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ROBERT L. AVERS
RAvers@dickinsonwright.com
734-623-1672
State of Michigan
Bureau of Elections
PO Box 20126
Lansing, MI 48933
Enclosed, please find a sworn complaint and corresponding exhibits challenging the
nominating petitions submitted by Mr. James Craig in connection with his gubernatorial campaign.
See generally MCL 168.552(8).
Please note that due to the size of the Microsoft Excel file referenced in the sworn
complaint as Exhibit 1-A, that file has been provided in native format as an email attachment.
Further, please also note that the Excel file contains two “sheets” or “tabs” – one titled “Defects”
and another titled “Duplicates.”
If you have any questions about this submission, please feel free to contact my office.
Sincerely,
Robert L. Avers
Enclosures
STATE OF MICHIGAN
BOARD OF STATE CANVASSERS
SWORN COMPLAINT
investigate whether a multitude of signatures on James Craig’s nominating petitions are valid and
2. Specifically, and as set forth in the affidavit attached hereto as Exhibit 1 and the
corresponding Microsoft Excel file attached as Exhibit 1-A, there is reason to believe that a
3. The spreadsheet attached as Exhibit 1-A specifies each signature being challenged
by sheet number and the line number bearing the signature, as well as the reason(s) why the validity
4. Further, based on the findings set forth in the attached exhibits, there is reason to
believe that the number of deficient signatures on Craig’s nominating petitions is such that his
campaign has failed to submit the requisite number of signatures to qualify as a gubernatorial
Accordingly, and for the reasons stated above and those set forth in the attached exhibits,
I respectfully request that the Board sustain this challenge to the candidacy of Mr. Craig, and that
1
Exhibit 1
Exhibit 1-A
(Excel file provided in native form)