TAITZ v DUNN - Complaint - DisplayPdf.do

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Dr. Orly Taitz, ESQ

29839 Santa Margarita Parkway, STE 100Rancho Santa Margarita CA 92688Tel: (949) 683-5411; Fax (949) 766-7603

E-Mail: [email protected]

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2010 JUfl I 7 /.:lIO: 12

SUPERIOR C O ~ T OF.C.ALIFORNIA 30-2010Laguna Hills DIvISion

Dr. ORLY TAlTZ, ES9,,IN PRO PER § 0 0 3 8 1 6 6 4PlamMf, §

§ PRESIDINGv. § Civil Action:

10J DAMON DUNN &

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§ELECTIONS CONTEST§ ELECTIONS FRAUD§ VOTER FRAUD§ t h

amendment common law jury§ trial is demanded on all counts

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John Does 1-18

Defendants.

§ and all issues oflaw and fact§ INJUCTIVE RELIEF§Declaratory Relief§

JURISDICTION

Legal action at hand involves contest of June 2010 Statewide Primary election.

Any California Superior Court is a proper jurisdiction. Defendant Damon Dunn is a

resident ofIrvine, CA with a business address in Irvine, CA. As such Superior Court

of the Laguna Hills Division is a proper jurisdiction. This complaint includes

violation ofCEC (California Elections Code) §§ 18203, 18500, 18501, 18502,8001.

Due to violations of he above Elections Code statutes, primary votes were not

properly cast and cannot be certified. Petitioner is seeking Declaratory Reliefdue to

violation of he following California Elections Code Statutes by the candidate on the

ballot, Damon Dunn, and as such, votes received by this candidate cannot be

certified.

18203. Any person who f i l e s o r submi ts fo r f i l i n g a nominat ion

paper o r dec la r a t ion o f candidacy knowing t h a t it or any p a r t o f it

has been made f a l s e l y i s punishab le by a f ine not exceeding one

thousand dol l a r s ($1,000) o r by imprisonment in th e s t a t e pr ison fo r

16 months o r two o r t h r ee years o r by both t he f ine and impr isonment .

Taitz V DIlllll Election Contest 1



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18500. Any person who commits fraud or attempts to commit fraud,

and any person who aids or abets fraud or attempts to a id or abetfraud, in connection with any vote cast , to be cas t , or attempted to

be cas t , is gu i l ty of a fe lony, punishable by imprisonment for 16

months or two or three years.

18501. Any publ ic of f i c i a l who knowingly viola tes any of theprovisions o f t h i s chapter, and thereby aids in any way the i l l ega l

cast ing or at tempting to cast a vote, or who connives to nul l i fy any

of the provisions of th i s chapter in order tha t fraud may be

perpet ra ted , sha l l forever be disqual i f ied from holding off ice in

th i s s ta te and upon convict ion sha l l be sentenced to a s ta te prisonfor 16 months or two or three years.

18502. Any person who in an y manner inter feres with the off icers

holding an elec t ion or conducting a canvass, or with the voterslawful ly exercising t he i r r ights of voting a t an elect ion , as to

prevent the elec t ion or canvass from being fa i r ly held an d lawful lyconducted, i s punishable by imprisonment in the s ta te pr ison for 16

months or two or three years.

18002. Every person charged with the performance of an y duty under

any la w of th i s s t a t e r e l a t ing to e lec t ions , who wil l fu l ly neglectsor re fuses to perform i t , or who, in h is or her of f i c i a l capaci ty,knowingly and fraudulent ly acts in contravention or viola t ion of an y

of those laws, i s , unless a d i f fe ren t punishment i s prescr ibed by

th i s code, punishable by f ine not exceeding one thousand dol lars

($1,000) or by imprisonment in the s t a t e pr i son for 16 months or tw o

or three years, or by both.

Parties to the dispute

Plaintiff in propria persona is Dr. Orly Taitz, Esq, hereinafter Taitz, was a

Republican Party candidate in the June 2010 primary election for Secretary of State

of California.

Defendant Damon Dunn, hereinafter "Dunn," was also a Republican party

candidate on the ballot in the June 2010 primary election for the same position of

Secretary of State.

Summary oftbe complaint

1. Taitz alleges that Dunn has committed knowingly fraud in registering to vote

in California as a Republican, declaring his candidacy and running as a

candidate for the position of Secretary of State. Taitz has suffered damages in

losing the election to an ineligible candidate and having to spend over $40,000

running against an ineligible candidate in the primary election. Damages

Taitz v Dunn Election Contest 2



3 suffered by Taitz are the direct result of fraud committed by Dunn and were

4 foreseeable. Taitz is seeking a Declaratory Relief from this honorable court,

5 j deeming Dunn ineligible candidate and seeking declaratory relief that votes

6 , for Dunn as ineligible candidate cannot be certified by the Secretary ofState

7 ofCA, due to fraud committed by Dunn and is seeking reimbursement of

8 damages suffered, as well as punitive damages from Dunn.

9 2. On or around April 2010 Taitz filed a timely complaint with the Registrar of

10. Voters ofOrange County. The Registrar forwarded the complaint to the

111 Secretary of State. As ofyet no action in relation to Dunn has been taken.I

12 3. On April 16 Attorney Danny Kepner of the prominent law firm of Shell

19 Fleming, Davis and Menge ofPensacola, Florida filed a complaint with the

J ) Attorney General ofCalifornia, Jerry Brown, and Secretary ofState Debra

21 Bowen. Mr. Kepner forwarded to Mr. Brown and Ms. Bowen information

22 regarding Dunn's registration in Florida and has asked them to investigate

23 possible criminal violations of CEC §18500 and §18203. No response was

24 received from either the Attorney General Brown nor Secretary ofState

25 Bowen.

26 4. The Primary Election was held in an environment ofharassment and

1J I intimidation ofTaitz as a candidate on the ballot and her supporters and

28 I voters. Results of an election held in the midst of campaign of intimidation

and harassment are invalid per se.

5. Secretary of State Bowen did not verifY the eligibility or identity of either of

the candidates or voters. Results of an election held in the environment of lack

of verification of eligibility of either voters or candidates are invalid.

6. Taitz was not given an opportunity to put her candidate statement on the ballot

brochure and therefore was at a disadvantage.




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3 Dunn was not eligible to run as a Republican Candidate in the June 8,

4 2010 Republican Primary because ofinvalidation ofvoter registration due to

5 the backdated signature on his voter registration card.

6 Defendant Dunn was a life time Democrat and former professional football player

7 from Jacksonville, Florida, who registered to vote as a Republican only last year in

8 2009, however he intentionally backdated his registration card with the date 1976

9 instead of2009. Backdating invalidates the signature and voter registration. (Exhibit

10 1 Voter registration executed by Damon Dunn in March of2009, but backdated as

11 March of 1976. ) Lack ofvalid voter registration invalidates one's ability to be a

12 Candidate on the ballot. Incredibly, Dunn was seeking the very office that validates

19' voter registration thus the backdating was not a mere oversight but an attempt to

:J) avoid committing petjury since he previously registered as a Democrat and did not

21 disclose this information.

22 Invalidation ofvoter registration due to fraud in lack of mandatory

Z3 disclosure of voter registration from at least two other states.

LA 1. Dunn registered for the first time as a Republican in California in March of

25 2009.

26 2. Section 16 on the voter registration card asks for mandatory disclosure of he

'IT prior voter registration

28 3. Dunn left section 16 blank. Based on that fact, the Registrar ofOrange County

Neil Kelly, as well as voters, including Taitz, reasonably believed that Dunn

had never registered to vote before. During numerous meetings with votersDunn described himself as a "recovering non-voter" further reinforcing the

deceit.

4. On April 7, 2010 Taitz reviewed PublicRecords.com for available public

information for Damon Dunn. (Exhibit 2 )




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3 5. PublicRecords.com revealed that though Dunn presented himself as someone,

4 who never registered before, this was not true. Dunn had registered to vote

51 before, and not in one but in two other states: Texas and Florida. While6 ! PublicRecords.com did not provide specific information regarding party

7 ! affiliation in Texas, it showed Dunn as a Democrat in FL and it showed him

8 active there as a voter.

9 6. One might believe that a person could simply forget about voter registration in

10 one state and give such individual a benefit of a doubt, however it is

11 unreasonable to believe that an individual would forget about being registered

12 to vote in two states, particularly in light of the fact that such individual is

19 running for the position ofSecretary ofState and will be in charge of elections

J ) and voter registration ofmillions of citizens ofCA.

21 7. On April 13 2010 Taitz traveled to Florida and met with the staff of the

22 I Registrar of Jacksonville FL where Dunn used to reside and where he

23 previously registered to vote.

24 8. Taitz received from Jean Marie Atkins, Manager ofElections in Duval County

25 Dunn's voter registration card there (exhibit 3), which clearly showedDunn

26 registered as a Democrat.

T1 9. Jean Marie Atkins provided Taitz with a letter (Exhibit 4), stating that on July

28 10,2009 Dunn contacted the Jacksonville Registrar ofVoters and asked to

delete his voter registration from the database voter records.

1O.lf previously one could believe that possibly Dunn forgot about hisregistration in two states, the fact that he contacted the Registrar in Duval

County and asked to delete his records, attests to the fact that it was not lack of

recollection, but rather an intend to defraud and violation ofCEC §§18500 and

CEC 18502. Voter registration in California achieved and executed by virtue of

fraud invalidates such voter registration. Without valid voter registration one




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3 cannot be a candidate on the ballot and cannot run for office. Additionally

4 such actions constitute violation ofCEC § 18502, as when a candidate in an

5 election registers without providing mandatory disclosure ofprior voter

6 registration, particularly registration with an opposing party, it takes away

7 from voters, particularly Republican voters the ability to participate in a fair

8 and lawful election.

9 II.Dunn also violated § 18002, whereby he took an oath" I understand that it is a

10 crime to intentionally provide incorrect information on this form. I declare

11 under the penalty ofperjury and under the laws of the state ofCalifornia that

12 the information on this form is true and correct". Dunn committed fraud and

19 perjury, as well as violation ofCEC §§18002, 18500, 18502. He knowingly

2D provided false information with the intent to defraud California Republican

21 voters and the Registrar.

22.[ 12. If one was to believe that Dunn did not attempt to defraud, then one would

23 j expect Dunn to contact the Registrar in Orange County CA and re-register,

24 providing mandatory disclosure of the record ofprior registration in Texas

25 and Florida where he registered as a Democrat. Dunn did not do that either at

26 the time of his registration in March of 2009, nor on July 10, 2009 when he

']] called the Florida Registrar and asked to delete his records from the database.

281 Exhibits 2,3 and 4 combined clearly point to an intentional obfuscation of

record with an intent to defraud the voters. Fraud invalidates voter registration.

Without valid voter registration in CA, one cannot be a candidate on theballot, therefore Dunn's candidacy needs to be invalidated due to fraud. Votes

received by him cannot be certified as valid, and therefore Taitz should be

certified as a Republican Party nominee for Secretary of State. Currently

according to the unofficial count Taitz is the second place candidate with

440,015 votes.




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13.On November 5, 2009 Dunn filled out his Declaration of candidacy, wherein

he attested that all the information on the declaration was correct. (Exhibit

6)At that time Dunn clearly knew that he did not provide mandatory disclosure

ofhis prior voter registration record, and had an opportunity to correct the

record. Dunn did not do that, which serves as additional evidence of fraud and

pelJury.

14. On March 10,2010Dunn signed his registration as a candidate on the ballot

and took the oath of the candidate. (Exhibit 7) Yet again he swore to the

truthfulness ofhis statements and eligibility, knowing full well, that he did not

provide truthful information. This is yet more evidence of fraud committed.

Invalidation ofvoter registration due to invalid nominations

1. On June 13, 2010 TV reporter and talk show host William Wagener prepared

an affidavit regarding his personal knowledge of fraud committed in

nomination of Damon Dunn. (Exhibit 10) On June 14, 2010 William

Wagener and his cameraman Robert McGuire met Taitz and forwarded above

affidavit to her. Affidavit stated the following:

2. Prior to the June 8 election, Mr. Wagener, talk show host and producer ofTV

program "On Second Thought" in Santa Maria CA, contactedMax and Vetele

Liston, residents of the retirement community Leisure World in Laguna

Woods.

3. Max and Vetele Liston are among the registered Republicans who appear in

official records of individuals who nominated Dunn for the position of

Secretary of State ofCA. (Exhibit 8)

4. Wagener has interviewed the Listons on camera and posted the interview on

YouTube™ under the name "Nomination Fraud".

5. On camera the Listons categorically denied ever signing any nomination for

Dunn.




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3 6. Taitz visited offices of the Registrar ofVoters in Orange County CA and

4 obtained the list ofRegistered Republicans, who nominated Dunn.

5 7. Wagener called Gloria Duthie, 3201 Via Buena Vista B, Laguna Woods,

6 • 92637, phone 949-587-0709. Ms. Duthie stated that not only she didn't sign

7 Dunn's nomination, she also stated that she was not even in California the

8 week she supposedly affixed her name, address and signature on the

9 nomination.(Exhibit 8)

10 I 8. Taitz has noticed that according to the addresses submitted by Dunn, the

11 I majority ofthe signatories are residents of the same retirement community

12 "Leisure World".

19 9. Taitz has called several of the individuals on the list. Taitz was advised by

3), signatories that they can't remember signing the nomination and that when

21 they gather in the clubhouse there, many papers are brought to them for

22 signature, usually petitions for propositions.

23 1O.On May 28th- , Taitz was invited to speak at one such clubhouse at Leisure

24 World. Taitz has noticed that many of the residents are very elderly: in their

25 eighties or even nineties. Many could not see well or could not hear well.

26 11. Ifnominations were obtained without valid signatures, or by virtue of

27 obtaining signatures by misrepresentation, by telling the signatories that this is

28 a petition for a proposition, then the nomination is not valid, and consequently,

the candidacy is disqualified. Additionally, such acts fall under violation of

CEC §§ 18203, 18500, 18502, 18002.12.0n March 10,2010 Dunn took an oath ofoffice to uphold the Constitution and

the laws ofCalifornia. If it is found that he indeed committed fraud, and/or

uttering, and lor forgery, he will be disqualified from holding office under

CEC § 18501. As an official candidate on the ballot Dunn took an Oath of

Office on March 10,2010, which made him a public official and subject to




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3 I §18501. As ofMarch 10, 2010, Dunn knew that he registered in two other

4 states and didn't disclose this infonnation on his voter registration card. He

5 knew that he called Florida to have his voter registration record deleted, but

6 didn't disclose this infonnation in California and he knew that at least some of

7 the individuals who supposedly signed his nominations, didn' t really sign

8 them. As such, Dunn committed fraud that disqualifies him from holding

9 office. therefore votes received by him cannot be certified.

10 Common law Fraud

II ~ o t i f 12 Dunn had a motifto commit fraud.

19 1. CEC § 8001(a)2 require one to disassociate from another party at least twelve

:l), months prior to declaration ofcandidacy. Dunn knew that he never

21 disassociated himself from the Democratic party.

22 2. An e-mail from the registrar ofvoters ofDuval county FL Jerry Holland states

23 that Dunn has never contacted them to change his party affiliation from

24 Democrat to Republican. (Exhibit 5)

25 3. Dunn was concerned that disclosure will reveal that he did not disassociate

26 himself from the Democratic party.

']] I 4. Dunn met with voters all over the state and repeatedly told them that he

28 I became a Republican after meeting Candolleza Rice and her father, when

Dunn was a college student, and being deeply influenced by fonner secretary

of state Candoleeza Rice. Disclosing the fact that Dunn registered to vote as a

Democrat after graduation from college, and the fact that he switched his

affiliation to Republican only last year, some sixteen years after being so

deeply influenced by Rice, would have shown that his assertions were nothing

but a sham, fraud. It would make it clear that Dunn is simply throwing around

names of famous Republican leaders, while his true motifs to run as a




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281 II.Act ofFraud count seven: Dunn did not disclose his voter registration in TIC,

while he took an oath ofoffice and declared himself as a candidate in March

2010.Intend to defraud

Dunn intended to defraud Taitz, voters of he state ofCA and Registrar and make

them believe that he did not register before.

Dunn had a particular intend to defraud Taitz, to make her believe that he did not

register before so she will not file a contest of he election.

Taitz vDunn

Election Contest 10



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Taitz was an actual and foreseeable victim of fraud perpetrated by Dunn, as her

campaign committee suffered damages of around $45,000, in having to run

against Dunn.

Taitz has filed a timely complaint with Orange County Registrar ofvoters Neil

Kelly.

Taitz has called Dunn's campaign headquarters and talked to Dunn's

spokesperson Hector Barajas, asking to schedule a meeting with Dunn.

Taitz has seen Dunn at two events and asked him to have a meeting and discuss

issues described above. Dunn refused.

Taitz was concerned that above issues would be embarrassing for the Republican

party and she is filling this complaint very reluctantly and after allot of

deliberation, since facts described above constitute embarrassment for the

Republican party and constitute basis for criminal indictment ofDunn, however a

possibility ofDunn becoming the next Secretary ofState ofCalifornia, in charge

of legitimacy of elections in the most populated state in the nation, outweighed

24, her reluctance in filing above complaint.

25 Dunn defrauded Taitz and while doing so violated CEC §§ 18203, 18500,

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18501,1850218002 and possibly 8001, which invalidates his registration and

invalidates his candidacy, which serves as basis for denial of certification ofvotes

received by Dunn in June 8, 2010 primary.

Possible Common Law Uttering

According to Affidavit by William Wagener as well as YouTube.com video tape"Nomination Fraud" Vetele and Max Liston did not sign nomination for Dunn,

even though they are listed among individuals who signed nomination for Dunn.

According to affidavit by William Wagener Gloria Duthy did not sign the

nomination as well.




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3 i Taitz has no ability to investigate this matter further, however Taitz requests this

4 Honorable court to forward this matter further to the office of the District

5 Attorney ofOrange county for criminal investigation for possible uttering,

6 forgery, misrepresentation, fraud related to nomination of the candidate on the

7 ballot.

8 Possible fraud related to Residency

9 1.0n March 10, 2010 Dunn has took an oath ofoffice, as a candidate on the

10 ballot, attesting to his residency.

11 2.Taitz has reviewed Dunn's residency on PublicRecords.com

12 3. PublicRecords.com show mUltiple addresses for Dunn in TX, FL, AZ and CA

19 4. Notably Dunn's address 1126 E. Thunderhill PI, Phoenix, AZ is listed as an

: l) active address from 2002-2010. (Exhibit 11)

21is . wo of the states on the list: FL and TX do not have state taxes.

22 6. At the moment Taitz has no access to Dunn's tax returns or homestead

23 , exemption filing. If during the discovery, it is found that Dunn has filed his taxes

24 in another state or filed his homestead exemption in another state, it would

25 ' constitute yet another count of fraud committed by Dunn and would serve as an

26 additional reason for invalidation.

'Il I Possible violation ofCEC§8001

28 I 1. Taitz has investigated discrepancy between PublicRecords.com showing Dunn

as an active voter in FL and a letter by Jean Marie Atkins, showing Dunn as

ineligible to vote. This discrepancy looked suspicious.2. While visiting Duval county FL, Taitz has asked to review Dunn's voting

record. Dunn's voting card record showed him as placed for the first time on

inactive status in 2005.

3. FL statute 98.045 Administration ofvoter registration (i)(2) Removal of

Registered Voters (a) states: "Once a voter is registered, the name of that voter

Taitzv

Dunn Election Contest12



123 may not be removed from the statewide voter registration system except at the

4 written request of the voter, by reason of the voters conviction of a felony or

5 adjudication as mentally incapacitated with respect to voting, by death of the

6 voter or pursuant to registration list maintenance activity conducted pursuant

7 to s. 98.065 or s.98075

8 4. Subsequent FL statute 98.065 Registration list maintenance programs (4)(c)

9 " •.• A voter on the inactive list may be restored to the active list of voters

10 upon the voter updating his or her registration, requesting an absentee

11 ballot, or appearing to vote. However, ifthe voter does not update his or

12 her registration information" request an absentee ballot, or vote by the

19 second general election after being placed on the inactive list, the voters

J ) name shall be removed from the statewide voter registration system and

21 the voter shall be required to reregister to have his name restored to the

22 statewidevoter registration system."

23, 5. Dunn's voter card audit clearly shows him as placed on the inactive list for

24' the first time in 2005. Second general election after 2005 was in 2008, there is

25 no notation in 2008 or later. Any attempt to mqke Dunn ineligible before 2008

26 would have been invalid per FL statute 98.065 and would have constituted

27 violation ofDunn's civil rights. Therefore there was no valid transfer from

28 inactive status to ineligible status.

6. Taitz further investigated a March 30,2010 letter from Jerry Holland,

Supervisor of election to Mark Loren, chief investigator Election fraud

Investigation Unit (Exhibit 12)

7. Above letter from Mr. Holland states that Dunn was put on inactive status in

2002 and became ineligible to vote in 2005. This is not a true statement, since

the very first time Dunn appears as inactive, is in 2005, not 2002, and

therefore he could not have been placed legally on ineligible status in 2005.




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8. It is not clear ifthere was a violation of §8001, however it is clear that Dunn

was concerned about possible violation of §800 1 and committed fraud to

cover up. He attempted to violate §8001 and by engaging in cover up, he

violated §18500.

9. Invalidation due to intimidation and harassment of the candidate on the

ballot and family of the candidate

Children ofTaitz received highly inappropriate insulting paintings under the title

"Birther Orly Taitz" These paintings depicted their mother nude in a highly

inappropriate light, giving birth, holding something that looked like a placenta

with blood gushing out of it. In an interview to Mother Jones magazine reporter

Stephanie Mencimer, creator of those paintings Dan Lacey admitted that he was

commissioned, paid to make such paintings. So far, Lacey refused to provide the

name of he individual, who commissioned him. Taitz intends to conduct

discovery to fmd out who paid to harass her, as a candidate on the ballot in the

statewide election, and her whole family, to intimidate and pressure her to

withdraw from the campaign. Taitz reserves her right to plead additional causes

of action upon completion of discovery.

26 2. Such inappropriate paintings were posted all over the Internet and some local

271 newspapers.

281 3. Taitz's children received e-mails stating "-you poor kid, your mom will be

thrown in prison, your mom will be thrown in a mental institution".

4. Taitz's websites were repeatedly hacked, and viruses deposited, which caused theweb sites to be blacklisted by the search engines and inaccessible to readers,

wherefore Taitz could not conduct her campaign on the Internet or get donations.

5. Taitz's newsletters were redirected to a different server and blocked by that

Server. That created a situation where Taitz could not conduct outreach to voters,

supporters and donors.




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3 Prayer for relief:

4 Wherefore, Taitz respectfully requests this Honorable court to grant the

5 following relief:

6 1. Declaratory rel ief based on contest of election deeming violation ofCEC

7 §§18203, 18500, 18502, 18002 and common law fraud and not qualified and not

8 eligible for certification ofvotes. Additionally Plaintiff is seeking Declaratory

9 relief deeming Dunn disqualified to hold office in California due to violation of

10 §18501.

11 2. Damages sustained by Taitz up to the amount allowed by this court 's limited

12 jurisdiction due to her need to campaign against an ineligible candidate, who

19 committed fraud.

:!) 3. Request for expedited discovery, to ascertain the identities ofJohn Does, who

aided and abetted Dunn in commission of fraud and John Does who were

complicit in intimidation and harassment ofTaitz and her family.

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4. Request to forward sua sponte above pleadings and adjudication order to the

Orange County District Attorney for criminal investigation ofDunn and

prosecution under CEC §§ 18203, 18500, 18501, 18502, 18002, as well as request

to forward to Orange County Registrar ofVoters and Secretary of State any and

all adjudication, order and declaratory relief prior to completion of canvassing on

July6, 2010 and Certification ofVotes on July 11,2010.

5. Punitive damages for fraud committed.

6. Any and all further relief this court deems necessary.

Respectfully submitted,

/s/ DR ORL Y TAlTZ ESQ




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/------------L , : : ~ ' : , _ , I " , - . - - - - . - - - - - - " - - - ~ . -B y : ~ ____ ____.!l_______

Dr. Orly Taitz, Esq. (California Bar 223433)

Attorney in Propria Persona

29839 Santa Margarita Parkway ste 100Rancho Santa Margarita CA 92688Tel.: 949-683-5411; Fax: 949-766-7603E-Mail: [email protected]

PROOF OF SERVICE

I CERTIFY THAT TRUE AND CORRECT COpy OF THE ABOVE

PLEADINGS WERE SERVED by registered mail on 06.16.10. on

Damon Dunn

3131 Michelson, unit 708 west

Irvine, CA 92612




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•

IsJOrly Taitz

Dr. Or1y Taitz Esq

29839 Santa MargaritaPKWY

Rancho Santa Margarita CA 92688




Exhibit 1



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CAUFORNIA VOTER REGISTRATION FORM -II oullhis lor", il)1ltJ pre ~ ~ r w IIO/er, bave mDftll ar [ilaoged jIOUf nSIII!, 0/ Wolnllt cIIallgi ,aUf !1Ciilicll party d l l l i ~ e . You must a U.S. citizen a n ~ at leas! U yeBl$lIId by the Il&'lt elKtiOli IG ne t l I ~ fgllD. Useblve Dr blad ink. Print c1eal1y.

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.( 20 7 0 g""')'..,,.(} '> ( . . . M ~ . . , r "t>.I'. ... r, fwtizn CIlIII1{f

:11. ,l:.(' "1 '\ "'''- CA 'I , • I t -

Oale4lbittb US.$IIllerilJlel1flC1l8fll!JQfI:lktlo

" o 3 I 5 91 G, 10' .,.. L. )( 4.. 50\ driversliceni18 cr Col ID end I

Jf)QI60nat "","" CAdrII1II'sllcne.llcar1, iIllle

1ssI • ..m\Ien;Wpn'$/llillSIeafi!IIIIIItItf,II}1111hM'_·· .;

Emd /iIt1fit1IINJ

:17.' d ... tl.\.oY\J .........a. r ~ ' t.- .......

, ~ , I ' Do YDII wam to relisteJ w l t ~ a political JWty?

IIWInI! IIDIbm 1118 JIOS\III! t1

.iI,IIIa*(II:l!II!dkIIdI).

r e : a . l w a o l l ~ r t ! l i m f M t l I l ~ i t i t l l p e " , ( ( _ ~ - __

O ~ i c > o D ~ 1 ' 8 r t y D ~ P , , ~ O l ' B c e l l ! d r ~ p l i I y ~ 1 l I h \ J a ID, I lia ' 111111 IqisIer 1IIiIh. paIiIkaI\WI!j.

(ffptdJed fIut I'IJI1flq1lli 1IfI•• I.!t

b _ _~ ' U J K i ' i t I J b ! s ; , , ~ ~ D ~ I k . f ' J r t J DDllfllaflul'W, O O \ b t r ~ t 1 I I « i J #

_____'IS. Til !'teem a VD!8.by-man balUl fa ,n Ble.dioIs. inltiJI h e I t : ~ . IQ: 1f}IIJU were registered to vote befor!, fill out below:

'"

. I Are voo a U.s. citizen?

Win yDII tie 18 or older by the next electiOll?

0 No '!>-A "110' ,nwir ID sither question 1I18US JDB CAtlQOT fu i l le r tD .ala

.1U'T1!S ORo

!:,~ : , ; Questions. p r ~ i l e m s ", . ,.oUo ,epotHtiiid:

-:O•' ; : ' ~ ':.; '.';. . . _. : .. :.. . $"...' ~ < . . Contact the ? e . ~ ~ 4 t t y of State.

..# ~ : i ~ ' . . . . . ., . _ c . ~ n ; , l . . a O . D ~ ~ V O T E (868)}-Email: [email protected]

· t ~ W l ! ! h s t e : ' ~ w w . S O S . C 3 . g 0 Y

130001

Or contact \lour county elections. office.

I.m

•

]

-~ D ~ l t 9 i f , o u Q A l I e l p o l l w o r k e l . { l J A i I i a ; I N 1 . I J I d O k I l P ~ ______

oelled li n f, w CIlI a poUinl piau Gn day.

B. Ycorlll1ni':ityIrauo __________

Cba:t)'IUI lanptfe Orelerelm DEnpslt D S / l I ~ I P I ~ 5 ; 1 l 1 i l u l

OCbrIlR OYietlllroest O K o r l . l ~ Obg.1vg Olipane5'!1':2 Y ~ t o.gil t''i->l T"a.Io(f EI$Mi

Did suneone lIelp you flU out IIr d&IIY8t tbis farm1lljES,b"IIfIIIrI*' helped,., GUSI fil1lt4ld sip baIlr)llbIf m KIIIlDIrIIt.

S/pmR iiiiiii'IiOj'1iiiI



Exhibit 2



Dates: Nov 30, 2001 - Dec 3, 2001

Q Professional License(s):[None Found]

FAA Certifications:[None Found]

1}- FAA Aircrafts:[None Found]

!<

Watercraft:[None Found]

MVoter Registration:Name: DAMON DUNNAddress: 2058 KNOLL CREST DR, ARLINGTON TX 76014-3686DOB: 311511976Gender: MaleState of Registration: TexasStatus: INACTIVE

Name: DAMON J DUNN

Address: 10135 GATE PKWY N APT 1111, JACKSONVILLE FL 32246-8264DOB: 3/15/1976Gender: MalePoli' . MOCRAT

te of R.,gistra I . FlondaStatus: ACTIVE '

" ' - i E ~ I u n t i J 1 ; g 1 F i i ! l s i f 1 h ing Perm it:[None Found]

l$$ Bankruptcies:

[None Found]

IF Liens and Judgments:[None Found]

• UCC Filings:[None Found]

&aPossible Properties Owned by Subject:

Property:Parcel Number - 804-101-04Property Address: - 23626 VIA ORTEGA, TRABUCO CYN CA 92679-4134, ORANGE COUNTYOwner Address: 23626 VIA ORTEGA, com DE CAlA CA 92679-4134, ORANGE COUNTYSale Date - 11/1512009

Sale Price - $905,000Loan Amount - $724,000Loan Type - CONVENTIONALData Source - A

Property:Parcel Number - 804-101-04Property Address: - 23626 VIA ORTEGA. TRABUCO CYN CA 92679-4134, ORANGE COUNTYOwner Address: 1 POLARIS WAY STE 100, ALISO VIEJO CA 92656-5360, ORANGE COUNTYData Source - A

Property:

4/7/10 9:59 AM

Paae 17 of 23



Exhibit 3



OUV

.. - _ . . . ._ •• - , . . ,""" I I I IClyt:t)1

103906683

~ ~ - y " " - . · - U - . S - . - c l - ' - " ' - n - ' - ' - - - - - - y - ~ 1 ..---

1)", , : NBW n,bIo ................. '-" """"-"" tiil

. . 11 -. . ;;nntk:kd tnua I ) j f ' ~ tf ( . . . . na)'

. _ - - -

.'

I .. . Nome

DUNN

Lo".1 a. ....._ Mdteoa

1OI.l50ATE PKWY N I ll ...

.. : N ~ . . rNili&,.·"'i .... b u , ~ e c '. . '. -' ... ,

.....mx 'Fina Namoo

DAMON- - - - - - - - - - - - - - -

city

JACJ{.WNVlLLE

_ i ' . " ~ ; . l " .

N i i ~ ..·"'Adif...,.: ...I " \ ~ ...... · ~ I ~ . "

tOlT ; '!

lb."" _ . ' - - ~ .. . ...ny .. ~ . p . e ' t d : d lAc ODI)· ;

{If", 111 .. lIlY . 4 ' ....) bIIa Mea IClPaRd.~ E - ~ iddlt w;,;;- - 4 s"" , , - ,

JEIUlU LM _ i

7Jp O><k . . .-- - - . ~ i'lL 32246-0000 I___ __ ------r- .._. ,_ 1

"

,1':-

-: .'.

- - - - , . . . , -" . . , - - - - - -

A s a _ ~ 1:0 rcuUu' " , ~ L

--"'1.. ,

~ - - " .. G41221911 13:03 10S042

Scan Oat•• lo131noro

: ,

.

".~ . , . . - .. ~ - ~ - ~ . , . ~ - , . - - - . - .

"'.,.............,. -11"\ .. .c. -• ... ." ........ - . ; " i ~ ..... VcM .t du. oflk.e will canaan oonfids:twal .nd u.K4 fQl VOWf resi.u.aion pu.rpoec:e ~ l G l y . DillCto.uflO of)"f'W'



Exhibit 4



COPY CERTIFICATION BY DOCUMENT CUSTODIAN

County of --'0...-""""""'.;"'''''''''1;'--_________

I, OJ1-1 7c;z; f'i\ . . / Name of CustodIan of Original Document

, hereby d e c l a r ~ that the attached reproduction of

;4[,,0/ /!J,c20ID & ; 1 d " - r t 2 ; ~ ; - e A b 2 1 ~ , DescrtpHon of Original men! V

is a true, correct, and complete photocopy of a document

in my possession or control....--'.---.... -,,-"1· . - - - -

Subscribed and swom to (or a:1ftrmed) before me on this day of - - . J : ~ . E - _ _ _ _ _ '

2 0 ~ by 0 lZ. '-" T A IT2--____ - - - - - - - - ~ proved to me on tlle basis , factory evidence to be the pers0nts) who appeared before me.

Signature(Notary ~ e a l )

- - - - - - - - - - - - - - - - - - - - -OPTIONAL- - - - - - - - - - - - - - - - - - - - -Though the information below ;s not requirsd by law, it may prove valuable to persons relying on the document and could prevent

. raudulent removal and reattachment of this form to another document.

Further Description of Attached Document

Title or Type of Document: LT/L pll<>M f \ , - fUJizrSrI.e.

Document Date: ~ ~ . l . . \ ~ , Z .. ,0 Number of Pages: ---'___

Signer(s) or Issuing Agency: _ . r ~ MIre-.1: ti-r""J"

Capacity Claimed by Custodian

o IndividualD· Corporate Officer - Title:

o University or School Officer - Title:o Governmenta1 Officer or Agent - Tille: ____________

o Business Proprietor or Manager

o Attorney

o Trustee

o Other:

Custodian Is Representing: __________________

© 1995 Nafilmal Notaty AsSODlaflon ·8236 AemmetAve., P.O. Box 7 1 B ~ • Canoga Park, CA 9 1 ~ 0 9 · 7 1 B 4 P.rod. No. 5909"

RjQHTTHUMBPRINT

OF CUSTODIANTop of thumb here

Reo(der: Call Toll-Free 1-800-876-6827



JERRY HOLLAND

SUPERVISOR OF ELEcrlONS

OFFICE (904) 630-1414CELL (904) 318-6817

April 13, 2010

OFFICE OF THE SUPERVISOR OF ELECTIONS

Dear Sir or Madam:

105 EAST MONROE STREET

JACKSONVILLE, FLORIDA 32202FAX (904) 630-2920

E-MAIL.jHOLLANOOCOj.NET

I am writing to document my correspondence with Mr, Damon Dunn. On July 10, 2009 Mr.

Dunn contacted ou t office via telephone and asked for his ineligible voter registration record

to be removed from the Duval County database. I contacted the Division of Elections later

that day to inquire if this was possible and the Legal Department for the Division informed

me that the record could not be deleted from the database because voter registration is

permanent record.

I then mailed a letter to Mr. Dunn informing him of my findings. I have not had additional

correspondence with Mr. Dunn since this incident.

Thank you,

C)1Jean Marie Atkins

Director of Voter Administration



J (Audit)

DUV 103906683

_ ~ ~ ~ ~ ~ _ _ _ _ _ _ _ __, _ c . n ~ . _ ! O P ~ ~ ~ ~ ~ ~ __ ~ ' - ' T F ~ e l a = = - = j N e ~ ~ ~ ~ ~ = = ~ = - ~ = = ~ ~ ~ ! ~ ~ i u e - = = - - = - J :6/16/200512:12 PM !DUV 'Vrsys ISttus· IP I '

- - - - L - - ~ - - -1.- -- ~ - - - - - - - - ..------ '- ' ---------.--.----,6/161200512:12 PM !DUV :Vrsys ,Reasn IR (R(P) Returned Mail, Inactive :A (A(I) Inactive)

[3/1720043:33-PM--i6Dv--iPhi i l jPs-----tsi reC---- i ~ ' ? t e l P k W Y I N trGiifefPkYiN-

' . ._._._ .. _._--------'--- _.-- -- - ......... -- - - - - - - - - ' - - - - - - - ~ ..---------------,:10/311200312:00 AM : ~ 8 H e n r y :comm-In iscanned Front of Card Img It'-Oi3-o12otY33:-1-tfpM... - - - ~ - - - - - - - 1 V r s y s - ~ o m m . : f n - - r s c a n n e c r F rantaf Card I m g - - ~ S r g a t u r e oo-nverted from Old_. _ _ _ ... ___ • _________________ -+----_____ :- __ _ •____ __________ ______1__________________________ ~ S - V § . ~ ( l I - -., __ . __ .. __________ _

311412002 12:00 AM : YrSys IComm-Out iFinal Notice ;Converted from Old Duval________________ -..-:._____ ___ ____.l.____.__ _ ... ____________.. __________________ - - - - - . : . . S - - - ' i s t ~ J n

•



Exhibit 5



damon dunn Duval County.doc

-----or ig inal Message-----

From: Ge n Rajska [mailto:[email protected].]

Sent : Wednesday, March 10 , 2010 11:46 PM

To: Holland, JerrySubject: Registration i s Public Record

Dear Sir :

May we know the party aff i l ia t ion of a certain Damon J . Dunn. He wasknown as a Democrat, bu t he claimed to have switched to Republican.

DO we have any record that he changed to Republican? I f we, when did he

do i t ?

Thanks fo r any information.

Very t ru ly yours,

Fel ici to Papa

Reply

Forward

Reply

Holland, Jerryto me

show detai ls 9:07 AM (3 hours ago)

Good morning,

In further response to your questions Mr. Dunn was registered as aDemocrat an d we do no t show any change o f p a r t y .

Thank you,

Jer ry Holland

Page 1 of 1

https:/ mail.googJe.comlmail/?ui=2&ik=a3a25723cf&view=att&th= 1294425c271d3ae5&a... 6/16/2010--------



Exhibit 6



RECEIVED AND FILEDT y p e l ' l ~ n Ink. I n t h e O ~ ( b e ~ o f S l 8 l e CANOIDATE INTENTION STATEMENT

V U py of Stete o b ~ 1 8 o Amendment (Expl.Bln) 0'1 1 S 2()()9

Candidate Intention StatementCALIFORNIA 501

FORM

For Official Use Only

Check One: 1&1 Initial

=========-______ ~ = = = D E B R A B O W E N 8Tretary of State

1. Candidate Information: \ '? '2.- 'Z--r: '7 (NAME OF CANDIDATE (Lest. First, MJddJe II'/itisl)

Dunn, Damon J.

STREET ADDRESS

2070 Business Center Drive, Suite 140

DAYTIME TELEPHONE NUMBER

( 949 ) 660-0716CITY

Irvine

FAX NUMBER (opUooal) E-MAIL (optJon8l)

STATI: ZIP CODE

CA 92612OFFICE SOUGHT (POSITION TITLE)

Secretary of State

AGENCY NAME

State of California

DISTRICT NUMBER, "appIcabht. \D N O N ~ P A R T I S A N nla PAR1Y: Republican

OFFICE JURISDICTION

Jia State (Com",'" Pa" 2.)

o City 0 County 0 MUlti-County:(Mams ofMWti-Coul1ty Juri!dlctlOn)

2. State Candidate Expenditure l imit Statement:(CaIPERS candidates, judges, judiclat candidates, and csndidale$ for local offlces are not required to complete Palf 2,)

2010 Primary/general electIon(Year ofSection)

(Cn&c/{ OM bO:K)

"'===;;-SpeclaVrunoffelection(YesrofE/ecllon)

IKJI accept the voluntary expenditure ceiling for the election stated above.

oI do no t accept the voluntary expenditure ceiling for the election stated above.

Amendment:

(Veer of Section)

o I did no! exceed the expenditure ceiling in the primary or special election held on: ----1----1__ and I accept the voluntary expenditure ceiling for the

general or special run-off election.

---......_--

(Mark If app/lCllble.),o On - - - -1 . . . . , - -1- - . I contributed personal funds in excess of the expend""re ceiling for the election stated above.

3. Verification:

I certify under penalty of p e ~ u r y under the laws of the State of c a l i f o m ~ . 9 0 i ~ Executed on 11/05/09 Signature tv

month. day; year.) (Candldat&)

t t l

FPPC Form 501 (JanuarylOl)FPPC Toll-Fre. HOlpllno: 866/ASK-FPPC (8661275-37721

k

...



Exhibit 7



Date Signature of Candidate

State of California

County of Orange

}

}

55 .

Subscribed and sworn to before me this fu0- day of J A ~ ,2010.

Notary Public (or other official)

Examined and certified by me this /rM day of L i 2010.

NEAL KELLEY, Registrar of Voters

WARNING: Every person ,acting on beflalf of a candidate is guilty of a misdemeanor who deliberately fails to file at !he proper time and in ihe proper place any declaration of candidacy in hislher

possession which is entitled to be filed under !he provisions of the Sections Code (Bections Code Section 18202).

OATH OF OFFICE

I, DAMON DUNN, do solemnly swear (or affirm) that I will support and defend the Constitution of the United States and

the Constitution of the State of California against all enemies, foreign and domestic; that I will bear true faith and

allegiance to the Constitution of the United States and the Constitution of the State of California; that I take this obligation

freely, without any mental reservation or purpose o ~ a s i o n ; and thaLl will well and faithfully discharge the duties upon

which I am aboutto enter.

State of California

County of Orange}

}

55 . Signature of Candidate

Subscribed and sworn to before rne this I 0 day of__ J I ' v t . . : . . : . . : ~ : . : / ~ I - , ~ ___ 2010.

Examined and certified by me this h>K day of ,2010.

NEAL KELLEY, Registrar of Voters By ~ / ? Certificate as to Candidate's Political Party Affiliation

/Elections Coda Section 8D01.

State of California

County of Orange}

} ss.

I hereby certify that (1) at the time of presentation of this declaration and continuously for

not less than three months immediately prior thereto, or for as long as he/she has been

eligible to vote in the state, the above-named candidate is shown by his/her affidavit ofregistration, executed on J -/7- 0"1 ' to be affiliated with the political party the

nomination of which he/she seeks. and (2) the candidate has not been registered as

affiliated with any other political party for the twelve-month period immediately preceding

the filing of this declaration.

Dated this 10/1. day of J A . , , ~ , , ~ ,2010.

Prior Registration NEAL KELLEY,

Deputy

Registrar of Voters _ - - - -

By ( - ; I l t l : : : > c : : ; ' - : : - ~ , 'Deputy

Party Affiliation

rJl) rrJJr

Declaration of Candidacy - Partisan 2010

AU code section references are to the Califamia Elections Code unless stated otherwise.



Exhibit 8



TO BE VERIFICATIONENTERED

BY CLERK NAME RESIDENCE. (TO BE

ENTERED BY

CLERK)

6.r- ~ E N C E A D D ~ 3 l : ~ . l J ' ,(J1l.I:

------

...--.Ri",-1:r

,

--->--.....::J • < " - J "--./ ~ I ~ ;S I G ~ .. ./ CITYORTOWN 1..... ?

7. V....,

•PRINT VFTfl_l" [ I C - ; - o . - RESIDENCE ADORESSDNlY ' - . T <r 3 {; <A !)IC !-Ill

Si C I T Y O R T O W N ~ A G-o l J ~ Woe l l S

B.

PRiNT M A"1o l--{ STbV RESIDENCE ADDRESS ONLY S S 4-? l / (ri- O [e-H Cl..

S - CITY OR TOWN LA &-v oJl\ I.vo ~ L ' > . i -9. ,

PRINT RESIDENCE ADDRESS ONLY

SIGN CITY OR TOWN

10.

PRINT RESIDENCE ADDRESS ONLY

SIGN CITY OR TOWN

AFFIDA VIT OF CIRCULATOR(To be completed In circulator's own hand)

§8041(b)

I, De-r.rr7i G. $..ueZAtZ.. , solemnly ~ w e a r (or affirm) that the signatures on this section of thenomination paper were obtained between 03 - 01 ,2010 and e:>3 _ ot.. ,2010; that I circulated the

petition and I witnessed the signatures on this section of the nomination paper being written; and that, to the best of

my information and belief, each signature is the genuine signature of the person whose name it purports to be.

My voting residence is: 1/53'2, EIt1(£ Ave tlJl'IfU>EN GI(i.DV€ 9 ' Z . . ~ 4 0 Street Address City Zip

I certify under penalty of p e ~ u r y under the laws of the State of Califomia that t h ~ f , . Q ~ " ~ , - ,•• - . ~ "_4 ~ - r e c t . . ,

Date: 03.-0'1- zP/D Signature of Petition Circulator: .. _ - ; = = : : - : : ~ Signature of Pe. __ .. _.___ . ~ .

Subscribed and sworn to before me t h i S _ . . L ~ - , - - - - - _ l o _ \ ' \ _ day of . . . . . . 1 1 ~ 4 f . f l l ' l ! + H ~ g : z ' - - ' ~ ~ ~ : : . . . . . _ _ _ "2010.

STATE OF CALIFORNIA

COUNTY OF DR.:Au6€.

Subscribed and swo (mto affIrmed) before me: Ffl&:stlll'. k

A Notary Public on this 100k.dayof t i 1 a . t e i . - ' ' - - L l L ~ l J . ! ~ ' - - - J ' : : L : : U D A A 9 . f , £ J g ; ' ' ' ' ' ' ' ' ' __\ D a t J ~ G, S A l . A ~ f Z . . . ~ = = = = = = = = = 2 ~ O I ~ ( ) = - - - " by

FARSHID FADAKAR~ Q ~ ~ J ! F 9 4 6 4 4



OFFICIAl FILING FORt.!

NEAL KELLEYREGISTRAR OF VOTERS

8 Y ~ O A r : ~ U ' O Vb 20

NOMINATION PAPER

(Elections Code Sections 100. 104.8041.8062.8066,. 8068. 8069;

Code of Civil Procedure Sf;lction 2015:5)

3 1page_tL_ of

CONTESTlD: 1042c::ANDIDATE 10: 1

I. the undersigned signer. for .DAMON DUNN, f9rthe Republican Party nomination to the office of Secretary

of State, to be voted for at the Statewide PtimaryElection 10 beheld June8,201O,hereby assert asfollows:

I am a resident of &!WhIR County and registered to vote.althe address shown on this paper'

and affiliated with the Republican Party. lam not at this time a signer of any nomination paper of any other

candidate for the above-named office, or in case there are several places to be filled in the above-named

office, I have not signed more nomination papers than there are places to be filledin

the above-named office.

My residence is correctly set forth after my signature hereto:

ENTEREO

BY CLERK

S

A

MPLE

5.

NAME RESIDENCE

1234

RESIDENCe ADDRESS ONLY

Please complete Affidavit of Circulator on reverse side •• >

•



Exhibit 9



SHELL FLEMING DAVIS ME Fa, 8504391872 Apr 16 2010 10;39am P001/009

SHELL, F L E M J ~ G , D"Avis & MENGE

A TTQ R ~ : N ; E L x s ' A t I ' , ; ; ; i ; A W," -, " ", i' . -. - " ;, / ' ..... ,,,.,

, " , /. ,"

" ' ' ' : : ' .,', ";\, - "

FA C S I l < I l , ~ E ' r ) t { \ N S ~ t i ' t A ; i ; Sit E E T.: :" ;; .{ ' .-( ,,":: - ,:' "' , I ' , " ' " :

TO:

OrlyTaitzCOMFANY: .

FAX N{)MBER:

94W7(i6-7603

PHONE N\il<I!lER:

949-683-5411

o VRGEl'I! o FOR REVIEW

NOTES/COMMENTS:

';:: "" ,-'.. FR¢i.!i;-.;;>,

..... 'Dap!lY,L. Kepner'-.. ~ : " "-" '

, J'''

'F' ~ , A G E S INCLUDING COVER:

. '.""

"

,; .

0'

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sWrj{i:.s i , 1 l i ) i ; ~ I ' l } M " U ' a50;454'2411

,,,' , , " , , ' " - '

.YOlJAREEI:RENCB Nl!MBER:

'<m9,8:24757

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P()'S'T: { ) ~ F : t ' i , C E 1 i q . X 183 I

o PLEASE RECYCLE

:22 6 SQUtR'pAtAFQ'X'15TREETN INmo,tiii'ooR;o'S,E:Vfi.t.E TO WER

P E N S A C O } * ; ' F L 9 R : : r ~ A ; 3 ) ' 5 9 8 -18 3 J

TELEPHONE (sso{4:it;i4i'("WA,:.,C.:;;IMILE (850) 435-1074': ","; ;:,. .' " :." .::';-;. ,':., '.:

-.;..



Aprlll(i, 2010

Page 3 of3

SHELL F L E M I ~ DAVIS ME Fax 850d3918r2

bee w/enc.: OrlyTaitz, Esq. (Via Fax Ollly)

Apr 16 2010 10:39am P002/009



. . , '

. ,-" :" :'r, t - : '.: . .'.-'!,', :) : .

POBOX 1 , 8 3 ! ; : 1 ' 1 t l i ~ ' i C , ? 4 ; ' P I , 3 . ~ ~ "T E i . B P K Q N i ; ~ , ( $ S O j J " . ~ 7 7 6 7 : "

E ~ M A l L . : : · ~ ~ , € ~ ~ ) : ~ ~ b f r i r i . ~ ~ , n ' ~ ~ ~ ,. .

Honorable Edmond G. Brown, Jr. : '::".":':Attorney Geneni,Vs Office

Califumia Department of JusticePO Box 944255' •

Sacramento, CA 94244-2550

Re: Damon DUnn ' " , ,

Candidate for Secretary o f S t a t e o f C ~ ~ r ; i l i I I . .. , . ' ' '- "" .

Dear Mr. Brown:' (

.

Please accept the following i h f o r t n a f j , q ! 1 r ~ l a t i n g t9'$i:: ,\:lUldidacy of Damon Dunn (as aRepublican) fotthe office o f S e c r e t a r y / ) f ~ # t ~ 9 f C ~ t t # ! t ' r t appears to me that Mr, Dunn isbeing less than. honest with the voters, bu,t f u ~ ~ i i ~ t n p 6 r t i : l ( i t l Y , ! e s s , t h a n honest in his dealings withthe election officials in your state. ' , ', '"

I have (although I have n o ~ " i : ~ ~ ; l e , d i t ) a : C - ! : i j l Y ' o f Mr. Dunn's California voter, .' '.', .. " ,-","-, -' .-. . . . . ."

registration cant on which he simply l e f t b J i ! J 1 k : t h ~ l l i q t i i r i e s ~ , a b Q u t any prior registration to vote,

the state where tegistered, and party affiliai,i9,)i;Mr. b # ' w ~ { l ' a s t registered to vote in the Stateof Florida, as a, Democrat. Failure toanswet f ~ r m q i 1 # t i 9 n s like these, it seems to me, is

tantamount to fraud" . ' ' : : >:::

Enclosed are copies of c o r r e s p o n ! i e n ¢ l : i ~ f r o , m ~ t ) # l c e o f the Supervisor of Elections in

Duval County, Florida. The March 3"0 l e u < i ; l i a s a l t i i c h e q . i G ' i j i / } , ~ r : Dunn's voter registration card

from 1999, and&: record of that o f f i c e ' ~ h l U i 9 1 m g of ~ i s ~ l ~ w . s : . - from active, to inactive andeventually to "ineligible." The copy oftbe)l4YIO,Z.01:J9,J#6rauthored by Jean Marie Atkins,Director ofVoter Administration, i s s j g n J . n g ! l i i ~ e s p e c i ! I I l Y i i l i ) J . e n considered with the letter she

wrote on April 13,2010, which is also e n c l h s e ( r ~ ¢ r i I l . " ';,', . I

In July, 2Q09, Damon Dunn a s k e c l t i i ~ ( : j e < ; t i o l ; ) ~ f f i e i l l i s t o remove the record of his priorregistration (as aDemocrat). Under Flopdiihi,w,§Uqh:li !'ePt<walwas not authorized, and he wasso informed, Had he been s u c c e s s f u 1 : i ; i : ~ i s : @ t . ; j ~ , . ~ e w ' < \ u l d have given "cover" for hisintentional misrepresentation on his voter regi'sttaiioi'icaro;',,;JIe':knew he had been registered in

Florida as a Democrat; he just did not w i t . 1 . i . a n y ; o n e e i ~ ~ . t Q k;tiow;that., ' v. ' " --,



'April 16, 2010Page 20f3

SHELL FLEMING DAVIS ME Fax 8504391872, - ' " . ;<'

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My questions to you is whether t h e S e ' ~ o n ~ ,bVMf; Dunn constitute criminal behavior

punishable under California law? . a i l i f ' o i J : l i ~ ~ I - e ~ i r i , : s : : ' ¢ t J d e § 18500 would appear to beimplicated, andp'erbaps § 18203, as welI'.jsJili,e • vt#lias4iiJappears highly unethical, and may

fonn the basis fQl:having his namer e m o v e < l ~ ~ ' t h e ..l j a j : W ! , f o ~ t h e

upcoming primary election., ' . ';-;" ;-,' . ' -. ' ~ : . " . ~ ; .

Thank you for looking i n t o t h ~ ~ ~ e t s . · ' r W O \ l t ~ ~ p r e c i a t e having a response from, . ' '., ", ..."':".

you. " ~ : ' .

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DLK:hr

Enclosure

cc: Debra Bowen ' ..

Secretary ofState of California

WilliamMcCu1 1 u t n , ' ..... .

AttorneyGeneral, State o f F l o r i d ~ . ~ " . ' -

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Exhibit 10



Report

243 MARGARiTA AVE. PALO ALTO CA 94306-2823 SANTA CLARA Sep 1999 - Apr Map2003

2058 KNOLL CREST DR. ARLINGTON TX " 6 0 1 ~ - 3 6 8 6 TARRANT Oct 2002 Map

10135 GATE PKWY NAPT 1111. JACKSONV!LLE DUVAl Aug 1998 - May MapFL 32246-8264 2002

610 NEWCASTLE LN. G R , ~ N D PRA.!RIE TX 75052-4411 TARRANT Sep 2000 - Mar Map

2002

ARRILLf'.GA FAMILY CENTER, P!\LO ;\ LTO CA 94305 SANTA CLARA Aug 1995 Map

ARRILLAGA FAMILY CN, PALO ALTO CA 94305 SANTA CLARA Aug 1995 MapARR'LLAGA FAMILY, PALO AL ! 0 CA 94305 SANTA CLARA Map

Active Address(es): V:ew.1I1I Acldress Variation Sources

" ;1126 E THUNDERH1LL PL. PHOeNIX I\Z 85048-4603. MARICOPA COUNTY (2002 - Apr 2010)Name Associated with Address:

DAMON DUNNCurrent Residents at Address:

HANNA L LULGJURAj-MURRAY

EDWIN GLYNN MURRAYLESL ' J BONDYHANliA LULGJURAJ MURRAYDELILA A JUNCAJHANNA MURRAY480-460-2244 MURRAY HANNA

Property Ownership Information fo r this Address

Property:Parcel Number -

Name Owner: BONDY, RON & LESLYProperty Address: -1126 E THUNDERHILL PI., PHOENIX i'Z 85048-4603, MARICOPA COUNTYOwner Address: 1126 E THUNO:::RH'LL PL. PHOENiX I\Z e.f5048-4803, MARICOP!\ COUNTi'

Name of Seiler: DUNN DAMON JData Source - A

Property:Parcel Number - 300-97-216

Name Owner: BONDY RONName Owner 2: BONDY LESLY

Property Address: " 1126 E THUNDERHILL PL, PHOENIX AZ 85043-4603. MARICOPA COUNTYOwner Address: 1'126 E THUNDERHILL PL, PHOENIX AZ 85048-4603. MARICOPA COUNTY

Total Market Value - $427,000Assessed Value - $42,700Land Value - $85,400Improvement Value - $341,600Land Size - 13,212 Square FeetYear Buitt - 1997

Name of Seller: DUNN DAMON JLoan Amount - $650,000Loan Type - CONVENTIONALLender Name - FIRST HORIZON HM LN CORPData Source - A

Property:

Parcel Number - 300-97-216Name Owner : LULGJURAJ-MURRAY UVING TRUST

Property Address: - 1126 E THUNDERHILL PI., PHOENIX .LZ 85C43-4603. [.1ARICOPA COUIHY

Owner Address: 1126 E THUNDERHILL PL. PHOENiX AZ 85048-4603, MARICOPA COUNTY

Total Market Value - $592,600Assessed Value - $59,260Land Value - $118,500Improvement Value - $474,100Land Size -13212 SF

Year Buitt - 1997Data Source - B

Neighborhood Profile (2000 Census)Average Age: 29

Median Household Income: $107,230Median Owner Occupied Home Value: $273,700Average Years of Education: 16

4/7/109:59

PaQe 3 of



Exhibit 12



....SHELLJLEMINq DAVIS ME Fa.x ~ 5 0 d 3 9 , 1 8 7 2 Apr 16 2010 10:dOam P005/009

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OFFICE OF THE SUPERVISOR OF ELECTIONS" ' , - , : ." ' . . ; . ::,.,; ,->.,.:. -:,

JERRY HOLLAND

SUPERVISOR OF ~ L E C T I O " S OFFICE (904)6.'0.'7'7

10; EAST MONROE STREET

JACKSONVILLE, FLORIDA 32202

fAX \SI04) ()30-2920

E-MAIL [email protected] (90<, ,18-687)

March 30,2010

Mark LorenChief Investigator

Election' Fraud Investigation 1)nitSecretary of State '

1500 11 thStreet

Sacrameoto, CA 95814

Dar 1\1r Loren: '. . . ..

Damon J. DUM registered in the Dl.ivafCtlu!Ilyon},Jlly.12, 1999. as a Democrat. usingthe a d d r e ~ s of 10135 Gate' Parkwjly, North;, #ltlI;) Jacksonville, Florida Records

indicate that in March of2002ML P U r t n ' s ' t e g l . ~ f t t ~ O I ) , w a s converted to the statewidevoter registration database and at, t h a H . i r o : t e ; : 1 , e c a i : i S f o f ~ ' d a c t i v i t y on his record, his statuswas changed from an active votev t'Q:q,ninactw.eiVQtet. Due to our office receiving

r e t u m e d r i : : t ~ i 1 from that a d d r e s s a n p ; : ; t h ~ e b e , i n g n 0 i a . c i i V i t y on his voting history, Mr.

Dunn's status was changed f r o n i · a ' n i H a ~ t i v e : v 6 t ¢ i t q * H 1 e l i g i b l e voter on June 6, 2005.

Mr. Dunn would be required tOl'Negi:;terin b l . l v ' < ? i ) ~ u n t y i f he wanted to have votingprivileges in Duval C O W l t y ~ . . ' .' . . ' "

We have: enclosed a copy of l\1r • D W ! n · ~ Q r j ~ i n a l . · · · .•2 . · l p ' , p l { ~ a t i o n with non-public recordsinformati'on redacted. Please reel free . . ' if we can be of further

assistance; .

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