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STATE OF WISCONSIN

BEFORE THE ELECTIONS BOARD

The Complaint of
DANIEL McMURRAY,
Complainant,

Against

CITIZENS FOR GARY R. GEORGE and
GARY R. GEORGE,
Respondents.


This complaint is under Elections Board Administrative Code EIBd. 2.05 - 2.07.

I, Daniel McMurray, allege that:

  1. I am a qualified elector in the State of Wisconsin residing at 305 S. Park St., Apt. A, Madison, Wl 53715.
  2. Respondent Gary R. George (George) is a candidate for the office of Governor of the State of Wisconsin and represents the 6th District in the Wisconsin State Senate. He resides at 4011 West Capitol Drive, Milwaukee, Wl, 53216.
  3. Respondent Citizens for Gary R. George is George's campaign committee. The mailing address of the committee is 1100 West Wells St, Ste. 1711, Milwaukee, Wl 53233.
  4. On or before July 9, 2002, nomination signatures were filed with the State Elections Board as required under Wis. Stat. § 8 by representatives of Citizens for Gary R. George. Elections Board auditors did a cursory review of these signatures on or about July 9, 2002, and found 2072 apparently valid signatures.
  5. In violation of El. Bd. 2.05(12), 33 signatures on the Respondent's nomination papers list addresses that are not valid residential voting addresses either because they are business addresses or because they do not exist. The page and line numbers of these signatures are listed on Attachment A.
  6. I individual who are listed as having signed the Respondent's nomination papers have provided affidavits indicating they did not sign them, a violation of El. Bd. 2.05(9). That affidavit is included as Attachment B.
  7. 16 individuals who are listed as having signed the Respondent's nomination papers have verbally indicated to me that they did not sign them, a violation of El. Bd. 2.05(9). Those contacts are listed on Attachment C.
  8. In violation of El, Bd. 2.05(9), a certified forensic document examiner has stated that 84 signatures collected by Dave Begel, Debbie Thao and Locha Thao are forgeries. That statement and supporting documents are included in this complaint as Attachment D.
  9. In violation of El. Bd. 2.05(9), upon information and belief, because numerous signatures collected by Begel, Debbie Thao and Locha Thao are forgeries, all signatures collected by them are invalid.
  10. In violation of El. Bd. 2.05(9), upon information and belief more than 65 signatures on the Respondent's nomination papers appear to have been forged. There are multiple instances of signatures that appear to have been signed in the same hand. Those instances are listed on Attachment E.
  11. In violation of El. Bd. 2.05(12), 17 signatures and/or addresses are illegible or incomplete, and upon information and belief, are not the signatures and/or addresses of valid electors. Those instances are listed on Attachment F.
  12. No signatures on papers circulated by either David Begel or Debbie Thao could be verified as having signed the nomination papers. Every contact made denied having signed the nomination papers and the papers seem systematically filled with illegible names, incorrect or non-existent addresses and signatures that appeared to be forged. In the short amount of time available for verification, three days since the filing deadline, many other signatures could not be fully researched and the individuals contacted, but are likely to be similarly flawed. For this reason, I have attached all pages circulated by either David Begel or Debbie Thao.

I hereby ask that the State Elections Board disqualify these signatures and take whatever other action it deems appropriate, including the denial of ballot access to the Respondent.

I, Daniel McMurray, being first duly sworn on oath state that I personally read the above complaint, and that the above allegations are true based on my personal knowledge and, as to those stated on information and belief, I believe them to be true.

Daniel McMurray
STATE OF Wl
County of Dane

Date: 7/12/02