Supreme Court of Ohio Clerk of Court - Filed August 26, 2020 - Case No. 2020-1044 Case No. ?upreme 03mm of the ?tate of @bt?n STATE OF OHIO ex rel. KANYE WEST, and STATE OF OHIO ex rel. MICHELLE TIDBALL, Relators, V. FRANK LAROSE, Ohio Secretary of State, Respondent. Original Action in Mandamus Election-Related Matter VERIFIED COMPLAINT FOR WRIT OF MANDAMUS Curt C. Hartman (0064242) David A. Yost (0056290) THE LAW FIRM OF CURT C. HARTMAN Ohio Attorney General 7394 Ridgepoint Drive, Suite 8 Bridget C. Coontz (0072919) Cincinnati, Ohio 45230 Section Chief, Constitutional Of?ces Section (513) 379-2923 OFFICE OF THE OHIO ATTORNEY GENERAL hartmanlawfirm@fuse.net 30 East Broad Street, 16th Floor Counsel for Rela tors Columbus, Ohio 43215?3431 Kanye West and Michelle idball (614) 728-2035 Bridget. Coontz@0hioA ttorn ey Gen eral. gov Counsel for Respondent Ohio Secretary of State Frank LaRose SUPREME COURT OF THE STATE OF OHIO STATE OF OHIO ex rel. KANYE WEST Case No. c/o Curt C. Hartman, Legal Counsel 7394 Ridgepoint Drive, Suite 8 Cincinnati, Ohio 45230, and STATE OF OHIO ex rel. MICHELLE TIDBALL VERIFIED COMPLAINT c/o Curt C. Hartman, Legal Counsel FOR WRIT OF MANDAMUS 7394 Ridgepoint Drive, Suite 8 Cincinnati, Ohio 45230, Relators, V. FRANK LAROSE Ohio Secretary of State 180 East Broad Street, 16th Floor Columbus, OH 43215-3431, Respondent. The STATE OF OHIO, by and on relation to Relators KANYE WEST and MICHELLE TIDBALL, brings this action in order to obtain: the issuance of a writ of mandamus to compel Respondent FRANK LARO SE, the Ohio Secretary of State: pursuant to RC. 3501.39, to accept the Statements of Candidacy and Nominating Petition of KANYE WEST and MICHELLE TIDBALL as candidates for President and Vice-President of the United States; and (ii) pursuant to RC. to certify for placement on the of?cial ballot for the forthcoming general election to be held on November 3, 2020, the names of KANYE WEST and MICHELLE TIDBALL as candidates for President and Vice-President of the United States. 1. Relator KANYE WEST is a citizen of the State of Wyoming and, as developed below, previously filed with the Secretary of State a Statement of Candidacy to be a candidate for President of the United States at the general election to be held on November 3, 2020. 2. Relator MICHELLE TIDBALL is a citizen of the State of Wyoming and, as developed below, previously filed with the Secretary of State a Statement of Candidacy to be a candidate for Vice-President of the United States at the general election to be held on November 3, 2020. 3. Kanye 2020 is the principal campaign committee organized and registered with the Federal Election Commission in support of the candidacy of KANYE WEST for President of the United States. 4. Respondent FRANK LAROSE is the Ohio Secretary of State and, in such capacity, is - the chief elections of?cial for the State of Ohio. 5. Amanda M. Grandjean is the Ohio Director of Elections and a Deputy Assistant Ohio Secretary of State. 6. This Court possesses subject matter jurisdiction over this original action pursuant to Article IV, Section of the Ohio Constitution. Overview 7. RC. imposes the mandatory duty. upon the Ohio Secretary of State to: certify to the board of elections of each county the forms of the of?cial ballots to be used at that general election, together with the names of the candidates to be printed on those ballots whose candidacy is to be submitted to the electors of the entire state. 8. RC. 3501.39 imposes the mandatory duty upon the Ohio Secretary of State to ?accept any petition described in section 3501.38 of the Revised Code? unless a protest is ?led or ?[t]he candidate?s candidacy or the petition violates the requirements of this chapter, Chapter 3513 of the Revised Code, or any other requirements established by law.? 9. Within the petitions described in RC. 3501.38 are ?nominating to or ?led with the secretary of state for the purpose of becoming a candidate for any of?ce 10. Based upon information and belief, no protest has been ?led with the Secretary of State concerning the Statements of Candidacy and Nominating Petition of KANYE WEST and MICHELLE TIDBALL to be candidates for President and Vice-President of the United States. 11. Neither KANYE WEST, MICHELLE TIDBALL, nor Kanye 2020 have received any notice from the Secretary of State that a protest has been ?led with the Secretary of State concerning the Statements of Candidacy and Nominating Petition of KANYE WEST and MICHELLE TIDBALL to be candidates for President and Vice-President of the United States. 12. Thus, absent the establishment of a clear violation of the requirements of Chapter 3501 or Chapter 3513 of the Revised Code, or a violation of any other requirement of law, the Secretary of State has the clear legal duty to accept, and to not reject, a nominating petition tendered by or on behalf of a person seeking to become a candidate for public of?ce, and, in turn, to certify such names to the of?cial ballot to be used for the general election, including, in particular, the nominating petition ?led by or on behalf of KANYE WEST and MICHELLE TIDBALL to be candidates for President and Vice-President of the United States, respectively, and, in turn, to certify the names of KANYE WEST and MICHELLE TIDBALL to the of?cial ballot as candidates for President and Vice?President of the United States, respectively. Legal Framework on Statements of Candidacy and Nominating Petitions 13. RC. 3513.257 provides, in part: Persons desiring to become independent joint candidates for the of?ces of president and vice-president of the United States shall ?le, not later than four p.m. 1'4. 15. of the ninetieth day before the day of the general election at which the president and vice-president are to be elected, one statement of candidacy and one nominating petition for the two of them. The prospective independent joint candidates? statement of candidacy shall be ?led with the nominating petition as one instrument. All nominating petitions of candidates for of?ces to be voted on by electors throughout the entire state shall be ?led in the of?ce of the secretary of state. No nominating petition for the of?ces of president and vice-president of the United States shall be accepted for ?ling unless there is submitted to the secretary of state, at the time of ?ling the petition, a slate of presidential electors suf?cient in number to satisfy the requirement of the United States Constitution. R.C. 3513.261 provides, in part: A nominating petition may consist of one or more separate petition papers, each of which shall be substantially in the form prescribed in this section. If the petition consists of more than one separate petition paper, the statement of candidacy of the candidate or joint candidates named need be signed by the candidate orjoint candidates on only one of such separate petition papers, but the statement of candidacy so signed shall be copied on each other separate petition paper before the signatures of electors are placed on it. . .. Each nominating petition shall contain a statement of candidacy that shall be signed by the candidate or joint candidates named in it. R.C. 3513.263 provides, in part: The nominating petitions of all candidates required to be ?led before four pm. of the ninetieth day before the day of the general election, shall be processed as follows: If such petition is ?led with the secretary of state, the secretary of state shall transmit to each board such separate petition papers as purports to contain signatures of electors of the county of such board. Written protests against such nominating petitions may be ?led by any quali?ed elector eligible to vote for the candidate whose nominating petition the elector objects to, not later than the seventy-fourth day before the general election. Such protests shall be ?led with the election of?cials with whom the nominating petition was ?led. Upon the ?ling of such protests, the election of?cials with whom it is ?led shall ?x the time and place for hearing it, and shall forthwith mail notice of the ?ling of such protest and the time and place for hearing it to the person whose nomination is protested. They shall also forthwith mail notice of the time and place ?xed for the hearing to the person who ?led the protest. At the time and place ?xed, such election of?cials shall hear the protest and determine the validity or invalidity of the petition. Such determination shall be ?nal. Factual Events 16. On August 5, 2020, Kanye 2020 ?led or caused to be ?led Statements of Candidacy personally signed by KANYE WEST and MICHELLE TIDBALL wherein they declared their candidacy for President and Vice-President of the United States, respectively. 17. On August 5, 2020, Kanye 2020 ?led or caused to be ?led with the Statements of Candidacy a Nominating Petition containing a suf?cient number of signatures to nominate KANYE WEST and MICHELLE TIDBALL as candidates for election to the of?ces of President and Vice-President of the United States, respectively. 18. The ?ling of the foregoing Statements of Candidacy and the Nominating Petition was made with the Of?ce of the Secretary of State. 19. In addition, at the time of ?ling the foregoing Statements of Candidacy and the Nominating Petition, Kanye 2020 also ?led a slate of presidential electors suf?cient in number to satisfy the requirement of the United States Constitution. 20. Based upon information and belief, the Of?ce of the Secretary of State transmitted the Nominating Petition to the various boards of elections for veri?cation of the signatures thereon. 21. Based upon information and belief, the Of?ce of the Secretary of State has received reports from the various boards of election whereby the Of?ce of the Secretary of State has con?rmed a suf?cient number of valid signatures have been ascribed to the Nominating Petition for KANYE WEST and MICHELLE TIDBALL to appear on the ballot at the forthcoming general election as candidates for election to the of?ces of President and Vice?President of the United States, respectively (or for the election of the presidential electors pledged to support or vote for KANYE WEST and MICHELLE TIDBALL). 22. Notwithstanding the foregoing, on August 21, 2020, Amanda Grandjean, transmitted to legal counsel for Kanye 2020 a Rejection Letter wherein she declared: Kanye West and Michelle Tidball will not appear on the November 3, 2020 General Election Ballot as joint independent candidates for President and Vice President of the United States. [T]heir nominating petition is rejected. 23. A true and accurate copy of the Rejection Letter is attached hereto as Exhibit/1. 24. Within the Rejection Letter, Amanda Grandjean on behalf of FRANK LAROSE and the Of?ce of the Secretary of State made the unilateral determination and decision to reject the Nominating Petition with the following explanation: Under Ohio law, a nominating petition must include at least one originally signed statement of candidacy, which may be copied on the other petition papers for circulation. The statement of candidacy that was designated as the original in their filing does not match the petitions circulated. In fact, the signatures for Michelle Tidball bear no resemblance, calling into question which is genuine. 25. The Of?ce of the Secretary of State has published on its website what it characterizes as the ?Original? and ?Circulated Version? of the Statements of Candidacy of KANYE WEST and MICHELLE TIDBALL. 26. A true and accurate copy of this Comparison as published on the website of the Office of the Secretary of State is attached hereto as Exhibit B. 27. Through a footnote in the Rejection Letter, Amanda Grandjean cited to State ex rel. Hawkins v. Cuyahoga Cty. Bd. ofElections, 28 Ohio St.2d 4, 6, 274 563 (1971); State ex rel. Rust v. Lucas Cty. Bd. of Elections, 101 Ohio St.3d 63, 2004-Ohio-9, 800 1162 (2004); and RC. 3513.261 for the proposition that ?a nominating petition must include at least one originally signed statement of candidacy, which may be copied on the other petition papers for circulation.? 28. The decision of the Ohio Supreme Court in State ex rel. Hawkins v. Cuyahoga Cty. Bd. ofElectz'ons, 28 Ohio St.2d 4, 274 563 (1971), is inapposite to the present case as the holding thereof indicated that without ?at least one originally statement of candidacy, as 3513.261] requires, [a board of elections] is not under a clear legal duty to place [a candidate?s] name on the ballot.? 29. Similarly, the decision of the Ohio Supreme Court in State ex rel. Rust v. Lucas Cty. Bd. ofElections, 101 Ohio St.3d 63, 2004-Ohio-9, 800 1162 (2004), is inapposite to the present case as the holding thereof also indicated that a nominating petition is properly rejected if the petition ?did not contain at least one originally signed statement of candidacy.? Id. 117. 30. The Statements of Candidacy of both KANYE WEST and MICHELLE TIDBALL tendered to the Ohio Secretary of State contained an original signature of both KANYE WEST and MICHELLE TIDBALL. 31. The signatures on the statements of candidacy copied to the part-petitions are also signatures of both KANYE WEST and MICHELLE TIDBALL. 32. And, in particular, the two signatures on the Comparison, Exhibit B, purporting to be the signatures of MICHELLE TIDBALL: i 7 Si??a?i 1" m" Signalmru uf are, in fact, the genuine signature of MICHELLE TIDBALL notwithstanding any perceived variation between the two. 33. Additionally, only ?substantial compliance? is required with respect to the requirements of RC. 3513.261, including, speci?cally, what is necessary when a statement of candidacy is copied onto other part-petitions. State ex rel. Osborn v. Fairfzeld Cly. Bd. of Elections, 65 Ohio St.3d 194, 602 636 (1992). 34. ?The public policy which favors free competitive elections, in which the electorate has the opportunity to make a choice between candidates, outweighs the arguments for absolute compliance with each technical requirement in the petition form, where the statute requires only substantial compliance, where, in fact, the only omission cannot possibly mislead any petition signer or elector, where there is no claim of fraud or deception, and where there is suf?cient substantial compliance to permit the board of elections, based upon the prima facie evidence appearing on the face of the jurat which is a part of the petition paper, to determine the petition to be valid.? State ex rel. Sa?old v. Timmins, 22 Ohio St.2d 63, 64, 258 112 (l970)(quoting State ex rel. Stern v. Board ofElections, 14 Ohio St.2d 175, 237 313 (1968)). 35. Thus, ?the standard for reviewing technical defects in declaration of candidacy [or statements of candidacy] and petition papers is whether the defect could cause a signer to be deceived or misled.? State ex rel. Green v. Casey, 51 Ohio St.3d 83, 85, 554 1288 (1990). 36. And the Ohio Supreme Court has speci?cally held that any variation between a statement of candidacy with an original signature and the copy of the statement of candidacy on other part-petitions does not violate the requirements R.C. 3513.261 (and is not grounds to reject a nominating petition) when there is no indication that such variation misled any voters or that there has been fraud or deception, and there is sufficient substantial compliance to permit the board of elections to determine the petition to be valid. State ex rel. Osborn v. Fair?eld Cty. Bd. ofEZections, 65 Ohio St.3d 194, 602 636 (1992). 37. ?The sole purpose of the declaration of candidacy [or statement of candidacy] is to inform the signer that one is seeking to be a candidate for a certain public of?ce to begin at a certain time.? State ex rel. Sa?old v. Timmins, 22 Ohio St.2d 63, 64, 258 1 12 (1970). 38. The ballots for the general election to be held on November 3, 2020, have not been ?nalized. 39. In fact, the major political parties have until September 4, 2020, to certify to the Secretary of State the names of their joint candidates for President and Vice-President of the United States. See H.B. 166 735.11, 133rd General Assembly any provision of the Revised Code to the contrary, the major political parties shall certify to the Secretary of State the names of the candidates for president and vice-president nominated at their national conventions pursuant to section 3505.10 of the Revised Code not later than the sixtieth day before the 2020 general election?). 40. The form of the of?cial ballots for the general election to be held on November 3, 2020, do not have to be certi?ed by the Secretary of State until September 14, 2020. See H.B. 166 735.11, 133rd General Assembly by the Secretary of State of the forms of of?cial ballots required by division (A) of section 3505.01 of the Revised Code shall occur on or before the ?ftieth day before the general election?). FIRST CAUSE OF ACTION Writ of Mandamus 41. Relators incorporate by reference all of the foregoing paragraphs as if fully restated herein. 42. ?In extraordinary actions challenging the decisions of the Secretary of State and boards of elections, the standard is whether they engaged in fraud, corruption, or abuse of discretion, or acted in clear disregard of applicable legal provisions.? State ex rel. Husted v. Brunner, 123 Ohio St.3d 288, 915 1215, 2009-Ohio-5327 119 (quoting Whitman v. Hamilton Cty. Bd. of Elections, 97 Ohio St.3d 216, 778 32, 2002-Ohio-5923 Ill 1). 43. The action and decree of Amanda Grandjean whereby, on behalf of the Ohio Secretary of State, she rejected the Statements of Candidacy and Nominating Petition of KANYE WEST and MICHELLE TIDBALL constitute an abuse of discretion and/or an act in clear disregard of applicable legal provisions. 44. To date, FRANK LAROSE has not personally rejected the Statements of Candidacy and Nominating Petition of KANYE WEST and MICHELLE TIDBALL. 45. Nonetheless, the action and decree of Amanda Grandjean whereby she rejected the Statements of Candidacy and Nominating Petition of KANYE WEST and MICHELLE TIDBALL can be imputed as the action of FRANK LAROSE as Secretary of State. 46. In light of the action and decree of Amanda Grandjean as set forth in the Rejection Letter, FRANK LAROSE will not certify the names of KANYE WEST and MICHELLE TIDBALL for placement on the official ballot for the forthcoming general election to be held on November 3, 2020, as candidates for President and Vice-President of the United States. 47. The refusal of FRANK LAROSE to certify the names of KANYE WEST and MICHELLE TIDBALL on the of?cial ballot for the forthcoming general election to be held on November 3, 2020, as candidates for President and Vice-President of the United States constitutes an abuse of discretion and/or an act in clear disregard of applicable legal provisions. 10 48. The rejection of the Statements of Candidacy and Nominating Petition of KANYE WEST and MICHELLE TIDBALL constitutes an abuse of discretion and/or an act in clear disregard of applicable legal provisions. 49. The refusal to certify the names of KANYE WEST and MICHELLE TIDBALL for placement on the of?cial ballot for the forthcoming general election to be held on November 3, 2020, as candidates for President and Vice-President of the United States constitutes an abuse of discretion and/or an act in clear disregard of applicable legal provisions. 50. It was an abuse of discretion and/or in clear disregard of applicable legal provisions on the part of Amanda Grandjean (on behalf of FRANK LAROSE) and/or FRANK LAROSE to reject the Statements of Candidacy and Nominating Petition of KANYE WEST and MICHELLE TIDBALL by imposing a standard of strict compliance with respect to the requirements of RC. 3513.261, including, speci?cally, what is necessary when a statement of candidacy is copied onto other part-petitions. 51. It was an abuse of discretion and/or in clear disregard of applicable legal provisions on the part of Amanda Grandjean (on behalf of FRANK LAROSE) and/or FRANK LAROSE to reject the Statements of Candidacy and Nominating Petition of KANYE WEST and MICHELLE TIDBALL by not applying a standard of ?substantial compliance? with respect to the requirements of RC. 3513.261, including, specifically, what is necessary when a statement of candidacy is copied onto other part-petitions, especially in light of precedent of the Ohio Supreme Court. 52. It was an abuse of discretion and/or in clear disregard of applicable legal provisions on the part of Amanda Grandjean (on behalf of FRANK LAROSE) and/or FRANK LAROSE to reject the Statements of Candidacy and Nominating Petition of KANYE WEST and MICHELLE ll TIDBALL by requiring the statement of candidacy copied onto a part-petition to ?match? the original statement of candidacy and, in particular, to require the signatures precisely ?match?. 53. It was an abuse of discretion and/or in clear disregard of applicable legal provisions on the part. of Amanda Grandjean (on behalf of FRANK LAROSE) and/or FRANK LAROSE to reject the Statements of Candidacy and Nominating Petition of KANYE WEST and MICHELLE TIDBALL premised solely and exclusively upon the subjective opinion of Amanda Grandjean as to the resemblance vel non of an original signature on a statement of candidacy and the signature indicated on the statement of candidacy copied onto a part-petition. 54. It was an abuse of discretion and/or in clear disregard of applicable legal provisions on the part of Amanda Grandjean (on behalf of FRANK LAROSE) and/or FRANK LAROSE to reject the Statements of Candidacy and Nominating Petition of KANYE WEST and MICHELLE TIDBALL by applying a subjective standard as to the genuineness of any signature or the copy of any signature. 55. It was an abuse of discretion and/or in clear disregard of applicable legal provisions on the part of Amanda Grandjean (on behalf of FRANK LAROSE) and/or FRANK LAROSE to reject the Statements of Candidacy and Nominating Petition of KANYE WEST and MICHELLE TIDBALL premised solely and exclusively upon the subjective opinion of Amanda Grandjean without providing KANYE WEST and MICHELLE TIDBALL any notice of any concern or the opportunity to be heard with respect to the subjective (and dispositive) opinion of Amanda Grandjean. 56. It was an abuse of discretion and/or in clear disregard of applicable legal provisions on the part of Amanda Grandjean (on behalf of FRANK LAROSE) and/or FRANK LAROSE to reject the Statements of Candidacy and Nominating Petition of KANYE WEST and MICHELLE 12 TIDBALL when there was no evidence or indication that any defect in the statement of candidacy copied onto a part-petition (to the extent there was a defect) caused any signer of the Nominating Petition to be deceived or misled, constituted fraud or deception, and where there was suf?cient substantial compliance to permit the board of elections to determine the petition to be valid. 57. It was an abuse of discretion and/or in clear disregard of applicable legal provisions on the part of Amanda Grandjean (on behalf of FRANK LAROSE) and/or FRANK LAROSE to reject the Statements of Candidacy and Nominating Petition of KANYE WEST and MICHELLE TIDBALL as MICHELLE TIDBALL has acknowledged that, notwithstanding any perceived variation, the signatures that appears in both the Statements of Candidacy and in the statement of candidacy copied to other part-petitions are, in fact, her genuine signature. 58. Having complied with the statutory requirements under Ohio law, KANYE WEST and MICHELLE TIDBALL have a clear legal right to have their Statements of Candidacy and Nominating Petition as candidates for President and Vice-President of the United States accepted by the Ohio Secretary of State. 59. Having complied with the statutory requirements under Ohio law, KANYE WEST and MICHELLE TIDBALL have a clear legal right to have their names appear on the of?cial ballot for the forthcoming general election to be held on November 3, 2020, as candidates for President and Vice-President of the United States. 60. FRANK LAROSE has a clear legal duty to accept the Statements of Candidacy and Nominating Petition of KANYE WEST and MICHELLE TIDBALL as candidates for President and Vice-President of the United States. 13 61. FRANK LAROSE has a clear legal duty to certify for placement on the official ballot for the forthcoming general election to be held on November 3, 2020, the names of KANYE WEST and MICHELLE TIDBALL as candidates for President and Vice-President of the United States. 62. KANYE WEST and MICHELLE TIDBALL have lack an adequate remedy in the ordinary course of the law, especially in light of the approaching deadline for FRANK LAROSE to certify the form of the official ballots for the general election to be held on November 3, 2020, as well as the approach of the general election itself. WHEREF ORE, the STATE OF OHIO, by and on relation to Relators KANYE WEST and MICHELLE TIDBALL, prays for the issuance, in its name, of a peremptory writ of mandamus, or, in the alternative, an alternative writ of mandamus, compelling Respondent FRANK LAROSE, the Ohio Secretary of State: to accept the Statements of Candidacy and Nominating Petition of KANYE WEST and MICHELLE TIDBALL as candidates for President and Vice-President of the United States; and (ii) to certify for placement on the official ballot for the forthcoming general election to be held on November 3, 2020, the names of KANYE WEST and MICHELLE TIDBALL as candidates for President and Vice-President of the United States Respectfully submitted, urt C. Hartman Curt C. Hartman (0064242) The Law Firm of Curt C. Hartman 7394 Ridgepoint Drive, Suite 8 Cincinnati, OH 45230 (513) 752-8800 hartmanlaw?rm @fuse. net Attorney for Relators Kanye West and Michelle Tidball l4 VERIFICATION State of COunty 1:324 )ss Comes ichelle Tidball, having been duly cautioned and sworn, and declares that she has personal knowledge of the factual allegations above and such allegations are true and accurate. l/ Sworn to a subscribed before me a Notary Public 111 and for the State of ,on this thea? day of August 2020 SHAUN K. COUNTY or 15 Exhibit A Frank LaRose I wswet?fg'068m I August 21, 2020 Matthew R. Aumann Isaac Wiles Two Miranova Place, Ste. 700 Columbus, OH 43215?5098 Re: Certi?cation to the Ballot for Kanye West and Michelle Tidball Dear Mr. Aumann: I regret to inform you that Kanye West and Michelle Tidball will nOt appear on the November 3, 2020 General Election Ballot asjoint independent candidates for President and Vice President of the United States. Under Ohio law, a nominating petition must include at least one originally signed statement of candidacy, which may be copied on the other petition papers for circulation.1 The statement of candidacy that was designated as the original in their: ?ling does not match the petitions circulated. In fact, the signatures for Michelle Tidball bear no resemblance, calling into question which is genuine. Therefore, their nominating petition is rejected. You may contact me if you have any questions. Sincerely, Amanda M. Grandj ea Director of Elections and Deputy Assistant Secretary of State 1 RC. 3513.261; State ex. rel. Hawkins v. Cuyahoga Cty. Bd. of Elections, 28 Ohio St.2d 4, 6, 274 563 (1971); State ex rel. Rust v. Lucas Cty. Bd. of Elections, 101 Ohio St.3d 63, 2004-Ohio-9, 800 1162 (2004). 22 North Fourth Street Columbus. Ohio 43215 I 877.767.6446 IOhioSoS.gov printer; :?n-housc Exhibit Original Form No. air Prescripcd were IONYSacretary creme (12 19) Nomtr?tin'g Petition- abdt?tgtement of Candidacy For President and Vice Presidentio'f the United States To be ?led with the Secretary of State not laterthan 4 pm. of the 90?" day before the general election. RC. ascriggs?lgls; 3365.26?? 2: 0 statement of?candidacy for President candidate must fit! in, sign and date this of before are air l, Kanye West .the undersigned hereby declare under penalty of election falsi?cation that Name of Candidate for President my residence address rs 3202 Big Horn Ave . Cody . WY 82414 . Sm??r an to further declare that I desire to be a candidate for election to the of?ce of President of the United States at the generalelection to be held on the 3 day of November, 2020 . Day Year I further declare that i shall be at least thirty-?ve years old, and shall have resided for at least fourteen years within the United States by the 20'" day of January after such election. i am a natural-born citizen the nited States. Dated this 15 day of July . 2020 . ?ay Montn Year Signature of Candidate WHOEVER COMMITS ELECTION FALSIFICATION IS GUILTY OF A FELONY OF THE DEGREE Statement o'f'Candidacy?for Vice President NOTE - Each candidate must ?ll in, sign and date this of before are . . .l . . zs?q mesa any,orm "ym? 1 further declare that I desire to be a candidate for election to the of?ce of Vice President of the United States at the general election to be held on the day of November, .. D?ay further declare that i shall be at least thirty??ve years old. and shall have resided for at least fourteen years within the United States by the 20? day of January after such election. 1 am a a natural-born citizen of the United States. lit/mgr!) 8121?; WHOEVER COMMITS ELECTION FALSIFICATION IS GUILTY OF A FELONY OF THE DEGREE Dated this I day of Day Signatl' we hereby designate the persons named below as a. committee to represent us: Name Residence Nominating Petition We. the undersigned, quali?ed electors of the State of Ohio, whose voting residence is in the county, city, village. or township. set opposite our names, hereby nominate as a mndidate Name or Candidate oi Presrdent for election to the o?ice of President of the United States and as a Name of Candidate of Vice President candidate for election to the office of Vice President of the United States to be voted for at the next general election, and certify said persons are, in our opinion, well quali?ed to perform the duties of the of?ce or position to which they jointty desire to be elected. Circulated Version Form No. a-A'Prescribed by the Ohio Secretary oi State (12-19) Nominating Petition and Statement of Candidacy 3 7 For President and Vice President of the United States To be ?led with the Secretary of State not later than 4 pm. of the 90'? day before the general election. RC. 3501.432. 3513.257, .261. .263 Statement of Candidacy for President NOTE - Each candidate must fill In, sign and date statement of candidacy before petitions are circulated. l, Kanye West . the undersigned, hereby declare under penalty of election falsi?cation that Name 0! Can taste for President my residence address is 3202 Big?om Ave. . Cody . WY 82414. Street Number and Address, if any. (ar Mm! route and number) City or Village further declare that desire to be a candidate for election to the of?ce of President of the United States at the general election to be held on the 3 day of November. 2020 Day Year?? further declare that i shall be at least thirty-?ve years old. and shall have resided for at least fourteen years within the United States by the 20?? day of January after such election. i am a natural-born citizen of the United States. Dated dayof July _2020 ?Day Month Yoar Signature of Candidate WHOEVER COMMITS ELECTION FALSIFICATION iS GUILTY OF A FELONY OF THE FIFTH DEGREE Statement of Candidacy for Vice President NOTE - Each candidate must ?ll in, sign and date this statement of candidacy before petitions are circulated. . Michelle Tidball Name of Candidate torvica Prosidenl my residence address is 907 Glade Court the undersigned. hereby declare under penalty of election falsi?cation that Cod WL 32414 City orV llage Zip Code I further declare that I desire to be a candidate for election to the of?ce of Vice President of the United States at the ress. i any, (or rural rouluunrl number) general election to be held on the 3 day of November. 9929 . 53y Year further declare that i shall be at least thirty-?ve years old, and shall have resided for at least fourteen years within the United States by the 20'" day of January after such election. I am a a natural-born citizen of the United States. Signature of Candidate Dated this 31 day of IE . 2020 Day Month Year WHOEVER COMMITS FALSIFICATION IS GUILTY OF A FELONY OF THE FIFTH DEGREE We hereby designate the persons named below as a committee to represent us: Name Residence Joe Fry 2250 Community College Ave, Apt 637, Cleveland OH 44l 15 Michael Walsh 13525 Newton Road. Middleburg Heights OH 44130 Wendy Jean Emch 2355 Durbin Drive, Fremont Ohio 43420 Jordan Emahiscr l02 Ballict Street, Nevada OH 43830 Mykah Brown 1419 Galway Bend N., Pataskala OH 431 10 Nominating Petition We. the undersigned. quali?ed electors of the State of Ohio. whose voting residence is in the county. city. village. or township, set opposite our names. hereby nominate Kanye West Name of Candidate of President for election to the of?ce of President of the United States and Michelle Tidball as a Name of Candidate of Vice President candidate for election to the office of Vice President of the United States to be voted for at the next general election. as a candidate and certify said persons are. in our opinion. well quali?ed to perform the duties of the of?ce or position to which they jointly desire to be elected.