V I R G I N I A: IN THE CIRCUIT COURT FOR THE CITY OF RICHMOND

JOHN MARSHALL COURTS BUILDING

In re: Petition for a Referendum Election

)
)
)
) Case Number: CL18-5131
)
)
)
)
)

PETITIONER’S WRITTEN OBJECTIONS TO THE REPORT OF CONSULTANT KIRK SHOWALTER

Now comes Petitioner Paul Goldman, as directed by the Court, submitting his written objections
to Ms. Showalter’s Report, which Petitioner finds to include the very severity of problems one would
expect since she secretly told a member of the media – neither the Court nor the Petitioner – that if
“you read the court order for how we are to check the petitions, it directs me to use the state
regulations” saying further that “since I have no authority in this matter beyond that court order, then it
is what we are doing. What challenges to that Paul may wish to bring is between the court and him,”
such view plainly incorrect and in effect creating an adversarial counting process when that is not the
intent of the City Charter. (Exhibit # 1)

ACTUALLY, IT’S NOT JUST BETWEEN PAUL AND THE COURT.

1. The Referendum election being sought by Petitioner, in association with a record number
of like-minded Richmond residents, stems from a legal power sought by, and given to,
the citizenry through their duly elected state legislative representatives pursuant to
Chapter 711 of the Acts of the 1998 Session of the General Assembly.
2. This new Referendum right is now found in §3.06.1 of the Charter of the City of
Richmond.
3. Once granted, the right to petition, and those associational and core speech rights
required to effectuate such a petition effort calling for an Advisory Referendum, are all
fully protected by the 1st Amendment of the Constitution of the United States, applicable
to Virginia through the 14th Amendment. Meyer v Grant 486 U.S. 414 (1988).
4. These “core political speech” rights are among the most highly protected from
denigration by government action or government officials. Id.
5. Petitioner believes the approach taken by the Registrar in the instant matter highlights
the reason the Virginia Supreme Court has said when such fundamental rights are at
issue, the actions of the government in imposing restrictions should require a
 “compelling government interest.” See e.g., Mahan v National Conservative Political
Action Committee, 315 S.E. 2d 829, 832 (Va. Sup. Ct. 1984).
6. Indeed Meyer, as reaffirmed by Buckley v. American Constitutional Law Foundation, Inc.,
525 U.S. 182 (1999), said the level of protections for the activities engaged in by those
championing the “Choosing Children over Costly Coliseum” are at their “zenith.” Id at
187.
7. §3.06.1 sets a very high bar for citizens using this right, so much so it has only been
successfully done twice in city history, in 2003 and 2017.
8. As the Court Order notes, said citizens must gather the enormous total of 10341
approved signers as a precondition to having the Referendum put on the ballot.
9. By contrast, presidential candidates, despite having vastly more resources, and a
universe of potential voters many times bigger, need only get 5000 signatures collected
statewide to get on the ballot. Va. Code §24.2-545 (B), §24.2-543 (C).
10. On a rough statistical comparison, a presidential candidate needing to meet the City
Charter signature threshold would need to get 3000% more valid signers.
11. Self-evidentially therefore, the time, effort and expenditures to get such Advisory
Referendum on the City ballot is considerable.
12. Petitioner is fully supportive of the fact, as the Courts have said, that election officials
play an important and necessary role in such process. Storer v Brown, U.S. 724, 730
(1974).
13. But the Courts have equally warned such officials that their actions, along with the laws
and regulations attendant, must meet considerable constitutional muster. Anderson v
Celebrezze, 460 U.S. 780, 789-790 (1983).
14. The general right “to petition the government for the redress of grievances” is contained
in §12 of the Bill of Rights in the Constitution of Virginia.
15. Relying on these guarantees from federal, state and local government along with the
Courts created to protect these rights from government denigration, Petitioner, in
association with at least 10341 Richmond voters, did their best to adhere to the rules.
16. Based on the basic rules of statutory construction and general principles of law,
Petitioners had every constitutional and legal reason to rely on the belief that Va. Code
§24.2-684.1 would be operative in this process even before the mention of this statute in
the Court Order. Infra, paragraph 29.
17. Petitioner filed the Referendum Petition with the Clerk of the Circuit Court (hereinafter
“Clerk”) as required by §3.06.1.
18. Knowing that the General Registrar of the City of Richmond (hereinafter “Registrar”) has
made clear she will only act under Court Order in these Referendum matters – and
knowing the Circuit Court had indeed endorsed this approach in 2003 and 2017 -
Petitioner tried to secure said Order many months ago to facilitate the counting of the
signatures.
19. This proved unsuccessful and the Petitioner went about his petitioning business.
20. Several months ago, as important deadlines for the Referendum effort grew nearer,
Petitioner sought to find the language the Registrar would accept, for as her lawyer said,
“we can fashion an order, but it has to work for her schedule.” (Exhibit # 2).
21. Petitioner had no interest then, and has none now, of imposing on the Registrar’s time,
the only interest being to get a fair, transparent and speedy count.
22. On July 12, 2019, this Court issued an Order in the instant matter (hereinafter “Order”).
23. The Order instructed the Registrar to complete her “check of the petitions in a ‘timely
manner’ and report back to the Court.”
24. The Order allowed the Registrar to complete her check as soon as possible and deliver
her Report at any time but “no later than by 4:00 p.m. EST on August 13th, 2019 and shall
report the findings consistent with this order.”
25. The date of the Registrar’s transmittal letter accompanying the Report sent to the Clerk is
August 13, 2019.
26. The time stamp on the copy of this letter given to the Petitioner says the Report was
“received and filed” at 3:52 p.m. or roughly 8 minutes before the deadline.
27. According to the transmittal letter, the Registrar said “[o]ur review was able to identify
the signatures of 9,941 qualified registered voters of the City of Richmond.”
28. The Order is clear, stating that for “purposes of counting the petition signatures, the
process will be as follows” then listing 10 separate items relative to this process.
29. The first such item says “1. The provisions of VA Code §24.2-684.1, Administrative Code 1
VAC 20-60-20, (sic) Charter for the City of Richmond §3.06.1 shall govern the process for
counting the petition signatures.” (Emphasis added).
30. At no time during the discussion of this ORDER did the Registrar indicate to the Petitioner
she felt bound by the regulations, not §24.2-684.1, should there be a conflict between
the two.
31. Upon information and belief, the Registrar likewise did not inform the Court either.
32. At the Hearing on August 15th, the Court entered the Report into evidence over the
objections of the Petitioner.
33. The Registrar was not in the Courtroom nor did she submit an affidavit as to whether she
followed that part of the Order in paragraph 29 supra.
34. Her transmittal letter makes no mention of any decision to follow state regulation 1 VAC
20-60-20 instead of Va. Code §24.2-684.1, a discussion of the difference between the two
on what Petitioner calls the “address issue” is contained in the Petitioner’s Motion to
Compel and is now incorporated by reference herein. (Exhibit # 3).
35. Upon information and belief, the Registrar has not formally informed the Court of how
she decided to resolve this conflict, at least in writing.
36. Indeed, the precise status of Ms. Showalter in this matter is unclear to the Petitioner.
37. Her lawyer described her role to Petitioner as “a reviewer and consultant.” (Text message
from Mr. Tunner copied Exhibit # 4).
38. Petitioner’s interest in her status is not idle curiosity but goes to the weight her Report
should receive in this matter.
39. For example, a candidate for office can challenge a Registrar’s decision to disqualify said
candidate from the ballot under Va. Code §24.2-506 (C).
40. The State Board of Elections created 1 VAC 20-50-30 to flesh out their view of the
requirements of such a challenge under Va. Code §24.2-506 and Va. Code §24.2-543,
both involving disqualified signatures on candidate petitions as opposed to referendum
petitions.
41. In the candidate process pursuant to 1 VAC 20-50-30, the “candidate bears the burden of
proof” for proving, in effect, that the Registrar erred in denying said candidate a spot on
the ballot by wrongfully disqualifying signatures.
42. This process, as a practical matter, is defendable under applicable Due Process
requirements since (1) since there is no constitutional right to be on the ballot and (2)
the likely candidate challenges would invariably involve petition requirements of a
relatively small number of signatures.
43. The instant matter requires Ms. Showalter to review roughly 15000 signatures.
44. Therefore, from a legal and practical perspective, the time frames in the 1 VAC 20-50-30
approach would be impossible in the instant matter.
45. As best Petitioner can ascertain, there is no statutorily mandated review process for the
Referendum petitions at issue, moreover the only two previous Referendum drives under
Charter §3.06.1 were found to have achieved the signature threshold without any
hearing.
46. Since, from a constitutional standpoint, a candidate has no constitutional right to be on
the ballot, there is no due process issue in giving a presumption to the Registrar.
47. But a Referendum Petition, unlike a political candidate petition, is essentially the
collective energies of citizens exercising constitutionally protected rights tied to getting
their redress of grievances on the ballot, albeit in the form of an Advisory Referendum
having no force or effect in terms of its passage immediately effectuating any legal
changes.
48. Unlike the challenge of a candidate to a Registrar’s report – which is issued in the
ordinary course of government business - Ms. Showalter has repeatedly said she is not
acting as the Registrar in this matter.
49. Petitioner is therefore on solid ground raising the question, to wit: Why should her
Report be given any presumption of correctness as a general matter, moreover in the
context of this specific matter given her actions?
50. This is particularly on point given the email sent by the Registrar during the counting
process.
51. It is furthermore on point since we know her transmittal letter is devoid of any specific
explanation of her standards or considerations as regards signatures, except her saying
“(p)ursuant to the order entered on July 12, 2019, (her) Office…reviewed the petitions”
submitted to her by the Court.
52. Petitioner endeavored to get Ms. Showalter to voluntarily agree to at least review some
of the petitions.
53. But Ms. Showalter maintained her previous position that she is powerless to act without
a Court Order. (Exhibit 1).
54. However, she did, on her own, voluntarily review the disqualification of Mr. Tom Wolf, a
former law partner of Senator Tim Kaine and one of the most highly respected lawyers in
our area. The same for his wife also disqualified.
55. Self-evidentially, Ms. Showalter could have reviewed the circumstances of other citizens.
56. Upon information and belief, there was nothing to prevent the Registrar from
volunteering to appear at the August 15th hearing to discuss in detail the process used to
develop her Report.
57. At the August 15th hearing, upon the request of the Petitioner, the Court instructed the
Clerk to give Petitioner a copy of the roughly 900-page Report along with copies of the
more than 1000 double sided petition sheets corresponding to the over 16000-line items
in the Report.
58. The Court gave Petitioner until no later than 4 PM, August 30th, 2019 to file written
objections to the Report, such objections contained herein.
59. Petitioner endeavored to resolve the matters at hand in a collaborative way.
60. But as the saying goes, it takes two to Tango.
61. Whether Ms. Showalter is acting as the Registrar, a consultant/advisor, or other capacity
is not for Petitioner to decide.
62. But given Ms. Showalter’s email, Petitioner is left with no other practical choice but to
make the following objections for the record.

1. DISREGARDING VA. CODE §24.2-684.1 SHOULD MAKE THE REPORT FATALLY FLAWED.

63. Upon information and belief, no signer failing to list an address has been counted as part
of the 9941.
64. There is nothing in the Registrar’s report to indicate the Registrar attempted to
determine if the signatures of said individuals would have been counted had they listed
what the Registrar regards as the appropriate address.
65. There is nothing in her Report to indicate Ms. Showalter ever intended to voluntarily
bring her decision to bypass §24.2-684.1 to the attention of the Court.
66. Her decision to simply disregard the statute or the plain language of the Court Order has
no legal justification.
67. Moreover, her decision to disregard the law in favor of 1 VAC 20-60-20 has serious
ramifications beyond only the many signers not providing any address.
68. 1 VAC 20-60-20 (C.5) imposes the ultimate petition sanction, as discussed in the Motion
to Compel, for voters who provide a Richmond address next to their name on the
petition sheet but not the Richmond address required by said regulation.
69. Petitioner discovered that many hundreds of voters fell into this category.
70. Based on Petitioner’s experience, this is generally the biggest category of disqualified
voters.
71. Self-evidentially, if no address is required, then the additional address requirement of 1
VAC 20-60-20 (C.5) is likewise not applicable for Referendum petitions.
72. Fortunately for Petitioner, the method used for circulating some petitions – for example,
on Election Day – has facilitated his ability to track down many Richmond residents
wrongfully not counted as part of the 9941 in the Report.
73. Furthermore, by choosing to enforce 1 VAC 20-60-20 (C.5) over not only Va. Code §24.2-
684.1, but also over §24-101 as amended by Chapter 684 of the Acts of the 2013 Session
of the General Assembly, the Report wrongfully disqualifies even more voters.
74. Instead of separating out this “address issue” as a separate exhibit, Petitioner has chosen
to put all those seemingly impacted by the Report’s flawed reasoning into a master list of
challenges to the Report’s disqualifications of Richmond voters. (Exhibit # 5).

2. THE DISQUALIFICATION PROCESS USED IN THE REPORT APPEARS TO HAVE A

DISCRIMINATORY IMPACT
75. While the basic state policies at issue in the instant matter created the general problem,
the arbitrary and capricious actions contained in the Report appear to have exacerbated
the situation.
76. The great majority of the citizenry moving between elections are working families,
especially minorities, students, and renters. Homeowners are far more likely to keep
their same residence, and thus the same voter address, for several years or more before
moving, unlike those individuals referenced above.
77. This is a basic fact known to anyone involved in political activities.
78. Until Petitioner has had the opportunity to complete his review of this aspect of the data
in the Report, he concedes his observation is based on his expertise in campaigning.
79. But Petitioner does have a good faith basis to draw the Court’s attention to the increased
inequities almost certainly caused in this area by the failure to abide by Va. Code §24.2-
684.1 as regards the provision of an address.

3. THE REGISTRAR’S REFUSAL TO VOLUNTARILY REVIEW SOME SIGNATURES IS

CONTRARY TO SPIRIT OF THE LAW

80. The process of reviewing the signatures in this matter is not created under the City
Charter as an adversarial process.
81. Petitioner agreed to the Court Order the Registrar wanted.
82. Upon information and belief, the Registrar was fully aware of various deadlines
associated with this matter and the November ballot.
83. The Registrar knows, as Petitioner pointed out in his Motion to Compel, that a certain
percentage of wrongful disqualifications are inherent in such a massive data set.
84. Since Petitioner has only one fundamental interest at this juncture – finding 400 more
voter signatures to count – it follows logically he would give the Registrar those he
believed she would most likely agree to count, not the one’s least likely.
85. As referenced in Meyer, supra, government officials, especially election law officials, are
supposed to hold in high regard the very rights whose protection requires such officials in
the first place.
86. Petitioner fails to see how the Registrar could reasonably believe she would not be
required to recheck the signatures referenced in paragraph 84, supra.

4. THE 15 DAY REVIEW PERIOD IS NOT SUFFICIENT GIVEN MAGNITUDE OF ERRORS IN

THE REPORT.

87. The Petitioner is not a novice in these matters, having run Doug Wilder’s historic
campaign for example.
88. He has worked diligently for two weeks reviewing matters in the Report, expending time,
energy, and funds.
89. The refusal of the Registrar to voluntarily help further required the Petitioner to put in
the time and energy to seek a Motion to Compel.
90. Petitioner has also been the State Democratic Party Chairman and has written state laws
on petitioning.
91. Based on his experience, the number of serious, legitimate challenges to the
disqualifications of Richmond voters, even long time Richmond voters, in the Report is on
 an unprecedented scale, necessitating efforts by a private citizen which exceed anything
previously contemplated in the Commonwealth.
92. Despite such an unprecedented effort, the 15 Day Period didn’t allow time to review a
good chunk of the petitions.

5. AS A LEGAL MATTER, THE REPORT IS ARBITRARY AND CAPRICIOUS.

93. VA Code §24.2-684.1 (1-7) says in pertinent part that each “qualified voter signing the
petition shall date his signature” and that “each qualified voter signing the petition shall
have been validly registered…”.
94. The other five items in Va. Code §24.2-684.1 relate to the requirements for filing the
original copy of the petition to be circulated with the Court, certain requirements of the
individual who starts the petition drive, the optional requirement of listing the last four
digits of the signer’s social security number, requirements related to circulators of said
petition, and the time frame within which the petition may be conducted.
95. The plain language of the statute is therefore clear: there is no requirement for a petition
signer to list an address.
96. By contrast, State Board regulation 1 VAC 20-60-20 imposes strict requirements for a
petition signer to provide the requested residence address, such failure to comply with
this address requirement considered a “material” omission by the signer and therefore
the signature “shall be rendered invalid.” 1 VAC 20-60-20 (C.5).
97. Tellingly, when it comes to signing a candidate petition, as opposed to a referendum
petition, Virginia law does require the signers to provide an address for the Registrar to
check. Va. Code §24.2-506.
98. Va. Code §24.2-506 covers candidate petitions a local Registrar may be required to check.
99. In Va. Code §24.2-506, the General Assembly pointedly required each signer to list “the
residence address…” Va. Code §24.2-506(A).
100. The fact the General Assembly included an address requirement for those signing a
candidate petition but did not include such a requirement when these same individuals
sign a referendum petition clearly demonstrates that state lawmakers intended to
impose differing requirements.
101. It is a common tenet of statutory construction that when the legislature specifically
leaves out words or phrases, they are not to be imputed to the statutory scheme. Grigg v
Commonwealth, 224 Va. 356 (1982).
102. Accordingly, the Virginia Board of Elections lacked the authority to issue regulation 1 VAC
20-60-20, entitled “Material Omissions on Referendum and Petition Signature
Qualifications,” in so far as it imposed a mandatory condition on the exercise of a voter’s
constitutional right to petition not contained in the very statute the agency claimed to be
following. (The regulation itself says this regulation is done “Pursuant to the
requirements of §24.2-684.1 of the Code of Virginia…”). 1 VAC 20-60-20 (A).
103. It is “emphatically the province and duty of the judicial department to say what the law
is” declared Chief Justice John Marshall, the person for whom the Circuit Courthouse is
named. Marbury v Madison, 5 U.S. (1 Cranch) 137 (1803).
 104. An “erroneous interpretation of a statute by those charged with its enforcement” cannot
override the statute’s “clear meaning.” Volkswagen of America Inc. v. Smit, 266 VA. 444,
453 (2003).
105. In Virginia, “when the General Assembly use(s) words of a plain and definite import,
courts cannot assign to them a construction that would be tantamount to holding that
the General Assembly intended something other than that which it actually expressed.”
Mozely v. The Prestwould Board of Directors, 570 SE 2d, 817, 820 (2002).
106. A maxim of statutory construction – Expressio unius est exclusio alterius – says that
where the General Assembly can be shown to have passed a statute providing a clearly
defined intent, there is a presumption against any government agency or official
arbitrarily and capriciously reading such omitted words into the mix. See e.g., Turner v.
Wexler, 244 Va. 124, 418 SE 2d 886 (1992).
107. Given that a highly protected constitutional right is at issue, the Registrar’s action, taken
in an official capacity for a state entity, can’t pass must under Celebreeze, supra at 11.

6. ARBITRARY, CAPICOUS STANDARDS CANNOT JUSTIFY A DENIAL OF CONSTITUTIONAL

RIGHTS.

108. If Petitioner is correct and it is shown the Report is based on arbitrary and capricious
standards, then the Report should be rejected by the Court.
109. The “state action” doctrine applies to the actions of the Registrar in this matter. See, e.g.,
Moose Lodge No. 107, v Irvis, 407 U.S. 163 (1972).
110. A Registrar may not act in a cavalier fashion since “[a] determination that an agency
made a decision without considering a relevant factor leads to condemning the decision
as ‘arbitrary and capricious’.” See e.g., Motor Vehicles 24.2-684.14 Manufacturers
Association v. State Farm Mutual Automobile Insurance Co., 463 U.S. 29, 46-57 (1983).

7. THE REPORT APPEARS TO BE PUNISHING SIGNERS WHO PUT DOWN SOCIAL
SECURITY NUMBERS.

111. Long time Richmond resident Mr. Wolf was not counted apparently due to incorrectly
listing the last 4 digits of his Social Security number.

112. The rest of the information provided by him in signing the petition is apparently correct.

113. Since the provision of the last four Social Security digits is optional, it is disconcerting to
learn such voluntary information can lead to mandatory disqualification.

114. There appear to be any number of people who may have been disqualified due to
informational issues raised when the Registrar’s Office used the Social Security number
as part of the checking process.

8. THE REGISTRAR’S DISQUALIFICATIONS UNDER VA. CODE §24.2-684.1(7) ARE

UNCONSTITUTIONAL.

115. According to the Code Section, signers should only be counted if they “shall have been
validly registered in the jurisdiction for which the petition is circulated at the time of
 signing the petition and at the time of validating the petition signatures.” (Emphasis
added).

116. Upon information and belief, it appears that a sizeable number of individuals who were
qualified to sign the petition and did so exercise their constitutional right have not been
counted on the grounds they have moved out of Richmond after signing a Referendum
petition form.

117. Petitioner is not aware of any case addressing this retroactive loss of a valid exercise of
this constitutional right for such reason, at least in terms of the research he could do
during this review period.

118. In Libertarian Party v Judd, 718 F. 3rd 308 (4th Cir. 2013), the Court stated that as matter
of general principle, the 4th Circuit seemed to adopt the formula in Nader v. Brewer, 531
F. 3d 1028 (9th Cir. 2008) that “the severity of the burden the election law imposes on
the plaintiff’s rights dictates the level of scrutiny applied by the Court” in reviewing
restrictive government action. Judd, supra at 317.

119. Self-evidentially the “severity of the burden” under the statute is as severe as it gets:
your previously exercised constitutional right is wiped out retroactively.

120. To uphold the statute, the Commonwealth of Virginia will at least need a compelling
state interest. Celebrezze, supra.

121. The mere fact someone may have moved a few miles to Henrico County is not a legally
acceptable reason, standing alone, to negate a previous constitutionally valid exercise of
petitioning rights for an Advisory Referendum.

122. For example, one of the Intervenors found to have standing is not a registered voter in
Richmond but apparently resides in a surrounding county.

123. If a county voter has the right to deny 10341 Richmond their right to an Advisory
Referendum, then it follows that a former Richmond voter, having signed the petition in
that capacity, should not have his or her signature disqualified due to having moved into
the same county.

9. REGISTRAR DOESN’T APPEAR TO BE CROSS CHECKING NAMES WITH OLD VOTER FILE
RECORDS.

124. This has long been the practice but upon information and belief, this checking would
yield additional qualified signatures.

125. For example, Petitioners have included in their list of challenges the situation where two
people living in Richmond have the same exact name on the voter list.

126. A person with that name signed a Petition earlier this year.

127. Petitioner, using old voting file data, believes he knows which of the two signed the
Petition.
 128. But he would need access to the Registrar’s old voter files to trace the ID number
assigned to this individual on the voter list to be certain.

129. Given the 15 day review period, the myriad of other issues discovered, and the fact the
Petitioner is a private citizen suggests the burden must be on the public official denying
this voter her constitutional rights to do this legwork, especially since they have refused
to work with the Petitioner in this period to help locate wrongfully rejected voters.

10. PETITIONER IS SUBMITTING OVER 2000 DISQUALIFIED VOTERS FOR REVIEW.

130. Despite the enormous and unprecedented burden placed on Petitioner for the
aforementioned reasons, Petitioner is submitting a list of 2,079 names, Referendum
Page and lines included, along with descriptions of the apparent reason the Report
rejected said signers name.

131. The Report’s descriptions of the reasons an individual had been disqualified aren’t
always as helpful as they could be.

132. If Petitioner had access to the same data available to the Registrar – which of course
isn’t so available to a private citizen – he is quite confident he could find even more
discrepancies, even more wrongly rejected voters, and better information to refute said
disqualifications.

133. Whether it is fair for Petitioner to be denied said information is an important one in
reviewing the process at issue.

134. However the Petitioner, having previously gone through court related processes
involving the counting or disqualification of signatures, is confident that if the Registrar
is required to adhere to the fair, equalized and transparent standards and analysis
required by law, at least 400 signers will be seen as having been wrongfully rejected,
thereby insuring Petitioner did in fact submit the 10341 required signers back in July.

134. The list is hereby attached hereto as Exhibit 5.

CONCLUSIONS AND PRAYER FOR RELIEF

WHERETOFORE and by reasons of the foregoing, the Petitioner having detailed any number of
serious issues with the Registrar’s Report, Petitioner believes one of the two following courses
of action is justified at this time by the Court:

A. The Court should find the Registrar’s Report fails the test of fairness and transparency,
that the actions since revealed make it impossible to be accepted for use in the instant
matter and thus declare the Petitioner to have achieved the required signatures, there
being no untainted evidence or intervenors having presented any evidence, to the
contrary, should decision consistent with fairness in this matter.
 B. Or, in the alternative should A not be granted, and being of the essence for no fault of
the Petitioner, the Court should give the Registrar 5 business days to review Petitioner’s
signatures and show by written evidence why he lacks the needed 400 additional
Richmond voters.
C. In any case, Petitioner asks the Court to order the Registrar to immediately decease and
desist from any further effort to finalize the November ballot, and further order the local
Richmond Electoral Board to take such action as it deems necessary to assist the
Registrar as regards such ballot finalization.
D. And such other further relief as the Court deems necessary given the Registrar’s actions
in this matter.

DATE: August 30, 2019

Respectfully submitted,

Paul Goldman

Petitioner
P.O. Box 17033
Richmond, Virginia 2322
804-833-6313