SUPRflv1E COURT: STATE OF YORK

COC:'\TY Or QlJEF'.'JS

ROBHRT TCRXER ET AL
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THE BOARD OF ELU 'TJ01\'S !.V
THE CITY OF NEl-V >"ORK. r.:I. al.
. /fr.,po11de nl .

ST A TE Of NEW YORK )
COlJNTYOF QUEENS ) ss.:
,...._
A TTOR/\'El'S AFF/RMA T/OlV
£,fl,1ERGENCY APPLIC4 TION
ELECTION LAW MA TTt.'R
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V. nn attorney at la\\ duly admitted to practice before the Cou11s of till'
-· York affirms under penalty of per:jury as l'ollows:
[J ..._,,.. ·- .'
,...... That the above application is on behall'ofthe petitioners herein
- I
· · .._The underlying action is pursuant to the New York State Election Law and the last <JaY to
fu .
· c . service is October 7th 2013.
Ii.; _,_
;::;:,; As a result of the short time frame he fore the expiration of the Statute of limitations on this m;lth.' r
and the necessity to serve all Respondents. it is respectfully rcyuestcd that this application he treated lrn a
crnergency basis so service can be completely in a timely fashion. Also. as a result of the sho11 time frnrnL·
!"or ser\'ice the petitioners have a mode service \Vhich has been in common use for election b\\
matters and particularly when there arc numerous respondents, and respectfully request that the Court grnnt
the same.

•· , . ..... .. _ .
------------ --··
!n the \'latter of the Application ot'
A TERl'v1 OF
T l--&ts""l"Jt> R E;-v1 E c 0 URT () r
THE STATE OF NEW \'ORK.
COUNTY OF
LOCATED AT 88-11
SUTPI 1!N BOULEv' ARD
.JAMAICA NY, ON THE 4TH
DAY OF OC'TOBFR, 20 l '3
.l.S.C.
x
---
ROBERT. TURNER, JOAN VOGT, 1\NTHONY \IUNZ!ATO, BART
HAGGERTY, JOSEPH Kl\SPER, JANICE BAR, MARGARET OGNIBE\E.
JOANN ARIOLA, EDWARD O'HARF, 1\1!\NLJEL CARUANA. JOSEPH
MAGNUS and AMY HOLDEN
Petitio:1ers,
-against-
....
THE QLEENS COUNTY REPUBLICA?\: COMMITTEE
and
PHILIP RAGUSA, CHAIR,
INDIVIDUALLY AND AS ALLEGED CHAIR
NO MO'lt'1c0N
FU.Ji»4liN

ORDER TO
SHOW
CAUSE
i
OF EACH OF THE QUEENS COUNTY REPUBLICAN
COMMITTEE AND EXECUTIVE COMMITTEE OF
THE QUEENS COUNTY REPUBLICAN CO'.\ll'.\llITTEE
INDEX
'1 : c-:: .--·· · 11 I · ·
1
10 ":) 1-. ) I f ·-)
'I -·
and
STEPHANlE ZGALJ!C
lNDlVlDUALL Y AND AS ALLEGED SECRETARY AND MEMBER OF THE
QlJEENS COUNTY REPUBLICAN COMMITTEE AND THE EXECUTlVE
COMMITTEE OF THE QUEENS COUNTY REPUBLIC AN COMMITTEE,
and
ROBERT V. BEL TRANI, JAMES MCCLELLA!'-;D, ANTHONY CAROLLO,
NAT AUE DUBOVICI, DEBORAH A. HEINICHEN, MARIE LYNCH, PHILIP
T. SICA, JUDITH STUPP, ROBERT HORNAK, SAMIHA MAKA WI ,
STEPHEN MORENA, ROSEMARIE A. IACOVONE, JASMINE O\VENS.
lV1ELISSA CASTANEDA, RUBY K. MUHAMMED, ANITA BAUMANN.
PETER SUTICH, JOSEPH DUBOWSKI, TIMOTHY FUREY, MICHAEL
HARRIS, PHILIP T. SICA, CECILIA WALSH, PIERRE ALCANTARA,
I I
PATRICK R. GALLAGHER, SER PHI"\! R. MALTESE, ROJ.AINE ANTIO:<E.
30YCE ARONOVICI,

I3ENOIT. ROBERT BISHOP. DANIEL
CREIC3HTON, KATHY DABOUR._ EL\I1\E C. WILLIAM LEWIS.
ANDRE PECOT and JLAN REYES, INDIV!Dl iAU .Y AJ\D AS OFFICERS
A:\D \'!EMBERS OF THE QUEENS COl REPUBLICAN COl'vil\1lTTEE
and
THE BOARD OF ELECTiONS l\: THE Ci TY Of [\t:\V \ ' ORK,

-:"'HE NEW YORK STATE BOARD OF ELECTIONS.
Respondents
For an Order to Articles 2 and 16 of
:he Election Law and the General Association Law
To invalidate the purpo1ted organi zational meeting of the Queens County
Republican County Committee held on September 27
111
, 2013 at the Reception
House Queens County NeVv York and to invalidate the Certificate of elected
officers at said meeting and filed with the Board of Elections in the City of New
York and the New York State Board o!' Elections
---------------------·-----------------------x
Upon the annexed petition of ROBERT JOA\l VOGT,
ANTHONY NUNZfATO, BART HAGGERTY, JOSEPH KASPER. JANICE
BAR, \1ARGARET OGNIBENE, JOA?'\!\; ARIOLA, EDWARD O'HARE,
\1ANUEL CARUANA, JOSEPH MACi'-JUS and AMY HOLDEN verified on the
Day of October, 2013, and upon al I of the papers and proceedings heretofore
had herein, it is hereby:
of this court should not be nrnde and entered pursuant to i\niclcs fwo and
Sixtei:n cf Election Law and Sccti(ln ! .J of the C:iencrnl Associatilm Lm\:
: . Invalidating the Organizational Meeti11g and Eledion and
: m·al id2ting the Certificate or Election officers and minll!L'S attached thereto
purportedly filed Vlith respondent Board or Flcctions in the City of New York and
\:ew York State Elections of the September 27, 20 I 3 Respondent Queens County
Repubiican Committee meeting and requiring the Respondent Ragusa to con,·ene a
new meeting to properly organize the Committee, and
2. Ai lowing oniy those Committeemen and Comrnittec\\'omen elected at the
September l 0
1
h, 20 ! 3 Prirnmy Elcctit'll to \'ote for the Officers of said Respondent
Cornmittee, and;
3. Allov,ing for Proxy voting as permitted in the Rules of the Respondent
Committee currentiy on file \.villi the l\ew York State Board of Elections and the
York City Board of Elections \'vith instructions. without deadline, up to and
including the time of the meeting and \\'ithout interference from the respondent
Ragusa and any of his appointees or agents and;
.+. Ai lowing for all duly elected members of' the County Committee to carry
proxies of any other duly elected County Committee member. and;
.'." . Appointing a Special Master or Court Monitor and Court Stenographer to
O\ ersee and record the proceeding of the OrgnninHional \/Jeering of the
Respondent County Committee :Yleeting, including, but not limited to, the
credentiaiing of the Committee Members and the voting for the Officers of the
Respondent County Committee at the Orgunizntional Meeting, and After the
meeltng, take possession of all of the proxies documents and records of said
meeting, and:
6. Allowing all duly elected members Lo attend the meeting, in person or by
proxy including requiring that the \ 'kcting be held in a hall, room
or facilitv larg· e enow2h to accommodate the entire duly elected Committee\\ ith
,,
sufficient parking for the '.V1ernbt:rs nf said Committee. and;
. '-
7. To require the purportedly elected Respondent Rap.usa Committee to give
the for the Petitioners' a complete list, including the names and addresses.
of z:ll of the officers. executive comrnittcc members, sub-committee members, and
other persons, elected or appointed at the meeLing or serving in any capacity for
the Respondent Queens County Repuhlicrrn Committee, and:
8. Requiring the Respondent Ragusa, in his c1pacity as the functus-officio chuir
to prior to caliing the Orgunizational Meeting to order to provide to the Petitioners'
attorney a list of all scaff people to be present at the meeting, whether inside or
outside the building, their exact function and purpose, including and not limited to
credentialing, tallying of votes and security, their compensation, it' any. and the
person or entity paying same, and;
9. Requiring the Respondent Rsgusa, in his capacity as the funcLus- officio
chair prior to ca!iing the Organizational Mcding to order to provide to Petitioners'
a representative or representatives on the credentials committee thereof, and a
representative or representatives the vote tellers at the rneeting(s) \Vho shall
h2ve the right to attend all proceedings ol' said committees and \Vho shall be
provided with all documents considered hy said committees as well as access to the
counting of votes ,,_·hether by roll or proxy, and;
l 0. Permitting the Petitioner:-:; tn have present\\ itb them at all meetings of any
committee or sub-committee and the count of the votes at the meeting their
attorney or the aitcrnative, to allow the petitilmers and each of them, to haYe
'..infottered access to counsel,
1 1
l l . Such other, further, tmJ different relief as this coun may find to be
. iust and proper and equitable
. V·· ,/ Suffident cause appearing therefore, leave is hereby granted to the
\, •C'
_\D \' ·t f · v·_petitioner to 2mend his as may be necessary, and

l , Sufficient appearing therefore, is hereby granted to the
.,>..}.._·- pe1itioners to submit on the dmc set for the hearing oCthis matter additional
. , .-.--)', \' .. . \": irnesses, exhibits, proofs and other C\'idcnce as may be necessary. realign the
' '-'1 panies hereto, and to aml:.'.nd the herein as may be required by further
)
!nvestiQation of the facts cmd/or the un<1v<1ilabilitv of facts at the time of this order
J
\and,
gR-n-a pp .. fi.cH--en-.t·IW- -
dL'liver to the court all notices. pro:-.:ies.
:ninutes, ro!i call. attendance. records of the
""'l"A""!- "'el .. I ')f'\ I "'1 ,, ...,?-:------_
p .... i po "c v ,s.LI 1L. tTCT\:11-rtti'Ti.1\..C ..-c-T;-1
0
. , "- . .... • ,-
1
... 1Th:. 1-_
Sufficient cause appearing therefore, it is l'urther
ORDERED, that the Court shall retain jurisdiction of the Organizationnl
\'ieeting of the Respondent Queens County Republican Committee County
pending A FURTHER ORDER OF THIS COURT, and
Sufficient cause appearing therefore, it is further
ORDERED, that Pcritioners shed] c:.1usc a cop;.- of' this order together with
311cillary papers thereto, upon which this order \\·as granted upon
Respondents l\ew York City Board of Flections and 0,'ew York State Board of
Elections at their Qeneral oniccs at 32 Brm1dwm \;e\V "\!or!-:, \JY nnd 40
J
?erirl Street Albany NY rcspi.::cti\cly. and Queens County Republican
Conm1ittee, by !Jersonally deli\ ·cring same to the offices thereof, or by personally
delivering san:e to any uf'the Respondent Officers, or any person authorized to
Sci"\, ice of papers for such respondent. on or be fore October 7, 2013 and
uoon Res1.:iondcnt Officers of the Ol;ccns Countv Renublic3n Committee. bv
. ' "' . .,
oersone1lly delivering same to thc·m 01· a per·son nf suitable age and discretion at
·[l:eir cf!iccs or cornmiucc 111ai11taincd by them on or before Ocwber
7. 20 l3 or alternativeiv, cit the 0
1
1
)tion ol'thc Petitioners. scn·ice mav he made b\
"' - "
2nciosing same in a securely sealed and post paid wrapper dddrcssed tc, the
Respondents ar the addrcsscs_j_istcd on the Certificate att(lchcd as Exhihit A via
t::: )l ;'.) 'P' _,_';;
L11\ted Stmes Postal Service \fail and depositing same with an office or
- C'-
deposiwry of the United Srntes Postell Service. 011 or before OctobcrJf. 2013 01··by·
mi :B it)tHt:T-tt-Ifyttl . l h c u l
I
d and drnt such service shai l be deemed good and sufficient sen ice /,,.--
DA TED: October 4, 2013
So ordered:
jl 'STICE 01" THE Sl fPREME COURT

SUPREME COURT OF THE STATE or NEW YORK
COUNTY OF QUEENS
-------------------------------------------------------------:"(
In the Matter of the Application of
ROBERT TURNER, JOAN VOGT, ANTHONY NUNZIATO, BART
I IAGGERTY, JOSEPH KASPER, JANICE BAR, MARGARET OGNJBENE,
JOANN ARIOLA, EDWARD O'HARE, MANUEL CARUANA, JOSEPH
MAGNUS and AMY HOLDEN
Petitioners,
-against-
THE QUEENS COUNTY REPUBLICAN COMMITTEE
and
PHILIP RAGUSA, CHAIR,
INDIVIDUALLY AND AS ALLEGED CHAIR
OF EACH OF THE QUEENS COUNTY REPUBLICAN
COMMITTEE AND EXECUTIVE COMMITTEE OF
THE QUEENS COUNTY REPUBLICAN COMMITTEE
and
STEPHANIE ZGALJIC
VERIFIED
PETITION
I ~ J, >&" rt
;f JY/ (!3
INDIV.!DUALL Y AND AS ALLEGED SECRETARY AND MEMBER OF THE
QUEENS COUNTY REPUBLICAN COMMITTEE AND THE EXECUTIVE
COMMITTEE OF THE QUEENS COUNTY REPUBLICAN COMMITTEE,
and
ROBERT V. BEL TRANI, JAMES MCCLELLAND, ANTHONY CAROLLO,
NATALIE DUBOVJCI, DEBORAH A. HEINICHEN, MARJE LYNCH, PHILIP
T. SICA, JUDITH STUPP, ROBERT HORNAK, SAMIHA MAKA WI,
STEPHEN MORENA, ROSEMARIE A. IACOVONE, JASMINE OWENS,
MELISSA CASTANEDA, RUBY K. MUHAMMED, ANITA BAUMANN,
PETER SUTICH, .JOSEPH DUBOWSKI, TIMOTHY FUREY, MICHAEL
HARRIS, PHILIP T. SICA, CECILIA WALSH, PIERRE ALCANTARA,
PATRICK R. GALLAGHER, SERPHIN R. MALTESE, ROLAJNE ANTIONE,
JOYCE ARONOVICI, SAMUEL BENOIT, ROBERT BISHOP, DANIEL
CREIGHTON, KATHY DABOUR, ELAINE C. JACKSON, WlLLIAM LEWIS,
ANDRE PECOT and JUAN REYES, INDIVIDlJALLY AND AS OFFICERS
AND MEMBERS OF THE QUEcNS COUNTY REPUBLICAN COMMITTEE
and
THE BOARD OF ELECTIONS IN TI-IE CITY OF NEW YORK,
and
THE NEW YORK STATE BOARD OF ELECTIONS,
For an Order pursuant to Articles 2 and 16 or
the Election Law and the Genernl Association Law
To invalidate the purpo11ed organizational meeting of the
Queens County Republican County Committee
held on September 27, 2.013 at the Reception I louse
Queens County New York and to invalidate the
Certificate of elected officers at said meeting ~ m d
tiled with the Board of Elections in the City of
\!ew York and the New York State Board of Elections
- - - - - - - - - ~ ~ - - - - - ~ ~ ~ - - - - ~ - - - - ~ - - - - - ~ ~ ~ - - - - - - - - - - - - - - - - - - - - - - ) (
TO THE SUPREME COURT or THE STATE OF NEW YORK:
The petition of ROBERT TURNER, JOAN VOGT, ANTHONY
NUNZIATO, BART HAGGERTY, .JOSFPI I KASPER, JANICE BAR,
MARGARET OGNIBENE, JOANNE ARIOLA, EDWARD O'HARE, MANUEL
CARUANA, JOSEPH MAGNUS and AMY HOLDEN by their attorney Thomas
V. Ognibene, respectfully shows this Court and alleges on information and belief
as follows:
1. Petitioners are all duly enrolled members of the Republican Pa11y and
registered voters in the County of Queens.
2. Petitioner Robert Turner, resides at 175 Ocean Avenue Queens NY l 1697
and is a former member of the United States I louse of Representatives from
Queens County State of New York. This petitioner is also a candidate who was
nominated to the office of Chair of the Republican County Committee at the
pu1vo1ied organizational meeting held on September 27, 2013. Petitioner Turner
believes he had the legitimate votes to prevail at the organizational meeting and his
rights have been detrimentally affected by the conduct of outgoing Chair
Respondent Ragusa and his mm1ons. He believes the election was ·'stolen'' and
requests the court intervene and prevent the egregious and illegal conduct of the
Respondent Ragusa and his minions as set forth below.
3. Petitioner Joan Vogt resides at 13-17 123 Street Queens NY 1 J 356 and is
a member of the Queens County Republican Committee from the 2t
11
Assembly
District having been re-elected to a two year term on September I 0, 2013. She is
also the female member of the Rcpuhlicnn Stntc Committee from that Assembly
District and is a member of the Executive Committee of the Queens County
Republican Committee.
4. Petitioner Anthony Nunziato resides at 56-04 Remsen Place Queens NY
11378 and is a member of the Queens County Republican Committee from the 30
1
1i
Assembly District having been re-elected to a t\VO year term on September 10.
20 l 3. He is also the male member of the Republican State Committee from that
Assembly District and is a member of the Executive Committee of the Queens
County Republican Committee.
5. Petitioner Bart Haggerty resides at 73-37 Austin Street #PHB Queens :\Y
I I 3 75 and is a member of the Queens County Republican Comrnittee from the 28
111
Assembly District having been re-elected to a two year term on September I 0,
2013. He is also the male member of the Republican State Committee from thC:lt
Assembly District and is a member of the Executive Committee of the Queens
County Republican Committee.
6. Petitioner Joseph Kasper resides at 133-18 1 16 Street Queens NY 1 l 420
and is a member of the Queens County Republican Committee from the 31st
Assembly District having been re-elected lo a two year term on September 10,
2013. He is also the male member of the Republican State Committee from that
Assembly District and is a member of the Executive Committee of the Queens
County Republican Committee.
7. Petitioner Janice Bar resides at 133-59 118 Street Queens NY l l 420 and
is a member of the Queens County Republican Committee from the 3 I st Assembly
District having been re-elected to a two year term on September l 0, 2013.She is
also the female member of the Republican State Committee from that Assembly
District and is a member of the Executive Committee of the Queens County
Republican Committee.
8. Petitioner Margaret Ognibene resides at 64-82 83 Street Queens NY
11379 and is n member of the Queens County Republican Committee from the 30
111
Assembly District having been re-elected to a tvvo year term on September 10.
2013. She is also the female member of the Republican State Committee from that
Assembly District and is a member of the Executive Committee of the Queens
County Republican Committee.
9. Petitioner Joann Ariola resides at 89-35 I 55 Avenue #6L Queens NY
11414 and is a member of the Queens County Republican Committee from the
23rd Assembly District having been re-elected to a two year term on September
l 0, 2013. She is also the female member of the Repuhl ican State Committee from
that Assembly District and is a member of the Executive Committee of the Queens
County Republican Committee.
10. Petitioner Edward O'Hare resides at 806 Shad Creek Road Queens NY
11693 and is a member of the Queens County Republican Committee from the
23rd Assembly District having been re-elected to a two year term on September
JO, 2013. He is also the male member of the Republican State Committee from that
Assembly District and is a member of the Executive Committee of the Queens
County Republican Committee.
11. Petitioner Manuel Caruana resides at 70-1 7 5 7 Drive Queens NY J J3 78
and is a member of the Queens County Republican Committee from the 30th
Assembly District having been re-elected to a two year term on September I 0,
2013. He is also the Chairman of the 30th Assembly District Committee and is a
member of the Executive Committee of the Queens County Republican
Committee.
12. Petitioner Joseph Magnus resides at 58-05 75 Street Queens NY 113 79
and is a member of the Queens County Republican Committee from the 30th
Assembly District having been re-elected to a two year term on September 10.
2013 .
13. Petitioner Amy !lo Iden resides at 74-19 Caldwell Avenue Queens NY
113 78 and is a member of the Queens County Republican Committee from the
30th Assembly District having heen re-elected to a two year term on September l O.
2013.
14. Respondent Boards of Elections are r·esponsiblc for the oversight and
conduct of all Election related procedures in the City and State of New York and
the Agencies with the responsibility of accepting and filing the above Certificate of
Election of Officers.
15. Respondent Board of Elections in the City or New York maintains its
files at the Executive Offices in the Borough of Manhattan. County of New York
16. All filings with the Respondent Board of Elections in the City of New
York are required to be made in the Borough of Manhallan. County of New York.
17. Respondent Board of Elections in the State of New York maintains its
tiles at its Offices in the County of Albany.
18. All filings with the Respondent Board of Elections in the State of New
York are required to be made in the County of Albany.
19. Respondent Queens County Republican Committee 1s a Constituted
Committee under the Election Law and is organized pursuant to A11icle 2 of the
Election Law of New York State. The Members of the Respondent Committee
were last elected at the Primary Election held on September 10th. 2013.
20. According to documents purported tiled tile with the New York State
and New York City Board of Elections, Respondent Philip Ragusa,. who resides at
14-15 157 Street Beechhurst NY 11357. is the purported Chair of the Respondent
Queens County Republican Committee.
21. According to documents on tile \\ith the New York State and Nev,, York
City Board of Elections, Stephanie Zgaljic, who resides at 30-47 29th Street
Astoria NY 11 l 02 is the purported Secretary of the Respondent Queens Count)
Republican Committee.
22. The respondents listed in Exhibit '';\" hereto which is the Certificate of
Election of Officers filed by respondents Ragusa and /.galjic, were allegedly
elected to the party positions indicated therein at the organizational meeting of the
County Committee held on September 27th, 201 J. Upon information and belier·
said list of ot1icers has been filed with the Board of Elections in the City of ;-..Je,,
York and the New York State Board of Elections.
23. This petition is made in order to preserve Petitioners' rights under the
Election Law of the State of New York and the General Association Law of the
State of New York to challenge erroneous results and conflicts and correct any
errors in the organizational meeting, and to provide for cou11 supervision of the
organizational meeting of the Respondent Queens County Republican Committee,
to allow for the comprehensive review of the matters under the jurisdiction of this
Cou1i.
24. That prior to the organizational meeting, Respondent Ragusa caused a
meeting notice to be sent to committee members for the organizational meeting of
the County Committee to be held on September 27th, 2013. Said meeting notice
was dated September 27, 2013, the same date as the meeting was called for, and
was NOT accompanied by any proposed by-laws or rules and was not mailed or
delivered to the county committee members in the time frame provided for in the
rules and by-law of Queens County Republican Committee .. (See Exhibit "B").
25. The meeting notice was insufficient us a matter of law to give adequate
notice of the actions that were to be taken al the meeting, and did not state the
order of business for the Organizational Meeting, as prescribed in the by-laws and
mies.
26. Upon information and belief respondents gave different and unequal
notice to different county committee members including giving more and favorable
notice to committee members supporting respondent Ragusa.
27. Upon information and belief, respondents also gave legally insutlicicnt
notice of the meeting, especially to those districts in which the respondents had lost
primary elections and that would not vote for their chosen slate of candidates. In
some instances there was only 48 hours or less notice of the purported meeting.
28. Upon information and beliet: at the ubove Organizational Meeting
Respondents allowed proxies to he voted which had been obtained \Vithout the
consent or knowledge of the county committee person.
29. Upon information and belict: at the Organiz:.nional Meeting held on
September 27th 2013, Respondents alJm,ved proxies to be voted which had been
obtained from voters who were not duly qua Ii lied or elected to be members of the
Republican County Committee.
30. Upon information and be! iel', at the Organizational Meeting held on
September 27th 2013, Respondents allowed proxies to be voted by County
Committee in their favor from members which contained either no signature or a
forged signature w l ~ i l e invalidating otherwise valid proxies on similar grounds.
3 l. Upon information and beliel: at the Organizational Meeting held on
September 27th 2013, Respondents never took a roll call for the election of
officers.
32. Upon information and bclict: at the Organizational Meeting held on
September 27th 2013, Respondents allowed for Assembly District votes to be
improperly stated by leaders and cast by persons not authorized to cast said votes
in contravention of the existing by-laws.
33. Upon information and belief, at the Organizational Meeting held on
September 27th 2013, Respondent's prohibited a proper record of the meeting to
be maintained and improperly denied motions to so record the meeting. This \Vas
done deliberately by the Respondent's to frustrate this Court's review of the
proceedings.
34. Upon information and belief Respondents unknown 1m111ons on the
purported Credentials Committee made challenges to and invalidated proxies
arbitrarily and capriciously and without any method or handwriting expertise or
comparing signatures to any Board of Elections record.
35. Upon information and helicf Respondents improperly calculated the
voting method and voting weight used at the organizational meeting in
contravention of New York State Law and the By-laws of the Republican County
Committee.
36. Upon information and be! ic r Respondents deliberately improperly
tabulated and counted the votes cast at the organizational meeting.
37. Upon information and respondents failed to provide or make
available copies of the bylaws and rules nt the reorganization meeting.
38. Upon information and belief, respondents failed to obtain a ce11ified
copy of the duly elec!ed members of the Queens County Republican Committee
from the New York City Board of Elections prior to the meeting.
39. Upon information and belie( the Queens County Republican Executive
Committee never organized and the certificate tiled by respondents Ragusa and
Zgaljic stating that such meeting took plrice is a false statement and a fraud.
40. Upon information and respondents intentionally and purposely
called the organizational meeting for a Friday at I 2:30pm, a work day, and also 8
Jewish Holiday, in order to purposely inconvenience members from attending and
to discourage attendance and participation.
41. Upon information and respondents allowed votes to be cast by
proxy, where no such proxies had been submitted by the members.
42. Petitioner Turner believes that if the proxies improperly disqualified by
the Respondents' were counted, he would prevail and be the duly elected Chair of
the Queens County Republican Committee. Petitioners' believe that only though
the intervention of this Court can they receive a fair organizational meeting. At a
fair meeting, it is their belief that Lhey v,:oulcl prevail.
43. To aid the Court, at the nc\V Organizational Meeting, an appointment of
a special master or referee and a stenographer wi 11 assist the Court in a speedy
determination of all issues that may be raised. It will also insure fairness and a
complete record of the proceedings.
44. Petitioners request leave to, and reserve the right to submit further proofs
by way of \Vitnesses, affidavits, and evidence upon the date set by this court for the
trial and hearing of this matter, to re<1lign the parties as may be necessary, and to
amend these pleadings to reflect the facts adduced by \vay of further investigation
and the conduct of the organi7.ation<1l meeting of the Respondent County
Committee.
45. Section 13 of General Associ<1tion Law as well as Articles 2 and 16 of the
Election Law give this Court jurisdiction m·er the organizational meeting or the
Respondent Queens County Republican Committee.
46. The Petitioners request Lhe Courl to keep jurisdiction of the
organizational meeting of the Respondent Queens County Republican Committee
to assure proper adjudication of all issues before one Court.
47. Alternative means of service are requested herein as the Respondents
may be difficult to gain access to, avoid service and in Election Lav ... m8tters
substituted service is routinely granted. Additionally, Respondent County
Committee maintains an office at 24-55 Francis Le\vis Boulevard, Queens, NY
11357.
48. No other application for the relier herein applied for has been made to
any other court in any jurisdiction.
49. Petitioner has no other relief in law or equity except as herein applied
for.
WHEREFORE, Petitioner respectrully demands that this court issue an order
invalidating the purported organizational meeting of the Queens County
Republican Committee and ftmher directing respondent Hoard of Elections in the
City of New York and the New York State Bourd of Elections to invalidate the
Certificate of Officers \Vith minutes attached thereto filed by such Respondents.
and that this court order a new organizational meeting of the Respondent Queens
County Republican Committee and that the Court take jurisdiction over the
conduct of the organizational meeting of the Respondent Queens County
Republican Committee, and grant the relief requested in the annexed Order to
Show Cause, together with such other, further, and different relief thnt this Court
may deem to be just and proper.
DATED:
Yours, etc
October 4th, 20 l 3
Melville, New York
Thomas V. Ognibene
Attorney for Petitioner
155 Pinelawn Road Suite 220
Melville, New York 11747
516-686-0000 PHONE
516-693-9185 FAX
Thomas V. Ogni ene Esq.
Attorney for the Petitioners
(
CERTIFIED
CERTIFICATE OF NAMES AND POST OFFICE ADDRESSES OF
OFFICERS ELECTED AT TT-TE PARTY ORGANIZATION ....;gg
OF THE REPUBLICAN PARTY OF QUEENS COUNTY
,..,.,
The New York State Board of Elections and To:
The Board of Elections in the City of New York c:>

-0
We, the undersigned Philip Ragusa as the Chairman and Stephanie Zgaljic as the Secretary of the
County Republican Party County Committee and tho;: Queens County Republi can Part
1
TITLE
Committee, r:
DO HEREBY CERTIFY THAT:
Pursuant to the New York State Election Law including but not limited to §2-112 and §2-114, and the By-
Laws and Rules of Party Organization for the Republican Party of Queens County, the following are the
names and post office addresses of the officers elected at the organization meetings of the Republican
Party County Cornmillce and the Republican Party Executive Committee of and for the County of Queens
al the duly convened meetings held al the Recept ion House located at 167-17 Northern Boulevard.
Flushing, Queens County, New York ity, New York on September 27•h. 2013.
And WE DO HEREBY CERTIFY THAT the following arc the current Names and Post Office
Addresses of the aforesaid Officers of the Republican Party County Committee and the Republican Party
Executive Committee of and for the County of Queens.
fi,\ E
·--------
ADDRESS.
1
CHAIR1'11AN PHl!,!P RAGUSA 14-15 157th Street, Bcechhurst, I 1357
t---- ---------- -;----------- - --+--·---
1 EXECUTIVE VICE CHAIRMAN ROBERT V. Rf-:l.TRANJ 35-31 85 Street Jackson Heights. '\:.Y 11372
I rIRST VICE CHAJRMAN JA.\1ES MCCLELLAND • 62-39 65' h" Street, Middle Village, 11379
- - ----- ----!-·--- - ---- --'-'----- --- .
L vrcE CHAIRPERSONS CALPHABET1cAL) - -+----------- --------
; I. ANTHONY CAROLl.O 157-03 10 Ave. Whitestone NY 11357
1

; 2. NATALIE DUBOVlCl 31-20 54•h Street. Woodside, NY 11377
<------- - --- - --+---- - ----
•• - _J _____________ -t-D_E_B_O_R_A_H_ A_H_E_.r.-; _'_ IC_H_E_N_' - ---t-1_24-09 25 Ave College Pt. NY 11356
4. MARIE LYNCH 30-06 29•h Street, Astoria :-;y 11102
f 5. PHILIP T. SICA 1 232-1 t Seward Avenue, Queens. NY 11427
r 6. JUDITH STI !PP 37-24 222"d Street, Bayside. ?\Y 11361
7. VACANT
I
---1
J
EXECUTIVE DIR.ECTOR ROBERT HORNAK • 21-16 33rd Street, Astoria NY 11105
DfRECTOR SAtvf!HA MAKA Wl ______ -+
1
1
_3_9-_2_0_G..,,,re ,.,. e_np_o_in_1_A_v_e,_S_u_nn_)_·si_d_c._N_'Y_ l 1_1 _04 _ __ 1
SECRETARY STEPHANIE ZGALJIC 30-4729rn Street. Astoria, NY I 1102

ASSISTANT SECRETARY STEPHEN ; 26-11 24
1
h Avenue, Astoria, NY 11102
CORRESPONDING SECRETARY ROSEMARIE A. !/\COVONE 69-23 Eliot Avenue, Middle Vil lage, NY 11379
.__ ,\-SS-.- T-. C_O_R_RE_S_P_O_N_O_rN_: '_G_S_E_C_R_E_T_AR _ Y_,_' -J-A-SM-IN-1 E-. I 07-16 1 07 Ave, Ozone Park, NY l 1417 --i
RECORDING SECRETARY MELISSA CASTANEDA 48-24 Lane, NY 113 77
ASSIS !'ANT RECORD! NG SECRETARY RUBY K. MUHAMMED 98-38 57 Avenue, Corona, NY I 1368
1---------------;----
T RE AS URE R ANITA BAUMANN I 34-24 Brookside Street, Little Neck, :<.Y I
.. . 169-24 24'h Road, \Vhitestone, NY 11357 ---i ! ASSIST Ai'IT TREASURER PETER SUT!CH
- - ------ ----- - !
I COUNSEL JOSEPH DUBOWSKI, ESQ. ; 86·19 Edgerton Boulevard. Jamaica, NY 11432 !
I DEPUTY COUNSEL VACANT f
L SGT. AT. ARMS TIMOTHY FUREY 217-25 50 Avenue, Bll)'S ide. ;-,ry 11354 J
_
1
A_SS_l_S_TA _ N_ T_S_G_T_. A_1_'_ARi _ M_s _____ L l\ _1_IC_H_A_E_L_ H_A_R_R_Is_· ____ - _-_-_-_- _- _- 3=6=8===========-..;!
Page 11
r
' .h
September 28, 2013
I
, -+
- ------- - -
CHAPLAIN PHILIP T. SICA I 232- I l Seward Avenue, Queens, l\Y I I 427
:
I
AMERICANISM CHAIRMAN CECILIA WALSH j 39-20 Grecnpoint Ave, Sunnyside: , NY I I 10.i
.
I
PROTOCOL OFFICER PIERRE ALCANTARA 4 7-50 59<1• Street, Woodside. NY 11377
I
DEPUTY PROTOCOL OFFICER PATRICK R. GALLAGIIER 80-27 64"' Road, Queens, 113 79
I
CHA1RMAN EMERJTUS SERPHIN R. MAJ,l'F.SE 60-16 74TH Street, Village. NY I I 379
- 1
--
\1EMBERS AT LARGE (ALPHABETICAL)
J
l ROLATNE ANTIONE 210-04 94 Ave. Queens Village I 1428
2 JOYCE ARONOVICJ 85-37 !60'h Street, Jamaica Hills, NY I 1432
------
I !
SAMUEL BENOIT 90-60 Frnneis Lewis Blvd, Village, I ]428
5
6
f 7
8
I 9
L 10
ROBERT BISHOP 52-46 Concord Ave, Queens, NY I 1362
-
DANIEL CREIGHTON j 62-35 83'd Place, Middle Vill age. NY 11379
-
KA THY DA130UR 82-74 !!8
1
h Lane, #2L, Glendale, NY 11385
-
ELAINE C. JACKSON J 68-20 l 27
1
h Avenue. Jamaica, :'\:Y JI 434
-----
WILLIAM LEWIS 43-60 Doug\aston Parkway Apt 515. NY I 1363
ANDRE A PECOT I 85-37 160'h Street, Queens, ':\!YI 1432
JUAN REYES I 69-36 Harrow Street, rorcst Hills NY 11375
IN WITNESS WHEREOF, I have hereunto set my hand this 28th day of September 2013.
ST A TE OF NEW YORK
COUNTY OF QUEENS SS.:
f -
PHILIP
Chairman
Sworn to before me on this 28'h day of Septl!mbcr, 20 J 3 Philip Ragusa to me known and known
be the person described in and who executed the foregoing instrument and he duly acknowledged to
that he executed the same. ':a
ROBERT ALAN HORNAK
Nolary Public, State ol New York
No. 01H06034606
Qualified In Queens County
Commission Expires March 15, 204

Notary Pub 1c 1J
IN WITNESS WHEREOF, I have hereunto set my hand this 28th day of September, 2013.
ST ATE OF NEW YORK
COUNTY OF QUEENS SS.:
gr;;;_ j?f Q - I

Secretary
Sworn to before me on this 28'h day of September, 2013 Stephanie Zgaljic to me known and known to me
to be th.e person described in and who executed the foregoing instrument and she duly acknowledged to
me that she executed the same.
Page 12
ROBERT ALAN HORNAK
Notary Public. State of New Yolk
No. 01H06034606
Qualified in Queens County
Commission Expires March 15, 201.!:f

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Qlleens Cot111t;' Repuhlica11
New 'lork City\' #I Republican ViJfing
OFFI CIAL l\fE ET ING NOTICE
REPUBLICA\ P1\RTY
\'lFETl':\G
FRIDAY. SFPTl:'.MBf:R 27, 2013 AT 12:30 P\1
To:
\.kt'ting
- ..r. - - -..:;. ::-=-:- :::: __ _
Pk;lSt' t:ike 1wtc rlrnr pur'Wllll tn 1he l:'.kc:i,,11 i .:i\\ nf'\C\\ '."i:;tc. and th.;> Rules nn'i
Regulati1111s of the (l1:,T11' C'N11
1
1y :ind l\e11· Yc·rh Sin!c P<l11). an
Org:111izutio1wl of the Qu<'en..; Republican is hcreh) ;;aJktL ;1;1d 's
scheduled lo be held on Friday, Sq1temhl'r 27. 201.3 at the Rrccption Housl'. 167-l i
Blvd, Flushing, I U:'i7 at !2:.30 P\1
The mcc1 ing. i:; called l\)1· the: Pl the t'b:tion of officers. T'hc co111ir.inec alsl'
consider !'lich ,,tlwr and pn,pcr husme,;s 0:; may lw prL·scntcd h) tht: :ncmhers
If you arc u11ahk tll pt:r,ona!ly ;1tll'i)d. a i'l'OX) i> .:nc:o;ed t(,r yut1r C<'llYC1iic1·,:;;o'. I 1;rgc
mcmk·h to irnmcdiatciy n.:111:11 the Official Pru'i:"' in the cnci,,,:.,·d
add1L"sscd t'mclnpc lo Ille Ourcns RL·puhlican 24-55 Francis Lc>'.\is
Blvd, Whitestone, NY 11357.
l'ro:xy l k>ldcrs arc nth·ised cn:J<.'11tials C\Hn111it1<.:c 1\ i!I ,1.,;ccpt111g ;1:"'.x:cs :1p
until 7 P!'d on September at our :1cndqu;irr,·r:; il l 24-5: Fr;111>:15 Le\1 is 8!1d.
\\'hikstonc. NY 11357. l'roxi:.:,; \1i'I :wt be • 1ha1 t: :1:c. This fom ck;; llin,
\\ill ullo11 the .:ommi!!L'c' the ti111c I<' nn·lp ·1 h v-=i·if: :1ll .:ri:·;k11t i11 '.<• th:ii t!n:
111L-ctin,:? is llL't 1:l'idt.1!) d•:l:i: cd l''!' ;m·· u·:: ·:L·d. I''' 1!! be pr-." idcd.
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1)lcnsc do iltlt htsitatc iL' call "' ::t (iUl' HcnJq11,;r:,·:·:; ;11 (-1 ()rt(l._i-:: .: \\ c
:1pprL'Ci:Ht' \(·ry inuc!1 cn11\i1111L'd i11tc·rcs1 :md .::o,)pL·r;iti1Hl .
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l'hii Ragus'i1
Chai1111L1n
P.S. A t:ll\dopc is cn<.:k>sed for : -<'L1r ,·,111\'cnicrn:l' It is vit;.illy i111p,)11n11t
that \\'e haven sufficient nuinbcr in at1c:11d:i11cc or PW\) Fi,rms mailed in w
obtain a Quornm so that we 111:1y prnpcrly organize the P:irry ::!Hi n:nrnin an active fort:c
in the' critirnl upcoming in 2013 and k:l'nd. Fl'en if:ou pl?.n to :·HtL·nd.
m.rr.il j Ql1J_Q.!Q:'0.' ii_1
co:n
Plione 718-690-3737
?A-55 C:'<if1C!S lewis Bovievard
Nev•1 York ; 1357
VNIW QGOP ".:Offi
Fax· 11 c-:·45.535G
Vl.:RIFIC:\'l'ION
STAfE OF NEW YORK
cot.:NTY OF NASS/\U ) ss.:
Thomas V. Ognihenc being duly S\Yorn deposes nnd says:
that I am an attorney at Law duly licensed to practice law in the State of c w York. and am the
attorney for the Petitioners hen:in.
That I make this verification pursuant to lhc Ci\'il Prnctice Law and rules.
That I have read the foregoing Petition and know the contents thereoJ: the same is true to
my own knowledge except as to those matters al legt•d on information and belief and as to those
matters I believe them to be true
I make this verifications because my clients ure not in the County where I mnintain m:
office.
Thomas