STATEMENT TO COMPLAINT

to
Challenge to the Recall Petition
Filed Against Jack Evans

This Statement is filed to set forth other facts that are alleged to constitute a petition defect or
violation of the law.

A. Circulator Donovan Mahoney, 10006 Bald Hill Rd., Bowie, MD 20721

1. SHEETS 617-620: The handwriting for these signatures appears to be written in the
same hand. Many of the signers on these Sheets are know to the elected official. The
signatures for these persons are not their signatures. Also, the addresses are essentially
sequential, which is belied by experience and logic, i.e., that the circulator simply went
door to door and collected each signature in order. Sheet 617 is only 1301 15th Street
NW. An example of this sequential order is found in lines 7 to 11, where the signatures
run in order: apartments 514, 515, 516, 522, 526. The same is true for Sheets 618-620.
The signatures on Sheet 618 are all from the 1300 block of Rhode Island Ave. NW, where
the addresses essentially run sequentially; and the signatures on Sheets 619 and 620 are
from the 1400 block of Rhode Island Ave. NW, where the addresses essentially also run
sequentially.

2. The same is true for Sheets 561-563. On Sheet 561, all the signatures are from residents
in 1301 15th Street NW. On Sheet 562, all signatures are from 1417 N Street NW. On
Sheet 563, all signatures are from the 1400 block of N Street NW. Again, all signatures
appear to be in the same handwriting.

3. On Sheets 353, all signatures are from an apartment house at 1400 N Street NW. The
addresses are listed in a manner where the street number is followed by the apartment
number, then the street name, e.g. 1401 707 N Street, NW. No one writes their address
like this (if for no other reason, the Post office will not deliver it). However, the District
of Columbia voter rolls do list addresses in apartment buildings in this manner. It appears
that the circulator simply ran down the voter rolls for this building and blindly copied the
addresses as listed, and then signed them all.

4. Under these fact patterns, it appears all these signatures are forged. It is respectfully
submitted that all the sheets should be struck as inherently corrupted. It is also submitted
 that any other petitions circulated by the aforementioned Donovan Mahoney should be
struck for the same reasons.

B. Circulator Mia Lovink, 1240 27th Street NW, Washington DC 20007

1. On Sheets 116 and 118, all the names and signatures appear to be written in the same
hand. Also, every third signature is in the same different-colored pen. It defies belief
that every third voter who signed showed up with the same different-colored pen.

2. Under these facts, it appears all these signatures are forged. It is respectfully submitted
that all the sheets should be struck as corrupted. It is also submitted that any other
petition circulated by the aforementioned Mia Lovink should also be struck for the same
reasons.

C. Circulator Peg Shaw, 2147 O Street NW, Washington DC 20037

1. On Sheet 520, all the signatures appear to be written in the same hand.

2. Under these facts, it appears all these signatures are forged. It is respectfully submitted
that all the sheets should be struck as inherently corrupted. It is also submitted that any
other petition circulated by the aforementioned Peg Shaw should also be struck for the
same reasons.

D. Circulator Matthew Carey, No Address Listed

1. On Sheet 34, the circulator lists the apartment addresses in the manner as set forth in the
District of Columbia voter rolls, e.g. 1715 – 308 P Street NW, etc. See section A.3.
above.

2. Under these facts, it appears all these signatures are forged. It is respectfully submitted
that this sheet should be struck as inherently corrupted. It is also submitted that any other
petition circulated by the aforementioned Matthew Carey should also be struck for the
same reasons.

E. Circulator Chris Otten, No Address Listed

1. On Sheet 43, all the signatures appear to be in the same hand.

 2. Under these facts, it appears all these signatures are forged. It is respectfully submitted
that this sheet should be struck as inherently corrupted. It is also submitted that any other
petition circulated by the aforementioned Matthew Carey should also be struck for the
same reasons.

F. Increased Pattern of Defective Entries

1. The percentage of defective signatures increased as the sheet numbers went up, as shown
in the following listing of the number of defects by groups:

Group 001 – 485 defects identified

Group 100 – 242 defects identified (this group has numerous blank sheets)
Group 200 – 614 defects identified
Group 300 – 816 defects identified
Group 400 – 691 defects identified
Group 500 – 267 defects identified (this group has dozens of blank sheets)

2. It appears that this pattern may have been caused by the fact that time was running out
when these sheets were circulated, and the Sponsor of the Recall became more pressed to
obtain the requisite signatures.

G. Specific Forged Signatures

1. Some of the persons who purportedly signed the Petition for Recall are known personally
by the elected official. Based upon his personal relationships with these persons, he
found it exceedingly unlikely that they would sign. Many of these persons were
contacted and they confirmed that THEY HAD NOT SIGNED the Petition. In the short
time available, essentially Monday and Tuesday, November 25 and 26, Declarations were
able to be obtained from two persons, Doll Gordon, 1316 Rhode Island Ave., NW, - Sheet
618, Line 14, and Joel Findlay, Sheet 619, Line 14. See attached. It is believed that
more Declarations would have been obtained, but many of the people were away for the
Thanksgiving holiday.

H. SUMMARY
1. Pursuant to the Board of Elections, 4949 valid signatures (10 percent of Ward 2
registered voters) are needed for the Recall Petition to pass. Petitioner filed 5609
signatures. This Complaint challenges approximately 2387 signatures (43.5 percent),
almost half of total number of signatures. All of the challenges are based on sound legal
grounds, and many are of clear cases of fraud and forged signatures.

2. Petitioner filed 628 sheets, 109 of which were blanks (17.4 percent), almost 1 in 5.

3. It is submitted that Petitioner(s) knew, at the time of filing, that the Petition for Recall
had numerous bad signatures. We had heard through social media that they knew at least
1500 were bad. It is thus submitted, that when Petitioner(s) filed this Petition for Recall
with the Board of Elections, they knew that they had insufficient signatures by a large
number and that they were filing a significant number of false signatures. In fact, we
were told directly by several sources that right after filing, Petitioner(s) were looking for
a lawyer to represent them in court because they expected that the Petition for Recall
would be thrown out "by Thursday." At the very least, this rises to the level of making
false representations to the Board of Elections in an effort to recall an elected official in
the District of Columbia.

4. Given the facts above, and the appearance of fraud, forgery and also misrepresentation, it
is respectfully submitted that this Petition for Recall be struck in its entirety as inherently
and irretrievably corrupted.