiss.
3. Factual allegations
a. The Voter Vault Controversy
A. The RNC has created the VV as a powerful election tool (see, e.g. Appendix pp. 1-6).
B. On or about July 30, 2009 Plaintiff’s representative sought access to the VV. (App. P. 9)
C. On August 5, 2009 Plaintiff sent defendant Conrad a formal request for VV access (App. Pp. 7-8).
D. Defendant Weiss sent Plaintiff a form to complete and Plaintiff completed the form and submitted it to the indicated fax number (App. 10-11).
E. Plaintiff heard nothing from the defendants, and on August 11,2009 defendant Conrad said he would "not be pressured into providing VV access.” (App. 12). VV access, of course, is time-sensitive. Conrad wants to delay Plaintiff’s access indefinitely.
F. On August 11, 2009, in light of Conrad’s intransigence, Plaintiff wrote to defendants Steele and Priebus seeking access. These defendants have not responded and are acting in concert and conspiracy with McKenna, Patrick Brady, and others who are subservient to McKenna.
G. Defendant Kirk is being given access to the VV, thereby conferring a very valuable, exclusive “contribution” to Kirk’s campaign in violation of federal election laws. McKenna seeks to make VV available to Kirk, but not to Plaintiff, to assist Kirk because of the hostility of Republican Party voters to Kirk’s extreme liberalism and support for gun control, infanticide and higher taxes through the Obama administration’s “cap and trade” statute.
b. The “Republican Day” Controversy
A. The ISF promotes a “Republican Day” the ISF.
B. Plaintiff was invited to participate in planning for the ISF and, as requested, sent a representative. (App. P. 16).
C. When Plaintiff’s representative appeared at the ISF on August 13th, Plaintiff has been advised by his representative that defendant Conrad said that Conrad was under orders to refuse to deal with Plaintiff or his representatives. In effect, Conrad invited Plaintiff and his supporters to perform a meaningless and burdensome act by driving to Springfield only to be insulted and turned away.
D. Conrad and McKenna are seeking to illegally use IRP funds to promote Kirk as the party’s candidate, when most Illinois Republicans despise Kirk and want nothing to do with him.
c. The “Illinois State fair” controversy
A. The ISF states that it recognizes the need to exercise constitutional freedom (App. p. 17) but then goes around and renders constitutional freedoms meaningless.
B. Plaintiff seeks to demonstrate in the vicinity of the IRP activity near the Governor's Lawn, not in some remote location.
C. The ISF seeks to quarantine Plaintiff and his supporters in an area which is remote from the Governor’s Lawn, thereby rendering his protest meaningless.
D. The ISF restricts “Broadcasting Devices,” (App. P. 18) but imposes no standards on the allowance of audio amplification. Plaintiff has two megaphones that he wishes to use. He has no idea if they meet criteria, or if written criteria exist at all, for the approval of devices. In effect, while claiming to recognize “protest,” the ISF renders protest virtually impossible through vague or nonexistent standards and coerced “demonstration” in remote areas having no connection to the targets of the actual protests.
4. Legal claim
a. The actions of the defendants are inequitable.
b. The Court has broad equitable powers to fashion equitable remedies directing the defendants to provide VV access to Plaintiff as well as barring secret support for Kirk.
5. Demand for judgment
a. Plaintiff seeks money damages as the Court or a jury may impose.
b. Plaintiff seeks any and all declaratory and equitable relief to which he may be entitled.
COUNT TWO
[CIVIL RIGHTS CONSPIRACY]
1-3. Plaintiff repeats and realleges ¶¶ 1-3 of Count One and further pleads:
4. Legal claim
a. The Illinois State Central Committee, also known as the IRP, is created under Illinois State law and is thereby a de facto state actor.
b. McKenna is using the IRP to contribute money indirectly to Kirk through behind-the-scenes assistance which is available to Kirk but not to Plaintiff.
c. McKenna’s conduct and Kirk’s conduct amounts to a conspiracy to violate the Illinois and United States Constitutions, and to rig a primary election with clandestine financial and operational support.
COUNT THREE
[FIRST AMENDMENT]
1-3. Plaintiff repeats and realleges ¶¶ 1-3 of Count One and further pleads:
4. Legal claim
a. The ISF’s restrictions on devices violate the First Amendment. Likewise the ISF’s restrictions on locations where protesters may gather, which are normally in the same vicinity as their opponents but which the ISF seeks to relegate to remote areas, render the First Amendment rights of the plaintiff on Illinois state property meaningless.
b. Plaintiff seeks to demonstrate in the vicinity of the Governor’s Lawn using megaphones and asks the Court to strike down the ISF’s restrictions on peaceful protests as overly broad and vague.
5. Demand for Judgment
Plaintiff seeks declaratory and injunctive relief striking down the ISF’s restrictions on the location of speech, and the manner in which speech may be communicated (through ”devices”).
COUNT FOUR
[PRIMA FACIE TORT]
1-3. Plaintiff repeats and realleges ¶¶ 1-3 of Count One and further pleads:
4. Legal claim
a. Illinois courts have adopted the concept of prima facie tort, see Pendleton v. Time, Inc., 339 Ill.App. 188, 89 N.E.2d 435 (Ill.App. 1st Dist. 1949) as originally recognized in Advance Music v. American Tobacco, 183 Misc. 855, 51 N.Y.S. 692, aff’d 296 N.Y. 79, 70 N.E.2d 401 (N.Y.).
b. The defendants’ ongoing activity is a classic case of prima face tort, because their activity would otherwise be legal and is characterized by a desire to retaliate against, and gratuitously injure and destroy plaintiff because of his honesty, integrity and reform political activity.
5. Demand for Judgment
a. Plaintiff seeks the same relief as sought in Count One.
DATED: August 13, 2009
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
U. S. Senate candidate Andy Martin sues Republican National Committee to open “Voter Vault”
Civil action filed by U. S. Senate candidate Andy Martin also says Illinois State Fair seeks to stifle dissent
U. S. Senate candidate Andy Martin sues the Republican National Committee for access to the Party’s “Voter Vault”
Martin is also asking a Sangamon County, Illinois court to stop censorship by the Illinois State Fair.
NEWS FROM:
ANDY MARTIN /2010
Republican for U. S. Senator
“He works for
the People of Illinois”
Suite 4406
30 E. Huron Street
Chicago, IL 60611-4723
(312) 440-4124
www.AndyforUSSenator.com
www.AndyforUSSenator.blogspot.com
www.AndyforUSSenator.wordpress.com
www.MarkKirk.us
FOR IMMEDIATE RELEASE:
ATTENTION DAYBOOK/ASSIGNMENT EDITORS
ANNOUNCEMENT OF SATURDAY NEWS CONFERENCE IN CHICAGO
ANDY MARTIN SAYS THE REPUBLICAN NATIONAL COMMITTEE IS INFLUENCED BY THE CORRUPT CHICAGO “COMBINE”
MARTINIS ASKING A SANGAMON COUNTY COURT TO ORDER THE RNC TO PERMIT HIM TO ACCESS THE PARTY’S “VOTER VAULT”
MARTIN SAYS THE ILLINOIS STATE FAIR UNLAWFULLY TRIES TO STIFLE DEBATE ON “REPUBLICAN DAY,” AUGUST 20TH
(CHICAGO)(August 15, 2009) Republican National Committee Chairman Michael Steele usually has a hard time keeping his mouth closed. Now he has been sued for improperly keeping the party’s “Voter Vault” locked shut.
Republican U. S. Senate candidate and insurgent “Internet Powerhouse” Andy Martin will hold a Chicago news conference Saturday, August 15th to announce that he has sued the Republican Party for illegally denying access to the RNC’s “Voter Vault” to his corruption-fighting campaign for the U. S. Senate. Martin’s lawsuit also names as defendants the Illinois Republican Party and details a series of improper acts by party officials.
Finally, Martin’s case, filed in Sangamon County Circuit Court, Springfield, Illinois, seeks a court order permitting protests at the State fair’s “Republican Day” to reflect the split in the Illinois Party.
"There are two Republican Parties in Illinois,” Martin says. “There are the Republicans who live and work on Main Street. Then there is the ‘other’ Republican Party of wealthy business leaders, known as the bipartisan ‘Combine’ of corruption that controls the nominal machinery of the Party through dishonest members of the State Central Committee.
“I represent Main Street Republicans; Mark Kirk is the candidate of the Daley Machine-dominated ‘Combine.’
“I am being harassed for exposing Republican, as well as Democratic, corruption in Illinois. But Republicans cannot win in 2010 by being two-faced about corruption. Michael Steel was elected Chairman with help from the ‘Combine.’
“I asked Steele for access to the RNC’s Voter Vault database because the Illinois ‘Combine’ is denying me access. The Voter Vault is supposed to be available to Republican candidates on a nondiscriminatory basis. Steele and his counsel refuse to answer. They are bowing down to the Combine-controlled faction of the Party.
“Likewise, the Illinois State Fair seeks to limit debate and confrontation on what the Fair calls ‘Republican Day.’ I managed to work out protest procedures with the Chicago Police Department on Chicago’s crowded streets and sidewalks, without the need to file a lawsuit. The Illinois State Fair is trying to stifle political dissent on state-owned land.
“What’s wrong with this picture? The entire State of Illinois is a racketeer influenced corrupt enterprise. Even the State Fair.
“As for Mr. Steele, he can blab about ‘reform’ all he wants; as long as he is keeping corruption-fighting candidates from accessing the Voter Vault, he is voting with the Chicago Combine and against the People of Illinois,” Martin will state. “The Voter Vault belongs to Republican candidates nationally; it should not be under the control of the corrupt ‘Combine’ in Illinois.”
Martin’s lawsuit is posted on the web as a separate release.
August 15th news conference details:
WHO:
U. S. Senate candidate and Internet Powerhouse Andy Martin
WHERE:
Sidewalk news conference, SE corner of Huron and Wabash,
Chicago
WHEN:
Saturday, August 15, 2009 3:00 P.M.
WHAT:
Internet Powerhouse and U. S. Senate candidate Andy Martin sued Michael Steele to force the Republican National Committee to stop discriminatory abuse of the RNC’s “Voter Vault.” Martin also joined the Illinois State Fair in his lawsuit, because the Fair seeks to limit dissent at “Republican Day” on August 20th.
MEDIA
CONTACT:
(866) 706-2639; Cell (917) 664-9329 (not always turned on)
WEBSITE:
http://www.AndyforUSSenator.com
E-MAIL:
AndyforUSSenator@aol.com
-----------------------------
Readers of Obama: The Man Behind The Mask, say the book is still the only gold standard and practical handbook on Barack Obama's unfitness for the presidency. Buy it.Book orders: Amazon.com or http://OrangeStatePress.com. Immediate shipment from Amazon.com or signed copies (delayed for signing) from the publisher are available.
-----------------------------
URGENT APPEAL: The Committee of One Million to Defeat Barack Obama raises money to oppose President Barack Obama's radical agenda and also to support www.BoycottHawaii.com.www.CommitteeofOneMilliontoDefeatBarackObama.com Please give generously. Our ability to fight and defeat Barack Obama's political agenda is directly dependent on the generosity of every American."The Committee of One Million to Defeat Barack Obama has no bundlers, no fat cats and no illegal contributions. Obama is opposed to almost everything America stands for," says Executive Director Andy Martin. "But while Obama has raised a billion dollar slush fund, his opponents lack sufficient resources. Americans can either contribute now, or pay later. If we do not succeed, Obama will."
-----------------------------
Andy Martin is a legendary Chicago muckraker, author, Internet columnist, radio talk show host, broadcaster and media critic. He has over forty years of broadcasting background in radio and television and is the dean of Illinois media and communications. He is currently promoting his best-selling book, Obama: The Man Behind The Mask and producing the new Internet movie "Obama: The Hawai'i years." Andy is the Executive Editor and publisher of www.ContrarianCommentary.com. Martin comments on regional, national and world events with more than four decades of experience. He holds a Juris Doctor degree from the University of Illinois College of Law and is a former adjunct professor of law at the City University of New York.
UPDATES: www.twitter.com/AndyMartinUSAwww.facebook.com/AndyMartin Andy's columns are also posted at ContrarianCommentary.blogspot.com; contrariancommentary.wordpress.com. [NOTE: We frequently correct typographical errors and additions/subtractions on our blogs, where you can find the latest edition of this release.]
MEDIA CONTACT: (866) 706-2639 or CELL (917) 664-9329 (cell not always on)E-MAIL: AndyMart20@aol.com © Copyright by Andy Martin 2009.
U. S. Senate candidate Andy Martin sues the Republican National Committee for access to the Party’s “Voter Vault”
Martin is also asking a Sangamon County, Illinois court to stop censorship by the Illinois State Fair.
NEWS FROM:
ANDY MARTIN /2010
Republican for U. S. Senator
“He works for
the People of Illinois”
Suite 4406
30 E. Huron Street
Chicago, IL 60611-4723
(312) 440-4124
www.AndyforUSSenator.com
www.AndyforUSSenator.blogspot.com
www.AndyforUSSenator.wordpress.com
www.MarkKirk.us
FOR IMMEDIATE RELEASE:
ATTENTION DAYBOOK/ASSIGNMENT EDITORS
ANNOUNCEMENT OF SATURDAY NEWS CONFERENCE IN CHICAGO
ANDY MARTIN SAYS THE REPUBLICAN NATIONAL COMMITTEE IS INFLUENCED BY THE CORRUPT CHICAGO “COMBINE”
MARTINIS ASKING A SANGAMON COUNTY COURT TO ORDER THE RNC TO PERMIT HIM TO ACCESS THE PARTY’S “VOTER VAULT”
MARTIN SAYS THE ILLINOIS STATE FAIR UNLAWFULLY TRIES TO STIFLE DEBATE ON “REPUBLICAN DAY,” AUGUST 20TH
(CHICAGO)(August 15, 2009) Republican National Committee Chairman Michael Steele usually has a hard time keeping his mouth closed. Now he has been sued for improperly keeping the party’s “Voter Vault” locked shut.
Republican U. S. Senate candidate and insurgent “Internet Powerhouse” Andy Martin will hold a Chicago news conference Saturday, August 15th to announce that he has sued the Republican Party for illegally denying access to the RNC’s “Voter Vault” to his corruption-fighting campaign for the U. S. Senate. Martin’s lawsuit also names as defendants the Illinois Republican Party and details a series of improper acts by party officials.
Finally, Martin’s case, filed in Sangamon County Circuit Court, Springfield, Illinois, seeks a court order permitting protests at the State fair’s “Republican Day” to reflect the split in the Illinois Party.
"There are two Republican Parties in Illinois,” Martin says. “There are the Republicans who live and work on Main Street. Then there is the ‘other’ Republican Party of wealthy business leaders, known as the bipartisan ‘Combine’ of corruption that controls the nominal machinery of the Party through dishonest members of the State Central Committee.
“I represent Main Street Republicans; Mark Kirk is the candidate of the Daley Machine-dominated ‘Combine.’
“I am being harassed for exposing Republican, as well as Democratic, corruption in Illinois. But Republicans cannot win in 2010 by being two-faced about corruption. Michael Steel was elected Chairman with help from the ‘Combine.’
“I asked Steele for access to the RNC’s Voter Vault database because the Illinois ‘Combine’ is denying me access. The Voter Vault is supposed to be available to Republican candidates on a nondiscriminatory basis. Steele and his counsel refuse to answer. They are bowing down to the Combine-controlled faction of the Party.
“Likewise, the Illinois State Fair seeks to limit debate and confrontation on what the Fair calls ‘Republican Day.’ I managed to work out protest procedures with the Chicago Police Department on Chicago’s crowded streets and sidewalks, without the need to file a lawsuit. The Illinois State Fair is trying to stifle political dissent on state-owned land.
“What’s wrong with this picture? The entire State of Illinois is a racketeer influenced corrupt enterprise. Even the State Fair.
“As for Mr. Steele, he can blab about ‘reform’ all he wants; as long as he is keeping corruption-fighting candidates from accessing the Voter Vault, he is voting with the Chicago Combine and against the People of Illinois,” Martin will state. “The Voter Vault belongs to Republican candidates nationally; it should not be under the control of the corrupt ‘Combine’ in Illinois.”
Martin’s lawsuit is posted on the web as a separate release.
August 15th news conference details:
WHO:
U. S. Senate candidate and Internet Powerhouse Andy Martin
WHERE:
Sidewalk news conference, SE corner of Huron and Wabash,
Chicago
WHEN:
Saturday, August 15, 2009 3:00 P.M.
WHAT:
Internet Powerhouse and U. S. Senate candidate Andy Martin sued Michael Steele to force the Republican National Committee to stop discriminatory abuse of the RNC’s “Voter Vault.” Martin also joined the Illinois State Fair in his lawsuit, because the Fair seeks to limit dissent at “Republican Day” on August 20th.
MEDIA
CONTACT:
(866) 706-2639; Cell (917) 664-9329 (not always turned on)
WEBSITE:
http://www.AndyforUSSenator.com
E-MAIL:
AndyforUSSenator@aol.com
-----------------------------
Readers of Obama: The Man Behind The Mask, say the book is still the only gold standard and practical handbook on Barack Obama's unfitness for the presidency. Buy it.Book orders: Amazon.com or http://OrangeStatePress.com. Immediate shipment from Amazon.com or signed copies (delayed for signing) from the publisher are available.
-----------------------------
URGENT APPEAL: The Committee of One Million to Defeat Barack Obama raises money to oppose President Barack Obama's radical agenda and also to support www.BoycottHawaii.com.www.CommitteeofOneMilliontoDefeatBarackObama.com Please give generously. Our ability to fight and defeat Barack Obama's political agenda is directly dependent on the generosity of every American."The Committee of One Million to Defeat Barack Obama has no bundlers, no fat cats and no illegal contributions. Obama is opposed to almost everything America stands for," says Executive Director Andy Martin. "But while Obama has raised a billion dollar slush fund, his opponents lack sufficient resources. Americans can either contribute now, or pay later. If we do not succeed, Obama will."
-----------------------------
Andy Martin is a legendary Chicago muckraker, author, Internet columnist, radio talk show host, broadcaster and media critic. He has over forty years of broadcasting background in radio and television and is the dean of Illinois media and communications. He is currently promoting his best-selling book, Obama: The Man Behind The Mask and producing the new Internet movie "Obama: The Hawai'i years." Andy is the Executive Editor and publisher of www.ContrarianCommentary.com. Martin comments on regional, national and world events with more than four decades of experience. He holds a Juris Doctor degree from the University of Illinois College of Law and is a former adjunct professor of law at the City University of New York.
UPDATES: www.twitter.com/AndyMartinUSAwww.facebook.com/AndyMartin Andy's columns are also posted at ContrarianCommentary.blogspot.com; contrariancommentary.wordpress.com. [NOTE: We frequently correct typographical errors and additions/subtractions on our blogs, where you can find the latest edition of this release.]
MEDIA CONTACT: (866) 706-2639 or CELL (917) 664-9329 (cell not always on)E-MAIL: AndyMart20@aol.com © Copyright by Andy Martin 2009.
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