HHD-CV18-6088961-S :
 SUPERIOR COURT MILLY ARCINIEGA, MICHAEL BRESCIA, JACQUELINE NADAL : J.D. OF HARTFORD LILLIE PARKER, ALEJANDRO RODRIGUEZ, MALY ROSADO, ANNA : SARRAGA-CIERI, ESTELA SEGARRA, PEDRO TORRES, JR, TYRONE WALKER CARL WILLIAMS, HYACINTH YENNIE KATHLEEN KOWALYSHYN : V. : AT HARTFORD GISELLE FELICIANO, DEMOCRATIC : FEBRUARY 17, 2018 REGISTRAR OF VOTERS FOR THE CITY OF HARTFORD; JOHN V. BAZZANO, TOWN AND: CITY CLERK
FIRST PARTY PLAINTIFFS’ POST TRIAL BRIEF
 
Pursuant to order of the Court, Shapiro, J, the first party Plaintiffs hereby submit their Post Trial Brief in support of their Complaint, case in chief, defense to the Counter Claim
Plaintiffs’ Complaint
 and Motion for a Directed Verdict. I.
 
ARGUMENT IN SUPPORT FIRST PARTY PLAINTIFFS’ COM
PLAINT
1.
 
REQESTED RELIEF
 In their prayer for relief the undersigned Plaintiffs asked the Court, in addition to granting the now concluded hearing, that 1) this court declare the petitions circulated by the Pamela Jackson and challenged by the affidavits be declared invalid pursuant to §9-410(c); 2) That this Court hold all the petitions circulated by Pamela Jackson be declared invalid  pursuant to 9-410(c); 3) that this Court declare that the Peterson Slate is not qualified to run in
 
the Democratic Town Committee primary because of the failure to file the necessary number of signatures on or before January 31, 2018 at 4:00 pm.
2. EVIDENCE IN SUPPORT OF REQUEST RELIEF
Attached to the Amended Verified Complaint were seven (7) sworn affidavits in which the affiants identified a signature line which contained their name, address, date of birth and a false signature. (Exhibits 1-7) An additional three affidavits were submitted during the hearing making the same assertion. (Exhibits 9-11) Each affiant identified a signature line which they swore did not in fact contain their signature. The following is a list of the affidavits by exhibit number with the corresponding page they challenged contained in Exhibit 8: Ex. No. 1.
 
Roderic K. McKone page 9 of Exhibit 8(Full Exhibit); 2.
 
Maria Salgado page 7 of Exhibit 8(ID); 3.
 
Beverly Fonfara page 3 of Exhibit 8(Full Exhibit); 4.
 
Walter Fonfara page 3 of Exhibit 8(Full Exhibit); 5.
 
Paul Moon page 4 of Exhibit 8(ID); 6.
 
Jenny Lopez page 5 of Exhibit 8(ID); 7.
 
Josefina Torres page 1 of Exhibit 8(ID); 9.
 
Janice Castle page of 2 Exhibit 8(ID); 10.
 
Johanna Sierra page 2 of Exhibit 8(ID); 11.
 
Jorge Cuevas page 4 of Exhibit 8(ID);
 
During the trial the undersigned elicited in Court testimony of seven witnesses regarding their signatures on petitions circulated by Pamala Jackson (Ex. 8). Each witness examined their alleged signature and testified that it was not in fact their signature. The following is a list of these witnesses and the page on Exhibit 8 upon which they testified: 1.
 
Hilda Negron page 1; 2.
 
Luis Sierra page 2; 3.
 
Beverly Fonfara page 3; 4.
 
Milly Arciniegas page 5; 5.
 
Maria Selgado page 7; 6.
 
Jane Grahn page 7; 7.
 
Rodric K. McKone page 9. Mrs. Arcineegas testified that she was familiar with her husband of over twenty years signature and that of her twenty-year-old
son’s and that in her experience both of their signatures
were also falsified on page 5. There was live testimony that six sheets of Exhibit 8 contained false signatures. Additionally, the affidavit of Walter Fonfara was admitted as a full exhibit as to the falsification of his signature. Therefore, eight individuals offered admitted evidence that six of the sheets in question contained forged signatures. That means just by the admitted evidence and not that of the exhibits which were marked for ID, two thirds of all of petitions submitted by Beverly Jackson contained signatures which were not those of the individuals who purportedly signed the documents in question.
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