Queens Gop Osc

7/27/2019 Queens Gop Osc

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SUPRflv1E COURT: STATE OF ~ E W YORKCOC:'\TY Or QlJEF'.'JS

- - - - - - - - - ~ - - ~ - - - - - - ~ - - - - - - - - - - - - - - - - - - - - - - - - ~ ~ROBHRT TCRXER ET AL/>'IiI i 17('}'.\',

-({gains!-

~ [/JF, QC EEN.'i' couvn R ~ P U B I J ( ':1.\' ( '(),\f\f 'JTfl,'~ v l . \ ' D PHJL!I' RACl SA C! : tfR. /:"/ , 1/,~ - Re .'fN111de111s .~ -um/-

THE BOARD OF ELU 'TJ01'S !.VTHE CITY OF NEl-V >"ORK. r.:I. al.. /fr.,po11denl .

- - - - - - - - - - - - - - - - - - ~ ~ - - - - - - - - - - - - ~ - - - - - - - - -ST A TE Of NEW YORK )COlJNTYOF QUEENS ) ss.:,...._

A TTOR/\'El'S AFF/RMA T/OlV,fl,1ERGENCYAPPLIC4 TIONELECTION LAW MA TTt.'R!NLJE.\'.\'O: ),f>J-'I/ ~ 0 1 3

r. ')t1}- - ~ . ' 7 r I - I O M A S V. O G N I B E ~ E . nn attorney at la\\ duly admitted to practice before the Cou11 s of t i l l'

- ~ - N e w York affirms under penalty of per:jury as l'ollows:[ J . _, - .'

~ j ~ c u . . _ ,......That the above application is on behall'ofthe petitioners hereinC i ~ ~ ? f - : - I .._The underlying action is pursuant to the New York State Election Law and the last


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, . . .. _

---------- -- -- !n the \'latter of the Application ot '

. A T ~ A TERl'v1 OFT--&ts""l"Jt>R ;-v1 Ec0URT () rTHE STATE OF NEW \'ORK.COUNTY OF Q U E E ~ S ,LOCATED AT 88-11SUTPI 1!N BOULEv'ARD.JAMAICA NY, ON THE 4THDAY OF OC'TOBFR, 20 l '3

.l.S .C.x- - -ROBERT. TURNER, JOAN VOGT, 1\NTHONY \IUNZ!ATO, BARTHAGGERTY, JOSEPH Kl\SPER, JANICE BAR, MARGARET OGNIBE\E.JOANN ARIOLA, EDWARD O'HARF, 1\1!\NLJEL CARUANA. JOSEPHMAGNUS and AMY HOLDEN

Petitio:1ers,-against-....

THE QLEENS COUNTY REPUBLICA?\: COMMITTEEandPHILIP RAGUSA, CHAIR,

INDIVIDUALLY AND AS ALLEGED CHAIR

NO MO'lt'1c0N ~FU.Ji4liN

~ W J ' M J ! t i ' fORDER TOSHOWCAUSE

iF EACH OF THE QUEENS COUNTY REPUBLICANCOMMITTEE AND EXECUTIVE COMMITTEE OFTHE QUEENS COUNTY REPUBLICAN CO'.\ll'.\llITTEE INDEX

'1 : c-:: .-- 11 I 1 , ~ o . 10 ":) 1-. ) I f -)'I -and

STEPHANlE ZGALJ!ClNDlVlDUALL Y AND AS ALLEGED SECRETARY AND MEMBER OF THEQlJEENS COUNTY REPUBLICAN COMMITTEE AND THE EXECUTlVECOMMITTEE OF THE QUEENS COUNTY REPUBLIC AN COMMITTEE,and

ROBERT V. BELTRANI, JAMES MCCLELLA!'-;D, ANTHONY CAROLLO,NATAUE DUBOVICI, DEBORAH A. HEINICHEN, MARIE LYNCH, PHILIPT. SICA, JUDITH STUPP, ROBERT HORNAK, SAMIHA MAKA WI ,STEPHEN MORENA, ROSEMARIE A. IACOVONE, JASMINE O\VENS.lV1ELISSA CASTANEDA, RUBY K. MUHAMMED, ANITA BAUMANN.PETER SUTICH, JOSEPH DUBOWSKI, TIMOTHY FUREY, MICHAELHARRIS, PHILIP T. SICA, CECILIA WALSH, PIERRE ALCANTARA,


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I

PATRICK R. GALLAGHER, SERPHI"\! R. MALTESE, ROJ.AINE ANTIO:


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c i r c ~ e r of this court should not be nrnde and entered pursuant to i\niclcs fwo andSixtei:n cf Election Law and Sccti(ln ! J of the C:iencrnl Associatilm Lm\:

: . Invalidating the Organizational Meeti11g and Eledion o C u i T i c ~ r s and: mal id2ting the Certificate or Election officers and minll!L'S attached theretopurportedly filed Vlith respondent Board or Flcctions in the City of New York and\:ew York State Elections of the September 27, 20 I3 Respondent Queens CountyRepubiican Committee meeting and requiring the Respondent Ragusa to con,ene anew meeting to properly organize the R e s p o n d ~ n t Committee, and2. Ai lowing oniy those Committeemen and Comrnittec\\'omen elected at theSeptember l 01h, 20 ! 3 Prirnmy Elcctit'll to \'ote for the Officers of said RespondentCornmittee, and;3. Allov,ing for Proxy voting as permitted in the Rules of the RespondentCommittee currentiy on file \.villi the l\ew York State Board of Elections and the

~ C \ ' v York City Board of Elections \'vith instructions. without deadline, up to andincluding the time of the meeting and \\'ithout interference from the respondentRagusa and any of his appointees or agents and;.+. Ai lowing for all duly elected members of' the County Committee to carryproxies of any other duly elected County Committee member. and;.'." . Appointing a Special Master or Court Monitor and Court Stenographer toO\ ersee and record the proceeding of the OrgnninHional \/Jeering of theRespondent County Committee :Yleeting, including, but not limited to, thecredentiaiing of the Committee Members and the voting for the Officers of theRespondent County Committee at the Orgunizntional Meeting, and After themeeltng, take possession of all of the proxies documents and records of saidmeeting, and:


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6. Allowing all duly elected members Lo attend the meeting, in person or byproxy including requiring that the ( ) r g a n i 1 . . ~ n i o n n l \ 'kcting be held in a hall, roomor facilitv large enow2h to accommodate the entire duly elected Committee\\ ith,sufficient parking for the '.V1ernbt:rs nf said Committee. and;. '-7. To require the purportedly elected Respondent Rap.usa Committee to givethe ~ t t o m e y for the Petitioners' a complete list, including the names and addresses.of z:ll of the officers. executive comrnittcc members, sub-committee members, andother persons, elected or appointed at the meeLing or serving in any capacity forthe Respondent Queens County Repuhlicrrn Committee, and:8. Requiring the Respondent Ragusa, in his c1pacity as the functus-officio chuirto prior to caliing the Orgunizational Meeting to order to provide to the Petitioners'attorney a list of all scaff people to be present at the meeting, whether inside oroutside the building, their exact function and purpose, including and not limited tocredentialing, tallying of votes and security, their compensation, it' any. and theperson or entity paying same, and;9. Requiring the Respondent Rsgusa, in his capacity as the funcLus- officiochair prior to ca!iing the Organizational Mcding to order to provide to Petitioners'a representative or representatives on the credentials committee thereof, and arepresentative or representatives ~ : i r n o n g the vote tellers at the rneeting(s) \Vho shallh2ve the right to attend all proceedings ol' said committees and \Vho shall beprovided with all documents considered hy said committees as well as access to thecounting of votes ,,_hether by roll or proxy, and;l0. Permitting the Petitioner:-:; tn have present\\ itb them at all meetings of anycommittee or sub-committee and the count of the votes at the meeting theirattorney or the aitcrnative, to allow the petitilmers and each of them, to haYe'..infottered access to counsel, a n d ~


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1 1l l . Such other, further, tmJ different relief as this coun may find to be. ust and proper and equitable

. V ,/ Suffident cause appearing therefore, leave is hereby granted to the\, C '\ ' tf v_petitioner to 2mend his p l e ~ i d i n g s as may be necessary, and

~ ; 1 / l , Sufficient c ~ r n s ~ appearing therefore, l e a \ is hereby granted to the>..}.._- pe1itioners to submit on the dmc set for the hearing oCthis matter additional, .-.--) ', \ ' . . \": irnesses, exhibits, proofs and other C\'idcnce as may be necessary. realign the' '- '1 panies hereto, and to aml:.'.nd the p ~ t i t i o n herein as may be required by further) !nvestiQation of the facts cmd/or the un


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~ 1 c c e p t Sci"\,ice of papers for such respondent. on or be fore October 7, 2013 anduoon Res1.:iondcnt Officers of the Ol;ccns Countv Renublic3n Committee. bv. ' "' . .,oersone1lly delivering same to thcm 01 a person nf suitable age and discretion at[l:eir cf!iccs or cornmiucc h c a d q u ~ 1 r t e r s 111ai11taincd by them on or before Ocwber7. 20 l3 or alternativeiv, cit the 0 11)tion ol'thc Petitioners. scnice mav he made b\

"' - "2nciosing same in a securely sealed and post paid wrapper dddrcssed tc, theRespondents ar the addrcsscs_j_istcd on the Certificate att(lchcd as Exhihit A via

t::: ) l ;'.) 'P' ,_';;L11\ted Stmes Postal Service P n L ~ r i t v \fail and depositing same with an office or- C'-deposiwry of the United Srntes Postell Service. 011 or before OctobcrJf. 2013 01by~ s - i - t ~ " T - ~ l ~ - + r ~ ~ l ' 9 mi :B t)tHt:T-tt-If y t t l . lhc u \ i 1 e - t t f t r - " t t C t i - - 1 5 ' < l ' + ~ t t - < : - } f - e e - I ~ , , h ~ H - : - Id and drnt such service shai l be deemed good and sufficient sen ice t h ~ r e o f : /,,.--

DA TED: October 4, 2013

So ordered:

jl 'STICE 01" THE Sl fPREME COURT


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SUPREME COURT OF THE STATE or NEW YORKCOUNTY OF QUEENS-------------------------------------------------------------:"(In the Matter of the Application ofROBERT TURNER, JOAN VOGT, ANTHONY NUNZIATO, BARTI IAGGERTY, JOSEPH KASPER, JANICE BAR, MARGARET OGNJBENE,JOANN ARIOLA, EDWARD O'HARE, MANUEL CARUANA, JOSEPHMAGNUS and AMY HOLDEN

Petitioners,

-against-

THE QUEENS COUNTY REPUBLICAN COMMITTEEandPHILIP RAGUSA, CHAIR,INDIVIDUALLY AND AS ALLEGED CHAIROF EACH OF THE QUEENS COUNTY REPUBLICANCOMMITTEE AND EXECUTIVE COMMITTEE OFTHE QUEENS COUNTY REPUBLICAN COMMITTEEand

STEPHANIE ZGALJIC

VERIFIEDPETITION

I ~ J, >&"rt;f Y/ (!3

INDIV.!DUALL Y AND AS ALLEGED SECRETARY AND MEMBER OF THEQUEENS COUNTY REPUBLICAN COMMITTEE AND THE EXECUTIVECOMMITTEE OF THE QUEENS COUNTY REPUBLICAN COMMITTEE,and

ROBERT V. BEL TRANI, JAMES MCCLELLAND, ANTHONY CAROLLO,NATALIE DUBOVJCI, DEBORAH A. HEINICHEN, MARJE LYNCH, PHILIPT. SICA, JUDITH STUPP, ROBERT HORNAK, SAMIHA MAKAWI,STEPHEN MORENA, ROSEMARIE A. IACOVONE, JASMINE OWENS,MELISSA CASTANEDA, RUBY K. MUHAMMED, ANITA BAUMANN,PETER SUTICH, .JOSEPH DUBOWSKI, TIMOTHY FUREY, MICHAELHARRIS, PHILIP T. SICA, CECILIA WALSH, PIERRE ALCANTARA,PATRICK R. GALLAGHER, SERPHIN R. MALTESE, ROLAJNE ANTIONE,JOYCE ARONOVICI, SAMUEL BENOIT, ROBERT BISHOP, DANIEL


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CREIGHTON, KATHY DABOUR, ELAINE C. JACKSON, WlLLIAM LEWIS,ANDRE PECOT and JUAN REYES, INDIVIDlJALLY AND AS OFFICERSAND MEMBERS OF THE QUEcNS COUNTY REPUBLICAN COMMITTEEand

THE BOARD OF ELECTIONS IN TI-IE CITY OF NEW YORK,and

THE NEW YORK STATE BOARD OF ELECTIONS,For an Order pursuant to Articles 2 and 16 orthe Election Law and the Genernl Association LawTo invalidate the purpo11ed organizational meeting of theQueens County Republican County Committeeheld on September 27, 2.013 at the Reception I louseQueens County New York and to invalidate theCertificate of elected officers at said meeting m dtiled with the Board of Elections in the City of\!ew York and the New York State Board of Elections- - - - - - - ~ ~ - - - - - ~ ~ ~ - - - - ~ - - - ~ - - - - - ~ ~ ~ - - - - - - - - - - - - - - - -TO THE SUPREME COURT or THE STATE OF NEW YORK:

The petition of ROBERT TURNER, JOAN VOGT, ANTHONYNUNZIATO, BART HAGGERTY, .JOSFPI I KASPER, JANICE BAR,MARGARET OGNIBENE, JOANNE ARIOLA, EDWARD O'HARE, MANUELCARUANA, JOSEPH MAGNUS and AMY HOLDEN by their attorney ThomasV. Ognibene, respectfully shows this Court and alleges on information and beliefas follows:

1. Petitioners are all duly enrolled members of the Republican Pa11y andregistered voters in the County of Queens.

2. Petitioner Robert Turner, resides at 175 Ocean Avenue Queens NY l 1697and is a former member of the United States I louse of Representatives fromQueens County State of New York. This petitioner is also a candidate who wasnominated to the office of Chair of the Republican County Committee at thepu1vo1ied organizational meeting held on September 27, 2013. Petitioner Turnerbelieves he had the legitimate votes to prevail at the organizational meeting and hisrights have been detrimentally affected by the conduct of outgoing Chair


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Respondent Ragusa and his mm1ons. He believes the election was 'stolen'' andrequests the court intervene and prevent the egregious and illegal conduct of theRespondent Ragusa and his minions as set forth below.

3. Petitioner Joan Vogt resides at 13-17 123 Street Queens NY 1 J356 and isa member of the Queens County Republican Committee from the 2t 11 AssemblyDistrict having been re-elected to a two year term on September I0, 2013. She isalso the female member of the Rcpuhlicnn Stntc Committee from that AssemblyDistrict and is a member of the Executive Committee of the Queens CountyRepublican Committee.

4. Petitioner Anthony Nunziato resides at 56-04 Remsen Place Queens NY11378 and is a member of the Queens County Republican Committee from the 3011iAssembly District having been re-elected to a t\VO year term on September 10.20 l 3. He is also the male member of the Republican State Committee from thatAssembly District and is a member of the Executive Committee of the QueensCounty Republican Committee.

5. Petitioner Bart Haggerty resides at 73-37 Austin Street #PHB Queens :\YI I 375 and is a member of the Queens County Republican Comrnittee from the 28 111Assembly District having been re-elected to a two year term on September I0,2013. He is also the male member of the Republican State Committee from thC:ltAssembly District and is a member of the Executive Committee of the QueensCounty Republican Committee.

6. Petitioner Joseph Kasper resides at 133-18 116 Street Queens NY 1 l 420and is a member of the Queens County Republican Committee from the 31stAssembly District having been re-elected lo a two year term on September 10,2013. He is also the male member of the Republican State Committee from thatAssembly District and is a member of the Executive Committee of the QueensCounty Republican Committee.

7. Petitioner Janice Bar resides at 133-59 118 Street Queens NY l l 420 andis a member of the Queens County Republican Committee from the 3 Ist AssemblyDistrict having been re-elected to a two year term on September l 0, 2013.She is


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Assembly District having been re-elected to a two year term on September 10.2013 .

13. Petitioner Amy !lo Iden resides at 74-19 Caldwell Avenue Queens NY113 78 and is a member of the Queens County Republican Committee from the30th Assembly District having heen re-elected to a two year term on September l O.2013.

14. Respondent Boards of Elections are responsiblc for the oversight andconduct of all Election related procedures in the City and State of New York andthe Agencies with the responsibility of accepting and filing the above Certificate ofElection of Officers.

15. Respondent Board of Elections in the City or New York maintains itsfiles at the Executive Offices in the Borough of Manhattan. County of New York

16. All filings with the Respondent Board of Elections in the City of NewYork are required to be made in the Borough of Manhallan. County of New York.

17. Respondent Board of Elections in the State of New York maintains itstiles at its E x e c u t i v ~ Offices in the County of Albany.

18. All filings with the Respondent Board of Elections in the State of NewYork are required to be made in the County of Albany.

19. Respondent Queens County Republican Committee 1s a ConstitutedCommittee under the Election Law and is organized pursuant to A11icle 2 of theElection Law of New York State. The Members of the Respondent Committeewere last elected at the Primary Election held on September 10th. 2013.

20. According to documents purported tiled tile with the New York Stateand New York City Board of Elections, Respondent Philip Ragusa,. who resides at14-15 157 Street Beechhurst NY 11357. is the purported Chair of the RespondentQueens County Republican Committee.


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21. According to documents on tile \\ith the New York State and Nev,, YorkCity Board of Elections, Stephanie Zgaljic, who resides at 30-47 29th StreetAstoria NY 11 l 02 is the purported Secretary of the Respondent Queens Count)Republican Committee.

22. The respondents listed in Exhibit ' ';\" hereto which is the Certificate ofElection of Officers filed by respondents Ragusa and /.galjic, were allegedlyelected to the party positions indicated therein at the organizational meeting of theCounty Committee held on September 27th, 201 J. Upon information and beliersaid list of ot1icers has been filed with the Board of Elections in the City of ;-..Je,,York and the New York State Board of Elections.

23. This petition is made in order to preserve Petitioners' rights under theElection Law of the State of New York and the General Association Law of theState of New York to challenge erroneous results and conflicts and correct anyerrors in the organizational meeting, and to provide for cou11 supervision of theorganizational meeting of the Respondent Queens County Republican Committee,to allow for the comprehensive review of the matters under the jurisdiction of thisCou1i.

24. That prior to the organizational meeting, Respondent Ragusa caused ameeting notice to be sent to committee members for the organizational meeting ofthe County Committee to be held on September 27th, 2013. Said meeting noticewas dated September 27, 2013, the same date as the meeting was called for, andwas NOT accompanied by any proposed by-laws or rules and was not mailed ordelivered to the county committee members in the time frame provided for in therules and by-law of Queens County Republican Committee . . (See Exhibit "B").

25. The meeting notice was insufficient us a matter of law to give adequatenotice of the actions that were to be taken al the meeting, and did not state theorder of business for the Organizational Meeting, as prescribed in the by-laws andmies.


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26. Upon information and belief respondents gave different and unequalnotice to different county committee members including giving more and favorablenotice to committee members supporting respondent Ragusa.

27. Upon information and belief, respondents also gave legally insutlicicntnotice of the meeting, especially to those districts in which the respondents had lostprimary elections and that would not vote for their chosen slate of candidates. Insome instances there was only 48 hours or less notice of the purported meeting.

28. Upon information and beliet: at the ubove Organizational MeetingRespondents allowed proxies to he voted which had been obtained \Vithout theconsent or knowledge of the county committee person.

29. Upon information and belict: at the Organiz:.nional Meeting held onSeptember 27th 2013, Respondents alJm,ved proxies to be voted which had beenobtained from voters who were not duly qua Ii lied or elected to be members of theRepublican County Committee.

30. Upon information and be! iel', at the Organizational Meeting held onSeptember 27th 2013, Respondents allowed proxies to be voted by CountyCommittee in their favor from members which contained either no signature or aforged signature w l ~ i l e invalidating otherwise valid proxies on similar grounds.

3 l. Upon information and beliel: at the Organizational Meeting held onSeptember 27th 2013, Respondents never took a roll call for the election ofofficers.

32. Upon information and bclict: at the Organizational Meeting held onSeptember 27th 2013, Respondents allowed for Assembly District votes to beimproperly stated by leaders and cast by persons not authorized to cast said votesin contravention of the existing by-laws.

33. Upon information and belief, at the Organizational Meeting held onSeptember 27th 2013, Respondent's prohibited a proper record of the meeting tobe maintained and improperly denied motions to so record the meeting. This \Vas


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done deliberately by the Respondent's to frustrate this Court's review of theproceedings.

34. Upon information and belief Respondents unknown 1m111ons on thepurported Credentials Committee made challenges to and invalidated proxiesarbitrarily and capriciously and without any method or handwriting expertise orcomparing signatures to any Board of Elections record.

35. Upon information and helicf Respondents improperly calculated thevoting method and voting weight used at the organizational meeting incontravention of New York State Law and the By-laws of the Republican CountyCommittee.

36. Upon information and be! ic r Respondents deliberately improperlytabulated and counted the votes cast at the organizational meeting.37. Upon information and b e l i e f ~ respondents failed to provide or makeavailable copies of the bylaws and rules nt the reorganization meeting.38. Upon information and belief, respondents failed to obtain a ce11ifiedcopy of the duly elec!ed members of the Queens County Republican Committeefrom the New York City Board of Elections prior to the meeting.39. Upon information and belie( the Queens County Republican ExecutiveCommittee never organized and the certificate tiled by respondents Ragusa andZgaljic stating that such meeting took plrice is a false statement and a fraud.40. Upon information and b e l i e f ~ respondents intentionally and purposelycalled the organizational meeting for a Friday at I 2:30pm, a work day, and also 8Jewish Holiday, in order to purposely inconvenience members from attending andto discourage attendance and participation.41. Upon information and b c l i e t ~ respondents allowed votes to be cast byproxy, where no such proxies had been submitted by the members.42. Petitioner Turner believes that if the proxies improperly disqualified bythe Respondents' were counted, he would prevail and be the duly elected Chair ofthe Queens County Republican Committee. Petitioners' believe that only thoughthe intervention of this Court can they receive a fair organizational meeting. At a


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fair meeting, it is their belief that Lhey v,:oulcl prevail.43. To aid the Court, at the nc\V Organizational Meeting, an appointment ofa special master or referee and a stenographer wi 11 assist the Court in a speedydetermination of all issues that may be raised. It will also insure fairness and acomplete record of the proceedings.44. Petitioners request leave to, and reserve the right to submit further proofs

by way of \Vitnesses, affidavits, and evidence upon the date set by this court for thetrial and hearing of this matter, to re


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Certificate of Officers \Vith minutes attached thereto filed by such Respondents.and that this court order a new organizational meeting of the Respondent QueensCounty Republican Committee and that the Court take jurisdiction over theconduct of the organizational meeting of the Respondent Queens CountyRepublican Committee, and grant the relief requested in the annexed Order toShow Cause, together with such other, further, and different relief thnt this Courtmay deem to be just and proper.DATED:

Yours, etc

October 4th, 20 l3Melville, New York

Thomas V. OgnibeneAttorney for Petitioner155 Pinelawn Road Suite 220Melville, New York 11747516-686-0000 PHONE516-693-9185 FAX

Thomas V. Ogni ene Esq.Attorney for the Petitioners


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(

CERTIFIEDCERTIFICATE OF NAMES AND POST OFFICE ADDRESSES OFOFFICERS ELECTED AT TT-TE PARTY ORGANIZATION E E T I N G ~ ....;ggOF THE REPUBLICAN PARTY OF QUEENS COUNTY ~ ~ ~,..,., w ~ OThe New York State Board of Elections and ~ ~ ~ ~ ~o: The Board of Elections in the City of New York c:> ~ ~ ; . - ; ; : .~ r i M : - : 1-0 ~ : : ~ =We, the undersigned Philip Ragusa as the Chairman and Stephanie Zgaljic as the Secretary of the ~ e e m ; < c i ~County Republican Party County Committee and tho;: Queens County Repub lican Part E x ~ t i v c ~ ~

1 TITLE

Committee, r:DO HEREBY CERTIFY THAT:Pursuant to the New York State Election Law including but not limited to 2-112 and 2-114, and the ByLaws and Rules of Party Organization for the Republican Party of Queens County, the following are thenames and post office addresses of the officers elected at the organization meetings of the RepublicanParty County Cornmillce and the Republican Party Executive Committee of and for the County of Queensal the duly convened meetings held al the Recept ion House located at 167-17 Northern Boulevard.Flushing, Queens County, New York ity, New York on September 27h. 2013.And WE DO HEREBY CERTIFY THAT the following arc the current Names and Post OfficeAddresses of the aforesaid Officers of the Republican Party County Committee and the Republican PartyExecutive Committee of and for the County of Queens.

fi ,\ E------ -- ADDRESS.1 CHAIR1'11AN PHl!,!P RAGUSA 14-15 157th Street, Bcechhurst, I 1357t - - -- - - - -- - ---- -;----------- - --+-----1 EXECUTIVE VICE CHAIRMAN ROBERT V. Rf-:l.TRANJ 35-31 85 Street Jackson Heights. '\:.Y 11372I rIRST VICE CHAJRMAN JA.\1ES MCCLELLAND 62-39 65' h"Street, Middle Village, 11379~ - - - - - - - - - - - - - - - - - - - ----- -- - - ! ---- - ---- --'-' - - - -- --- .LvrcE CHAIRPERSONS CALPHABET1cAL) - -+----------- --------; I. ANTHONY CAROLl.O 157-03 10 Ave. Whitestone NY 11357 1r - - - - - - - - - - - - - - ~ - - - - - - - - - ~ - -; 2. NATALIE DUBOVlCl 31-20 54h Street. Woodside, NY 11377


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CHAPLAIN PHILIP T. SICA I 32- I l Seward Avenue, Queens, l\Y I I 427 :AMERICANISM CHAIRMAN CECILIA WALSH j 39-20 Grecnpoint Ave, Sunnysid e: , NY I I10.i .IPROTOCOL OFFICER PIERRE ALCANTARA 4 7-50 59


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l!on. 1'!1ilip ! ~ a g u s a('/w/n:wn

\a:hnn\ ( ~ ) 1 ? 1 0!; \1 ' \U. ' /., 1' I i'.\isBlvd, Whitestone, NY 11357.l'ro:xy l k>ldcrs arc nthised t h ~ t cn:J


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Vl.:RIFIC:\'l'IONSTAfE OF NEW YORKcot.:NTY OF NASS/\U ) ss.:

Thomas V. Ognihenc being duly S\Yorn deposes nnd says:that I am an attorney at Law duly licensed to practice law in the State of c w York. and am theattorney for the Petitioners hen:in.

That I make this verification pursuant to lhc Ci\'il Prnctice Law and rules.That I have read the foregoing Petition and know the contents thereoJ: the same is true tomy own knowledge except as to those matters al legtd on information and belief and as to thosematters I believe them to be trueI make this verifications because my clients ure not in the County where I mnintain m:

office.

Thomas


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Queens Gop Osc