STATE OF NEW YORK

NEW YORK STATE EDUCATION DEPARTMENT

In the Matter of Application of John P. Ghezzi,

Patricia K. Shannon, Christine E. Lenaghan, et al.,
challenging the actions and determinations of the
Board of Education of the City of Atbany School
District in connection with the holding of the
meeting of voters held on February 91 2016 to
adopt a budget for 2016 and approve a bond in
connection with the construction of the Albany
High School

NOTICE OF
PETITION ON
APPEAL

PLEASE TAKE NOTICE that upon the attached duly verified Petition of the
petitioners herein sworn to on

tne 21& day of Febru ary, 2016 together with

the

attachments and exhibits attached thereto, the said petitioners appeal to the Commissioner

of Education of the State of New York from the decision and certification by the Albany
City School District of the results of the school district meeting and the votes cast thereat
on February 9,2016 that the budget and bond issue for the Albany High School were
approved by the voters and notice is further given that the City of Albany School District

shall file with the Office of Commissioner of the New York State Education Department
its appearance and answer to the allegations set forth in the Petition herein in accordance

with the Regulations of the Commissioner of Education which are available at

!v.i-\-l\ii-ti.9lt-LltelJlls-qd.g!,):

or from the Office of Counsel, NYS Education Department,

State Education Building, Albony, New

york

12234.

lf an Answer is not served and filed in accorclance

w,ith the provisions of such

rules, the statements contained in the Petition herein shall be deemed to be true
statements, and a decision

will be rendered thereon by the Commissioner.

PLEASE TAKE FURTHER NOTICE that such rules require that an answer to
the petition must be served upon the petitioners, or

if they

be represented by counsel,

upon their counsel, within 20 days after the service of the appeal, and that a copy of such
answer must, within five days after such service be filed with the Office of Counsel, New

York State Education Department, State Education Building, Albooy, New York 12234.
PLEASE TAKE FURTHER NOTICE that this Petition on Appeal also includes
an application for a Stay of such Certification of the Election results by the Albany City

School District and Affidavits in opposition of this stay application must be served on the
undersigned attorney and filed with the Office of Counsel to the State Education
Department within three (3) business days after service of this Petition on Appeal.

PLEASE TAKE FURTHER NOTICE that your petitioners request oral

argument of this appeal and a hearing on such facts as may be disputed herein as allowed

in section

27

6.2 of the Education Law.

Dated: February

il,

roru

tr-Lw
.,%"*

E. swEENEy, ESe.
Attorney for the Petitioners
Office and P.O. Address
79 Columbia Street
Albany, New York 12210
Te[: (518) 281-3994
I

1II

q311 ! t LtUt !rgLc:._qrg

STATE OF NEW YORK

NEW YORK STATE EDUCATION DEPARTMENT

In the Matter of Application of John P. Ghezzi,

Patricia K. Shannon, Christine E. Lenaghan, et al.,
challenging the actions and determinations of the
Board of Education of the City of Albany School
District in connection with the holding of the
meeting of voters held on February 91 2016 to
adopt a budget for 2016 and approve a bond in
connection with the construction of the Albany
High School

TO:

VERIFIED
PETITIOI\ ON
APPEAL

THE COMMISSIONER OF EDUCATION

OF THE STATE OF NEW YORK
The Petitioners herein, by their attorney John E. Sweetrey, Erq., each being a

resident and duly qualified voter of the City of Albany and eligible to vote at the Meeting

of the Albany City School District on Febru ary 9, 2016 make the following petition in
support of their appeal to the New York State Commissioner of Education from the

certification of the results of the budget vote approving the bond issue for the
construction of the Albany High School published by the Albany City School District on

February
I

17

,2016.

The nanles and residence addresses of the Petitioners to this appeal are set

forth in the attached Exhibit A, each of whom is a resident of the City of Albany and
registered to vote and qualified to vote in School District Meeting held on February g,

2016 at which a vote was taken on the approval of the budget for the Albany City School

District to include approval or disapproval of the bond for the City of Albany High
School.

2.

This appeal is taken pursuant to the Education Law to the Commissioner of

Education of the State of New York with offices at the NYS Education Building at 89
Washington Avenue, Albany, New York 12234 from the decision and certification by the

Albany City School District of the results of the voting held on February 9,2016 that
approved the passage of such bond.

3.

For the reasons set forth herein it is respectfully submitted that such decision

and certification of the election results by the Albany School District were erroneous and

invalid and should be set aside.

4.

Your petitioners, for the reasons set forth herein, request a stay of such

decision and certification of the election results pending a final decision by the
Commissioner of Education on this appeal and further request oral argument of the matter
as may be

allowed under the procedures and regulations of the Commissioner.

FLAWS IN THE CONDUCT OF THE ELECTION:

INSUFFICIENT PAPER BALLOTS

5.

The initial flaw that doomed the February 9, election, was the willingness

of

the Albany School District to ignore the statutory requirement of the Education Law at
section 2608, subd. 3, which requires the district to provide a sufficient number of ballots

for City of Albany voters to cast their ballots on this important and consequential issue of
a orle hundred eighty million dollar new tax burden on City of Albany taxpayers.

6.

More specifically, this requirement states

that:

"There shall be delivered to

the inspectors in each school election district on the day of the annual election, before the
opening of the polls therein, a supply of such ballots which shall at least equal the
number of qualified voters entitled to vote in such district." (Education Law, section
2608, subd. 3).

7.

The Times Union reported in its post election coverage that the School

District had ordered

8.

total of 5,250 ballots for the entire citywide election.

In last fall's close election on the high school bond issue the total vote cast in

the City of Albany was 11,674 votes

- 5,791 in favor of the bond issue and 5,883

opposed.

9.

For a redo of that election three months later, the school district ordered and

provided to the fifteen polling places for the February 9, election, a total of 5,250 paper

ballots

that totaled less than one half of the total votes cast on the same issue at last

fall's general election. (Attached hereto as Exhibit B is the list of the polling locations
for the February 9, City of Albany school district election by Ward and Election District.)

10.

One of the polling places in the February 9, election was at Mater Christi

school where four districts from the

8'h

ward (Election Districts 1 through 4) and all nine

districts from the l4s ward were combined into one polling place. The total number of
voters from the

8th

ward were 1,992 and the total number of voters from the l4'h ward

were 4,386 for a total number of registered voters eligible to vote at the Mater Christi
school of

6,378. (Attached

hereto as Exhibit C is the enumeration of the total number

of

registered voters in each election district by Ward and the total vote for and against the
passage of the bond issue in the November,20l5 General Election as taken from the

official records of the Albany County Board of Elections)

I

l.

Thus, the initial purchase of 5,250 paper ballots by the school district

administration to conduct the entire city-wide February 9, election did not even meet the
statutory requirement of the Education Law to provide one polling place, the Mater

Christi school, with the statutorily mandated number of ballots. The total number of
registered voters in the City of Albany eligible to vote in the school district election was

44,104. (See Exhibit C).

12.

The obvious catastrophe was put off during the day by the careful

distribution of ballots throughout the city until the voters started coming home from work
and went to their polling places and by about 4 p.m., and to no one's surprise, there were

not enough ballots to continue the voting throughout the city.

I

3.

After the careful and measured creation of this disaster, the school district

administrators then order 2,200 additional paper ballots during the day, while stranding
hundreds of voters throughout the city at various polling places trying to vote without
ballots.

14.

This results in the obvious chaos and confusion and impatience throughout

the city's polling places as a mere 53 total inspectors appointed by the School District for
the fifteen polling places try to be professional and courteous to outraged voters.

15.

The dramatic decline in voter participation in the February 9, school budget

vote is by 3,915 voters ( total votes cast in November, 2015 - 1l ,674less 7,759 total
votes cast in the February 9, budget vote

).

This constitutes a one-third decline in voter

participation in the second vote held on Febru ary 9.

16. Is it the School District's conclusion that suddenly after three months the
taxpayers and voters in the City of Albany lost interest in the question of whether
spending 180 million dollars on a new high school was a good idea and worth the money.
17

For over one hundred years, voting in the City of Albany has been a

cherished family right, handed down by generations and exercised by young and old and
is never ignored.

18.

The City School District this year changed the rules by blatantly and with

malice taking away the only object necessary to hold an election

19.

- the ballots.

The Education Law explicitly provides the obligation on the City of Albany

School District to provide ballots at section 2609, subd. 2 where it states:

"All

persons

whose names appear upon the register prepared for such election as residing in such
election district shall be permitted to vote and shall be given ballots for such purpose."

ABSENTEE VOTERS

20.

- DISABLED AND ELDERLY

The Election Law at section 8-400, subd.4 provides that voters, who have a

perrnanent disability or illness, are entitled to have an absentee ballot sent to them

automatically by the Board of Elections for each election for which they are eligible to
vote.

2l

In the City of Albany there are approximately 700 such perrnanent absentee

voters eligible to have cast their ballots in the February 9, 2016 budget vote and to have
received their absentee ballots automatically from the Albany School District which ran
the election.

22.

The list of registered voters in the City of Albany eligible to vote in the

February 9, election was sent to the School District by the Albany County Board

of

Elections, and on such list indicated which voters were perrnanently disabled voters to

whom an absentee ballot was required to be sent automatically without any further
personal application for such ballot being made to the school district for this election.
(See, Election Law, section 8-400, subd. 4)

23.

The Election Law at section 5-612, subd. 3 requires that when a Board

of

Elections sends such a list of qualified registered voters to a school district in connection

with an election at a school district meeting, the Board of Elections shall indicate on such
list or by the making of a separate list, the names of all of the voters who are
"permanently disabled".

24.

Upon information and belief, such identification of "permanently disabled"

voters was timely sent to the Albany City School District by the Albany County Board

of

Elections.

25. Priorto the election on February 9, it came to the attention of certain family
members and friends of voters who were perrnanently disabled that they hacl not yet

received their absentee

ballots. At that time

steps were taken by some of those

individuals to ttrake a specific application fbr an absentee ballot for those permanently

disabled voters to receive and vote by absentee ballot.

26.

Having recently received this information and not knowing the extent to

which "permanently disabled" voters were not automatically sent absentee ballots by the
school district prior to the February 9, election, your petitioners have caused a written
letter to be sent to many of the voters on the list of perrnanently disabled voters to learn

if

they received their absentee ballots from the school district prior to the election.
27

Because the permanently disabled list consists of voters who are frequently

elderly and more significantly are people with disabilities who constitute a protected class

of people under the Americans with Disabilities Act who are not able to personally get to
a polling place because of such disability or able to endure standing in voting lines
because of a serious illness, such a failure to protect the voting rights of these individuals

is a particularly significant violation of the state and federal statutes and regulations that
have been adopted to protect such voting rights from the discrimination that is alleged to
have occuffed here by the particular acts of the Albany School District.

28. In the event that there is a demonstrated

failure to provide each of the

pennanently disabled voters in the City of Albany with an absentee ballot, the narrow
margin by which the bond vote was passed is easily offset by the large number

of

perrnanently disabled voters who were presumptively not provided an opportunity to vote

in this election.

29.

The Education Law at section2018, subd.2(g) requires that the Albany

School District have sent out absentee ballots to the voters who were identified as

"permanently disabled" without any further application or steps being required of such
voters to automatically receive their absentee ballots for the February 9, election.

PRIVACY RIGHTS OF VOTERS DENIED:

30.

[n the late afternoon of election day, as the supply of official paper ballots at

each of the polling places in the city was depleted, rather than wait hours for any

supplement supply of official ballots to arrive, some polling place inspectors used self
help to go to the school office and create a photocopy of the ballot and provided that for

voting purposes at their polling place.

3I

Upon information and belief at several polling places now operating under

these unique circumstances, the inspectors added a new requirement that each of the

voters who voted on these emergency ballots had to sign their name on envelopes into

which their ballots were placed before they were allowed to cast their ballot. At least two
such polling places were at William S. Hackett Middle School on Delaware Avenue (6ft

Ward) and the Montessori Magnet School on Tremont Street (12* Ward).

32.

It is well established in the Election Law that the secrecy and privacy of a

voter's casting of his ballot at a polling place shall be held as one of the highest priorities
and the new requirement that a voter should now be forced to identifo his ballot with his

nalne and signature when it is placed in an envelope forever connected and identified as

his ballot at the polling place destroys whatever hope or expectation that such voter may
have held that his vote would be anonynlous and secret. This loss of privacy becarne
even more blatant when ballot envelopes were opened individually by inspectors before

the close of the polls so that each such voter's vote became public knowledge.

33.

The consequence of this intimidating and unauthorized requirement that

before a voter could cast an emergency ballot that they had to place their signature and
name on such ballot was, upon information and belief, obviously sufficient to cause

voters to either change their votes or to not cast their vote at all given the consequences to

their employment, their children's standing and grades in their classes, and the general
knowledge that school district employees would know how they voted on this 180 million

dollar bond issue to rebuild the Albany High School.

34.

A fuither example of this violation of the voting rights and privacy rights of

the voters in this election resulted when the absentee and affidavit ballots were counted at
the polling places by the inspectors of election before the close of the polls, that is, before
9 p.m. when the polls closed.

35.

Although the Election Law requires the use of locked boxes for the storage

of voted paper ballots, there is no recollection by any of the voters who discussed their
experience on election day at the various polling sites in the City of Albany of any locked
boxes in which their voted papers ballots were to be secured after the voters had marked

their ballots. (See Election Law, section 4-132, subd. b; and section 8-104, subdivisions 2

&4)

36.

By counting the absentee ballots before the polls closed the inspectors were

also precluded frorn complying rvith the requirements of Election Law section 9- 106

which required that there be an inventory of all of the ballots that were used in the course

of the voting during the election.

37

In addition, by counting the votes during the course of the voting day and

before the close of the polls, upon information and belief, inspectors were observed
opening the absentee ballots envelopes individually, that is one by one, and removing the
paper ballot from the envelope and immediately tallying that voter's ballot, obviously

knowing and recording how each absentee voter had voted when they cast their ballot.
This voting process was observed at the Eagle Point School polling place and remarked to
have occulred at other polling places. (See generally Election Law, sections 9- 108 and 9-

l 10).

POLLING PLACES WERE ILLEGALLY CROWDED

38.

The Election Law at section4-104, subd. 6 sets forth a general statement that

that each polling place " shall be of sufficient area to admit and comfortably
accommodate voters in numbers consistent with the deployment of voting systems and

privacy booths, pursuant to 9 NYCRR 6210.19. Such deployment of voting systems,

election workers and election resources shall be in a sufficient number to accommodate
the numbers of voters eligible to vote in such polling place."

39.

The largest number of voters that seem to be allowed in any polling place by

the Election Law where election districts are combined is 2,000 voters in the City of New

York for a primary election or special election (Election Law, section 4-104, subd. 5 ( c );
see also generally at section 4-100, subd. 3 (a) where the maximum number of voters

allowed in an election district is

l,l

50 and only rvith the permission of the board

of

elections). The Election Law at section4-104, subd.5 (a) provides that in combining
election districts into a polling place for an election, that no such combination is to
exceed 500 voters.

40.

tn this February 9, election, the poll site at the Mater Christi school

contained over 6,378 voters and was set up with only one voting machine and two tables

of inspectors with the list of voters divided alphabetically.

4l

The voters in the

14'h

ward and the

8'h

ward in the November general election

at which the previous bond issue was put to a vote and by a narow margin defeated, were

in the election districts that provided the largest margins of votes cast to defeat the
previous vote on the bond issue. (See Exhibit C above)

42.

The voters in Wards 14 and part of ward 8, were thus knowingly combined

to vote at Mater Christi school with a total of 6,378 eligible voters assigned to that one

location. Exhibit C above shows that the l4'h ward and the 8th ward

are by far the two

largest wards in the City of Albany with the number of voters in these two wards being

nearly twice as large as any other wards in the

City.

The deliberate malice of the Albany

School District in planning this election is that instead of dividing and then combining
parts of these two largest wards in the City into an additional polling place, they
combined half of the voters in the 8'r' ward and put those voters into the Mater Christi

polling place which already had the second greatest number of voters in any ward and
polling place in the entire city of Albany.

13. Upon information and belief,, the polling site at Mater Christi ran out of

official ballots at mid-day and there was obviously mass confusion and chaos as this
polling site had neither the personnel nor the equipment to timely process the excessive
and unauthorized number of voters whose only place to vote was at that polling location.

44.

At approximately seven p.m. on election day, the room was filled with well

over 100 voters waiting in lines that circled the meeting room of gymnasium size while
dozens more voters were waiting in the hallway and in the entrance portico not even able

to get into the room. A series of three photographs were taken at that time scanning the
room which are attached hereto as Exhibit

D.

Obviously it took at least an hour for the

voting process to proceed so slowly that these lines developed and it then took another
hour at least for these lines of delayed voters to work their way through the voting and
registration lines to complete the voting process.

45. Upon information and belief, at this one polling place dozens of voters came
into the building took one look at the lines and delays and immediately turned around and

left the voting

filled

site.

The parking of vehicles for the Mater Christi voting site was already

as the church parking lots had no spaces

left and voters'parked cars spread for

several blocks in each direction from the polling site, with the obvious impediment to

elderly and sick voters.

46.

The Rules and Regulations adopted to implement the use of digital voting

equiprnent or scanning devices of paper ballots at elections in Nerv York State require
that "County boards shall deploy sufficient voting equipment, election workers and other
resources so that voter waiting tirne at a poll site does not exceed 30 rninutes. Each

county board of elections may increase in a non-discriminatory manner, the number of

voting devices used in any specific polling place." (See 9 NYCRR section6210.l9 ( c )).
These voting rules were put in place as legally binding on the conduct of all elections in

New York State when the newly approved digital and electronic scanning voting devices
were approved by the New York State Board of Elections and to prevent their use in such
an inadequate number as to result in the kind of delay that occurred at Mater Christi

school on February 9.
47

The results of this election conducted by the Albany School District are so

tainted by the designed voting flaws at the Mater Christi school location as to void the

integrity of the final vote and require that a new vote under the supervision of the Albany
County Board of Elections be conducted to assure compliance with the basic
requirements of the Education Law and the Election Law.

OTHER MISCELLANEOUS VIOLATIONS

48.

Although the hours of the election on February 9, required to polling places

to be opened at 7 a.m., at several locations when voters showed up at the polling places at
that hour on their way to work, the polling sites were not open and in several instances
there was no adequate signage or directions where the voters were to proceed or where to
enter the building.

49. The rninimum

number of inspectors that were employed by the School

District to conduct the elections at each of the polling places were in large number not
trained or certified, or better, experienced in running polling places and elections an4

upon information and belief, there is no record that at least l4 of the 54 inspectors
completed any training by the Albany County Board of Elections for inspectors.

50.

There was no proper inventory made and maintained by the inspectors at

each of the polling places of the registration sign in sheets and paper ballots, whether

official or emergency, and a reconciliation of such materials

conducted by the Albany school district

as

officials. This failure

in the form of a recanvass

was demonstrated when

the margin of the votes cast in favor of the bond issue was changed and reduced by the

Albany School District after Beverly Padgett, one of the inspectors at the Arbor Hill
Library polling place, noticed in the Times Union article that published the voting results
from each polling place in the school board election, that the published numbers for her
district did not match her recollection of the numbers that she certified
5l

as an inspector.

Polling inspector Padgett notified the school district officials of this

discrepancy from her recollection and the published numbers, and in response the school
board officials changed the resulting margin from its initial determination that the
approval margin was by 228 votes to its final margin number of 189 votes.

52.

The Padgett vote margin change is shocking for two reasons. First, that

Beverly Padgett checked the published numbers issued by the Albany School District for
her polling place and found that frorn her memory the published numbers were

inaccurate. And secondly, that the School District, with no more than the recollection of
a polling inspector, was willing to change the official certification of approval of a 180

rnillion dollar bond issue vote, by the 39 vote difference that an inspector discerned in

newspaper

article.

Without an official supervised recount of the voting results from the

records maintained and in the sole possession of the Albany City School District, the

voting results as published are highly questionable and unreliable.

53.

In every election in New York State conducted by a county board of

elections, there is a statutorily mandated recount or recanvass of all of the ballots cast in
every election. (Election Law, section 9-208). There is no reason in the instant case

with the irregularities already made public, that the Commissioner of Education should
not order a recanvass of the ballots and review of the voting materials utilized in the
disputed February 9, Albany School District budget election.

54.

In the event that the Albany City School District seeks to rely upon

Education Law section 2608, subd.S that the results of this election shall not be declared

invalid or illegal "because of the use of ballots which do not conform to the requirements
of this section or of the provisions of the election law, provided the intent of the voter
may be ascertained from the use of such irregular or defective ballots", petitioners

respectfully assert that this section only applies to the election of school board candidates
and not to budget votes and further that the application of this subdivision only is applied

when the use of such ballots "was not fraudulent and did not substantially affect the result

of the election" (section 2608, subd.

5).

Your petitioners as shown herein respectfully

urge that the planned use of the official and emergency ballots by the Albany School

District was indeed fraudulent and did affect the outcome of the election as described
herein.

55.

For the reasons set forth above, your petitioners request that the

Commissioner grant a stay of the implementation of the results of the Albany School

District certified approval of the vote in favor of approval of the 180 million dollar bond
issue for the building of a new Albany high
stay

school. The failure of such issuance of a

will allow the school district to proceed with financial commitments

expenditures to include approval of bonds for this project which

and

will make any future

determination by the Commissioner on this appeal a nullity and leave the petitioners

without any routine administrative remedy contemplated by the Education Law.

56.

Given the far reaching allegations set forth herein, your petitioners further

request that the Commissioner order, that pending any further determination of the issues
raised herein, that the Albany County Board of Elections be directed to conduct a
recanvass of the ballots and voting materials utilized in the February 9, school district

election and report to the Commissioner on the conduct of the election and the regularity
and reliability of the results of such election with the authority to propose and

recommend such further or different findings as may be appropriate under the Education

Law and the Election Law. Your petitioners request that such recanvass by the county
board of elections be conducted in public and in accordance with their usual procedures.

51

Attached heretcl are af'l'iclavits crccutccl try rnost of the Pctitioners

herein which highlight on a personal trasis their cxperience as they attempted to

vttte rln February 9, ut the school clistrict budget elcction. Thc af'l'iclavits merely

highlight the difficulty or dit'ficultics that each encountercd as they each went to a

polling place to vote and any general observations and cttnclusions they reached
with regard to the conduct of the election. (Affidavits are attached hereto

as

Exhibit E)

58.

Atso attached hereto are contemporaneous online postings by local

meclia reporters from various television staticlns as may be inclicittecl clr the local

Times Union newspilper. Thesc mediar postings document the allegations in the
petiticln on appeal as to the irregularitics in the conduct of the electittn in either the
photctgraphs that are offered or tlte accornpanying dcscription

reporters

observed. In some

tlf the evcnts that the

cases as well, the comments of voters are included

and/or postings ['ry voters clr citizens who are describing their experience as they
atternpted to

59.

vote.

(Media reports arc attached hereto as Exhibit F)

Within an hour of the close of the polls on February 9, the President of

thc i\lbarry Schotll Board, Kcrrny Brucc was clurlted by Mary Wilscln. it reportcr ott
Ncrws Channel

I0 as saVing thut: "It's rlisuppointing lhat we btttched this

clectir-ul". Hirrlier in the clav tln lrcbruirry q, I\'lr. I]ruce ttlld Tirrrcs [Jnitln rcpttrter
LJe

thany llurnp at-rout running tlut ol'tlrllots th:tt: "Wc tlidn'I hltvc proccsscs ltnd

proceclures in place around running out" (,lf

ballttts). In addititlrt

WN YT

television sration printecl clut u statenrent from the Albany City School District

well as a comment by the Mayor ()f the City o[ Albany ancl Assemblywoman

as

Pnt

Fahy whg called fur an "indepenclent investigaticln" of the February 9, clection.

(Each of these public stzrtements by the President of the Albany School Board and
the school board statement is attttched hereto as Exhitrit G).

Respect lull y sub mi ttecl.,

gJaf avt,r"

q'{,'F%
{d^E. Sweetrey, Esq.

Attorney for Petitioners

Office and P.O. Address
79 Columbia Street
Albany, New York 12210
Tel: (518) 281-2994

VERIFICATION
STATE OF NEW YORK)
ss.:

COUNTY OF ALBANY)
I the undersigned, being one of the Petitioners in this proceeding make the
following statement as true under the penalties of perjury:
That I have read the foregoing Verified Petition and know the contents thereof and
the same are true to my knowledge except as to matters stated therein to be alleged upon
information and belief and as to those matters I believe them to be true. The basis of such
belief is my conversations with other voters and election officials and my observations on
February 9,2016 at my polling place and other polling places that I visited or saw.

Dated: February

Zl ,2016

/,Jr./,1/r (" r7-

Sworn to before me this

day of February,2016

vi th
LI HONGYUAN
^IOTARY PUBLIC.STATE oF NEW YoRK

No. 0l

11632 7847

Quolified in Atbony County

Notary Public

Comrnrssion Expires July 20, 2019