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STATE OF VERMONT
SUPERIOR COURT
WASHINGTON UNIT
CIVIL DIVISION :
DOCKET NO. 10 ~tU-1
H. Brooke Paige,
Plaintiff, pro se
v.
State of Vermont,
Secretary of State James Condos and
Attorney General William Sorrell
Defendants.
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APPENDIX OF EXHIBITS SUPPORTING THE
VERIFIED COMPLAINT AND PETITION FOR DECLARATORY
JUDGMENT AND INJUNCTIVE RELIEF
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Prepared by the Plaintiff:
H, Brooke Paige
Town Road #17, Box #41
Washington, Vermont 05675
In Consultation with and the Assistance of:
Mario Apuzzo, Esq.
185 Gatzmer Avenue
Jamesburg, New Jersey 08831Table of Contents of the Exhibits Accompanying the Verified Complaint of the Plaintiff
in H. Brooke Paige v. State of Vermont, et al (2015)
PAGE
Exhibit A — Letter of Enquiry to Secretary of State James Condos, dated 7/31/15 (1-2)
(p. 3) - Candidate Information Form (completed by Plaintifi) G)
(p. 4) ~ Plaintiff/Candidates Certificate of Live Birth @)
(p. 5) ~ Plaintiff/Candidate’s Birth Certificate (front) 6)
(p. 6) ~ Plaintiff/Candidate’s Birth Certificate (reverse) (6)
(p. 7) - Candidate Information Form (suggested revision, blank) (7)
(p. 8) = Vermont Presidential Petition of the Plaintiff (8)
(p. 9) - Vermont Presidential Petition (suggested revision, blank) (9)
Exhibit B — Reply Letter from Secretary of State Condos, dated 9/17/15 (10-11)
(p. 3) ~ Petition for Nomination as issued by Elections Office (12)
(p. 4) ~ Consent of the Candidate Form (17 V.S.A. §2702) (3)
Exhibit C— Decision of the Vermont Supreme Court, dated 10/18/2013 (14-19)
Exhibit D — “The Justiciability of Eligibility: May Courts Decide Who Can Be (20-29)
President?” Dr. Daniel Tokaji, Ohio State University (2008)
Exhibit E — Definitions of the Words, Phrases and Idioms found in the (30-34)
Constitution of the United States of America, Compiled by
H. Brooke Paige - 2013
Exhibit F — The Intended Meaning of the Words and Idioms used by the Framers
to Identify and Differentiate the Various Characteristics of Citizenship and
the Reasons for their Inclusion in the U.S. Constitution.- H. Brooke Paige.
April 15, 2013, (35-46)
Exhibit G- A Citizen is One Thing, But a Natural Born Citizen is Another.
by Mario Apuzzo, Esq. - November 29, 2015 (47-58)
Exhibit H — Senator Cruz, Senator Rubio, and Governor Jindal Should Not Be
Allowed to Participate in the Presidential Debates Because They,
Like De Facto President Obama, Are All Not Natural Born Citizens
and Therefore Not Eligible to Be President By Mario Apuzzo, Esq.-
May 25, 2015 (59-63)
Exhibit !— The Forgotten Presidents of the United States and the Evolution of
the Office of President of the United States - compiled by
H. Brooke Paige - July, 2012 (rev. 09-30-15) (64-77)H. Brooke Paige
‘Town Road #17, Box #41
Washington, Vermont 05675
James Condos
Vermont Secretary of State
128 State Street
‘Montpelier, Vermont 05633-1011
July 31, 2015,
Re: Information and requirements for inclusion on the 2016 Presidential Primary Election Ballot
Dear Sir,
In anticipation of my petition drive to be included in the 2016 Vermont Presidential Primary, | wish to clatfy
several issues to assure that my efforts and those of my supporters are not diminished or in vain,
First, | am requesting that your office verify that | am constitutionally qualified to run for and serve in the office |
am seeking. To that end, | have included a form which solicits information essential to the verification of
ualifications for the office of President of the United States and obtaining certain other information such as
address, contact numbers and the like. have provided a copy of the form in blank and completed with my
information. Additionally, | have included a certified copy of my birth certificate and certificate of live birth to
confirm the date and location of my birth as well as the citizen status of my parents at the time of my birth. 1
believe that such information should be required of all candidates seeking inclusion on the Vermont Presidential
Election Ballot and wish to lead by example in providing the necessary documentation.
Secondly, Ihave attached a copy of the petition | wish to use - as | believe the information and form ofthe petition
form posted on the SOS web-site i insuficient to ascertain that those signing the petition are in fact qualified to
sign a petition for a candidate on the Vermont Presidential Ballot. Please review my proposed petition and confirm
that its sutficient for use in the Vermont primary.
‘While | understand that your Election Office asserts that you, as Secretary of State, have only a ministerial
relationship to the election process, | believe that your office does have the right and responsibilty to request and
collect sufficient information and documentation for the Superior Court of Washington County to promptly
ascertain the Constitutional qualifications of each candidate seeking inclusion on the ballot.
Please contact me at your earliest convenience to confirm that: (2) that my personal information and
{documentation confirms my Constitutional qualification to seek the office of President (or inthe alternate, that |
‘must petition the Superior Court to receive the conformation | am requesting), (2) that the form of the “Candidate
tnformation Form” is acceptable and whether your office will request all cancidates to provide the same necessary
information and (3) the form and content of my petition is acceptable and sufficient
Your prompt attention and response will be greatly appreciated.
3
H. Brooke Pai
Enc. (6)
Exhibit A-p.1 ay