!

aaassseee 111:::111222---cccvvv---000000222444111---MMMAAADDD---AAATTTBBB DDDooocccuuummmeeennnttt 111 FFFiiillleeeddd 000222///000888///111222 PPPaaagggeee 111 ooofff 111111

UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF NEW YORK

---------------------------------------------------------------){
ALBERT ED MUES, Plaintiff,

ECF CASE COMPLAINT

-againstTHE TOWN OF DENNING, NEW YORK, ROBERT BRUNING, Town Supervisor, Town of Denning, NEW YORK, ANDREW DEAN. PAUL SCHOONMAKER, KEVIN SMITH and DAVID BROOKS, Councilmen of the Town of Denning, New York, Defendants.

DEMANDS TRIAL BY JURY

Case no. 1:12-CV-0241(MAD/ATB)

---------------------------------------------------------------){
Plaintiff, Albert Ed Mues, by his attorneys. Drew, Davidoff & Edwards Law Offices, LLP and Robert N. Isseks, Esq., complainiiig of the defendants, alleges as follows:

THE PARTIES
1. At all times hereinafter mentioned plainti ff was and remains a resident of the County of Ulster. State of New York. 2. Defendant Town of Denning, New York (the "Town of Denning" or "Town") is a municipality located within the County of Ulster, New York, with principal offices located at 1567 Denning Road. P.O. Box 277, Claryville, New York 12725. 3. Upon information and belief, defendant Robert Bruning ("Bruning") is an individual residing in the County of Ulster, State of New York. At all times hereinafter mentioned, Bruning was, and continues to be, a registered Republican and the Town Supervisor of the Town of Denning. Bruning is being sued in his individual and official

!aaassseee 111:::111222---cccvvv---000000222444111---MMMAAADDD---AAATTTBBB DDDooocccuuummmeeennnttt 111 FFFiiillleeeddd 000222///000888///111222 PPPaaagggeee 222 ooofff 111111

capacities. 4. Upon infonnation and belief, defendant Andrew Dean ("Dean") is an individual residing in the County of Ulster, State of New York. At all times hereinafter mentioned, Dean was, and continues to be, a registered Republican and a Councilman of the Town of Denning. Dean is being sued in his individual and official capacities. 5. Upon infonnation and belief, defendant Paul Schoonmaker ("Schoonmaker") is an individual residing in the County of Ulster, State of New York. At all times hereinafter mentioned, Schoonmaker was, and continues to be, a registered Republican and a Councilman of the Town of Denning. Schoonmaker is being sued in his individual and official capacities. 6. Upon infonnation and belief, defendant Kevin Smith ("Smith") is an individual residing in the County of Ulster, State of New York. At all times hereinafter mentioned, Smith was, and continues to be, a registered Republican and a Councilman of the Town of Denning. Smith is being sued in his individual and official capacities. 7. Upon infonnation and belief, defendant David Brooks ("Brooks") is an individual residing in the County of Ulster, State of New York. At all times hereinafter mentioned, Brooks was, and continues to be, a registered Republican and a Councilman of the Town of Denning. Brooks is being sued in his individual and official capacities.

NATURE OF ACTION AND JURISDICTION

8. This is a 42 U.S.C. 1983 action seeking compensatory and punitive damages and declaratory and injunctive relief against the above named defendants for committing

!aaassseee 111:::111222---cccvvv---000000222444111---MMMAAADDD---AAATTTBBB DDDooocccuuummmeeennnttt 111 FFFiiillleeeddd 000222///000888///111222 PPPaaagggeee 333 ooofff 111111

acts under color of law which deprived plaintiff of rights secured under the First Amendment to the United States Constitution. 9. Jurisdiction is conferred on this Court by 28 USC l331 and l343. 10. Each and all of the acts of defendants Bruning, Dean, Schoonmaker, Smith and Brooks alleged herein were done by them under the color and pretense of the statutes, ordinances, regulations, customs and usages of the State of New York and under the authority of their offices with the Town of Denning.

STATEMENT OF CLAIMS
11. At all times relevant, and from November, 2003 until January 4,2012, plaintiffwas employed by the Town of Denning as the Solid Waste Attendant, or Town of Denning Recycling Manager, at the Town's Transfer Station and Recycling Center (the "Center"), a position for which plaintiff was hired rather than appointed. A copy of the job description of the Town's Solid Waste Attendant, as revised September 17,2010, is attached as Exhibit A. 12. Throughout plaintiffs employment as the Town's the Solid Waste Attendant he continuously and consistently fulfilled his duties, met his responsibilities and performed his functions in a professional and competent manner. 13. On August 25,2011, in anticipation of the then upcoming local elections, plaintiff, a registered Democrat, sent an email (Exhibit B) to about 32 recipients, copied to Bruning, regarding the subject, "the upcoming caucus" which read, verbatim: Fellow Democrats and perhaps a few not,

!aaassseee 111:::111222---cccvvv---000000222444111---MMMAAADDD---AAATTTBBB DDDooocccuuummmeeennnttt 111 FFFiiillleeeddd 000222///000888///111222 PPPaaagggeee 444 ooofff 111111

The election for Town Supervisor is rapidly approaching (Nov. 8,2011).

It appears that the Democratic Party in the Town of Denning has no candidate for

Town Supervisor. There must be someone who can run for the position for the simple reason that if the current supervisor, Bill Bruning, runs unopposed, then the Town of Denning appears to all to be deeply flawed. No matter what the office, no one should run unopposed. It is un-American and unhealthy for the collective psyche of our town. It doesn't matter that Bill gets elected. He is a very good fiscal manager, and over all, a good Town Supervisor. If someone runs against him, then and only then, will we have autonomy . You don't have to want to be town supervisor to run. Just to be part of a fair playing field. Please consider throwing your hat in the ring. See the announcement attached, FYI. Pass it on to other Dems you know. peace and light, ed mues Attached to this August 25, 2011 email were copies of announcements (included in Exhibit B) that had been published in the local press alerting the public to the upcoming Town of Denning Democratic Caucus and calling for all prospective candidates seeking the nomination of the local Democratic Party to contact the Party Chairman. 14. Plaintiffs writing and transmittal of his August 25,2011 email, together with the transmittal of the email's attachments constituted political speech protected by the First Amendment. 15. On Wednesday, August 31,2011, plaintiffs first workday of that week, at around 7 :30 a.m., Bruning approached plaintiff at the Center and asked, "Ed, what the hell do you think you're doing?" Plaintiff responded by asking, "What?" and Bruning answered, "You know damn well what. That [expletive] email you sent out. You can't do

!aaassseee 111:::111222---cccvvv---000000222444111---MMMAAADDD---AAATTTBBB DDDooocccuuummmeeennnttt 111 FFFiiillleeeddd 000222///000888///111222 PPPaaagggeee 555 ooofff 111111

that. You work for me!" Plaintiff then said, "No I don't. I work for the Town of Denning... Bill, what the hell's the problem. I'm just trying to promote democracy. I didn't diss you. I even paid you a compliment." Bruning's response was simply, "You don't do that. Now I may have to spend money. Ed, I'm warning you stay out of this. If you want to play politics, you'll be sorry. I guarantee it." 16. On September 12,2011, members of the local Democratic Party held its caucus during which plaintiff moved for the nomination of three candidates to run in opposition to the Republican incumbent Town Councilmen Schoonmaker and Dean in the upcoming election. Bruning was in attendance and witnessed plaintiffs making said motion. 17. Plaintiffs' participation in the September 12,2011 Democratic Party Caucus and his motion to nominate candidates to fill two seats on the Town Board constituted political speech and association protected by the First Amendment. 18. On October 22, 2011, members of the local Democratic Party met to discuss issues and ideas to be utilized by the Party in its campaign against the local Republican incumbents. Out of that discussion, in which plaintiff was a known participant, three political mailings (Exhibit C) were drafted and distributed and thereafter received and/or discussed by the public, including the defendants. 19. Plaintiffs' participation in the meeting and discussions held on October 22, 2011 and the consequent drafting and dissemination of the three mailings constituted political speech and association protected by the First Amendment.

!aaassseee 111:::111222---cccvvv---000000222444111---MMMAAADDD---AAATTTBBB DDDooocccuuummmeeennnttt 111 FFFiiillleeeddd 000222///000888///111222 PPPaaagggeee 666 ooofff 111111

20. On November 8, 2011, the elections were held and the Republican incumbents Schoonmaker and Dean were re-elected. 21. Shortly after the elections, Bruning informed plaintiff that he, plaintiff, was going to "pay" for what he did and that plaintiff had "brought it on himself." 22. On November 9,2011, in a closed session of a Town Business Meeting, the Town Board heard and passed Resolution No. 43 of2011 which reads: WHEREAS Town Law 20(1)(a) and (b) authorize the Town Board to appoint employees it deems necessary for the proper conduct of the affairs of the Town, And WHEREAS the position of Town Recycling Manager is deemed necessary for the proper conduct of the affairs of the Town, And WHEREAS the Town Recycling Manager is the only Town position that is not appointed, And WHEREAS the Town Board desires to make Town Recycling Manager an appointed position, the Town of Denning Town Board HEREBY defines the position of Town of Denning Recycling Manager as a appointed position. This position will be appointed each year at the Town of Denning organizational Meeting held at the first meeting of each year. The motion to adopt and approve Resolution No. 43 was carried unanimously by vote of Dean, Schoonmaker, Smith, Brooks and Bruning. 23. On January 3, 2012, in a closed "organizational meeting II held just before the regular Town Board meeting, the Town Board heard a motion to vote on Resolution No. 18 of2012 which provided: WHEREAS Town Law 20(1)(a) and (b) authorizes the Town Board to appoint employees it deems necessary for the proper conduct of the affairs of the Town,

!aaassseee 111:::111222---cccvvv---000000222444111---MMMAAADDD---AAATTTBBB DDDooocccuuummmeeennnttt 111 FFFiiillleeeddd 000222///000888///111222 PPPaaagggeee 777 ooofff 111111

NOW THEREFORE BE IT RESOLVED to appoint Ed Mues who resides at 434 Greenville Road, Sundown, N.Y. 12740 to the position of Town of Denning Recycling Manager, at a salary of $13.49 per hour to be drawn from Refuse and Garbage Personal Services. (General Fund Appropriations Code A8160.1) Upon a request made by Bruning, the Town Board, consisting of Dean, Schoonmaker, Smith and Brooks, voted to table Resolution No. 18. 24. Later during the same January 3, 2012 meeting, Bruning opened a discussion on tabled Resolution No. 18 of 20 12 and discussion followed regarding the appointed position. Bruning explained his reasoning and informed the Town Board that he had another candidate to submit for the Board's approval. Brooks inquired if the Town should advertize for the position and Bruning responded that he did not wish to leave the site unattended for a month. Bruning also commented that he had explained the time requirements to the candidate. 25. Thereafter and still during the January 3, 2012 closed "organizational meeting", the Town heard and passed Resolution No. 23 of2012 which provided: WHEREAS Town Law 20(1)(a) and (b) authorizes the Town Board to appoint employees it deems necessary for the proper conduct of the affairs of the Town, NOW THEREFORE BE IT RESOLVED to appoint Scott Mickelson who resides at 455 Yeagerville Road, Sundown, N.Y. 12740 to the position of Town of Denning Recycling Manager, at an salary of $13.49 per hour to be drawn from Refuse and Garbage Personal Services. (General Fund Appropriations Code A8160.1) The motion to adopt and approve Resolution No. 23 was carried unanimously by vote of Dean, Schoonmaker, Smith, Brooks and Bruning. 26. On January 4,2012, Bruning told plaintiff that his job as Solid Waste

!aaassseee 111:::111222---cccvvv---000000222444111---MMMAAADDD---AAATTTBBB DDDooocccuuummmeeennnttt 111 FFFiiillleeeddd 000222///000888///111222 PPPaaagggeee 888 ooofff 111111

Attendant was ended and said "Clean out your stuff and give me the keys. It's political, Ed. You brought it on yourself." Plaintiff said, "That's discrimination", and Bruning replied "It's political." 27. The defendants' aforesaid conduct in changing the position of the Town of Denning Recycling Manager from a hired position to an appointed position and then effectively terminating plaintiffs employment by appointing someone in plaintiffs place was arbitrary, capricious and unsupported by any rational or legitimate governmental purpose or interest. 28. The defendants' conduct in effectively terminating plaintiffs employment was carried out with malice and in retaliation for, and in violation of, plaintiffs exercise of his First Amendment rights to free political speech and association. 29. The decision to terminate plaintiffs employment was made by the defendants as the Town's final policymakers. Accordingly, the defendant Town of Denning is liable for such conduct. 30. As a result of the defendants' conduct, plaintiff has suffered anguish, public humiliation, and economic loss. 31. The defendants' conduct as set forth above has had, and continues to have, an objective chilling effect upon the exercise of First Amendment protected political speech and association. 32. By reason of the foregoing, plaintiff is entitled to awards of compensatory damages against the defendants.

!aaassseee 111:::111222---cccvvv---000000222444111---MMMAAADDD---AAATTTBBB DDDooocccuuummmeeennnttt 111 FFFiiillleeeddd 000222///000888///111222 PPPaaagggeee 999 ooofff 111111

33. By reason of the individual defendants' acting with malice and retaliatory motive; plaintiff is entitled to an award of punitive damages against those defendants. 34. Plaintiff lacks an adequate remedy at law and equity requires that he be reinstated to his previous position in the Transfer Station and Recycling Center for the Town of Denning. WHEREFORE, Plaintiff asks this Court to: A. Issue an order adjudging and declaring that the defendants' conduct was in violation of plaintiffs rights guaranteed by the First Amendment to the United States Constitution; B. Issue an Order directing the defendants to reinstate plaintiff to his previous position in the Transfer Station and Recycling Center for the Town of Denning; C. Award plaintiff compensatory damages against the defendants in amounts to be determined by the Court; D. Award plaintiff punitive damages against the individual defendants in amounts to be determined by the Court; E. Award plaintiff the costs and disbursements of this action; F. Award plaintiff reasonable attorney fees; and G. Grant plaintiff such further and other relief as to this Court may seem just and proper.

!aaassseee 111:::111222---cccvvv---000000222444111---MMMAAADDD---AAATTTBBB DDDooocccuuummmeeennnttt 111 FFFiiillleeeddd 000222///000888///111222 PPPaaagggeee 111000 ooofff 111111

Dated: FebruaryB.-, 20 12

MICH DAY I OFF (MD7501) DREW, DAYlDOFF & EDWARDS LA W OFF ICES, LLP 13 Liberty Street, P.O. Drawer 1040 Mont icello, New York 1270 I (845) 794-5000

ROBERT N. ISSEKS (Rl 0241) 6 North Street Midd letown, New York 10940 (845) 344-4322

!aaassseee 111:::111222---cccvvv---000000222444111---MMMAAADDD---AAATTTBBB DDDooocccuuummmeeennnttt 111 FFFiiillleeeddd 000222///000888///111222 PPPaaagggeee 111111 ooofff 111111

UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF NEW YORK ALBERT ED MUES,

---------------------------------------------------------------){
Plaintiff, -againstVERIFICATION

THE TOWN OF DENNING, NEW YORK, ROBERT (BILL) BRUNING, Town Supervisor, Town of Denning, NEW YORK, ANDREW DEAN, PAUL SCHOONMAKER, KEVIN SMITH and DAVID BROOKS, Councilmen of the Town of Denning, New York, Defendants,

---------------------------------------------------------------){
ALBERT ED MUES, being duly sworn, deposes and says: That he is the plaintiff herein; that he has read the foregoing Complaint and knows the content thereof; that same is true upon his pers<?nal knowledge or upon information and belief,

AL
?rt1

RTEDMUES

-J -

Sworn to before me this day ofFeburary, 2012

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-)...--,

Notary Public

PAMElA A. SMITH Notary Public, State Of New York Sullivan County Clerk's #2096 Commission Expires Oct. 30, 20

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CIVIL COVER SHEET

The tll',l cover shee t and the info rm:mon cont:llned here in Reither replace norsupplerr.:nllhe fihng3lld serviceofple:ld mgsnro thcr papcrsas rcquir",d by [a ...... except as prol" o:kd by local rulcs of court Th is form. appro,'ed by the Judicial Conference or the United 51 ale5 In September 1974, is required for Ihe usc of the Clerk orcoul1 for the purpore ofmltllhng
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Albert Ed Mues
( b ) Coumy of ReSIdence of FirS! Lisled Plainuff

Town of Denning, NY, Robert Bruning, Andrew Dean, Paul Schoonmkaker, Kevin Smith, David Brooks

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_ _ ___ D'AgostinoMAG JUDGE ___Baxter 1:12-CV-0241 COMPLEX

JUOGE _ _ _ _ _ _ __

_ _ _ _

!aaassseee 111:::111222---cccvvv---000000222444111---MMMAAADDD---AAATTTBBB DDDooocccuuummmeeennnttt 111---222 FFFiiillleeeddd 000222///000888///111222 PPPaaagggeee 111 ooofff 111 EXHIBIT A

SOLID WASTE ATTENDANT

DISTINGUISHING FEATURES OF THE CLASS: The work responsibility fCor pcrforminq routine tasks in a recycling center and/or solid waste transfer station. The work is carried out in accordance with established procedures and involves directing users of the facility to appropriate areas for solid waste transfer and recyclables, and keeping the. site as orderly as possible. Work is performed under general supervision according to a prescribed routine. Supervision of others is not usually a function of this position. Does related work as required.
TYPICAL WORK ACTIVI'.rIES:

The typical work activities listed below, while prOViding representative examples of the variety of work assignments in the title do not describe any individual position. Incumbents in this title may perform some or all of the
following, as well as othpr related activilies not described.

Opens and closes recycling center and/or solid waste transfer station for use by public; Ensures that individuals have authorization to use recycle and solid waste transfer
areas;

Keeps unauthorized persons from recycle and solid waste transfer areas: Collects tickets and/or fees as required; Directs users to proper recycle and solid waste transfer areas; Informs users of proper procedures for recycling and transferring solid waste: insures that users are complying with the established procedures used for recycllng and transferring solid waste; May participate in a recycling and transfer of solid waste programs; May function as a Scale House operator in a facility: May operate automotive and other motorized equipment in the performance of work assignments; May keep record of disposal area use: FULL PERFORMANCE KNOWLEDGES, SKILLS, ABILITIES AND PERSONAL CHARACTERISTICS: Ability to acquire knowledge of the laws and requirements for the disposal of solid waste and recyclable material: ability and willingness to perform simple manual tasks without direct supervision: willingness to work under adverse weather conditions; ability to secure the cooperation of others; firmness; tact: dependability; courtesy: physical condition cornml?nsuratr:- with the demands of the position. MINIMUM QUALIFICATIONS: None.

In an agency where driving vehicles andl or equipment on public roads is required, incumbents must possess New York State and Federai Drivers Licenses appropriate to the equipment being operated. Incumbents functioning as Scale House Operators must possess such certifications as may be required by the State Department of Agriculture and Markets.

ULSTER COUNTY 6885 SOL WS'l' AT

Adopted: June 1, 1993 Revised: September 17, 2010

!aaassseee 111:::111222---cccvvv---000000222444111---MMMAAADDD---AAATTTBBB DDDooocccuuummmeeennnttt 111---333 FFFiiillleeeddd 000222///000888///111222 PPPaaagggeee 111 ooofff 333 EXHIBIT B

Robert Isseks
From:
Sent: Ed Mues [gardend@mountainair.us] Tuesday, January 24,20124:42 PM Robert N. Isseks, Esq. Fwd: the upcoming caucus

To:
Subject:

Gentlemen: Here is the original email in question. Note it was sent August 25th, 2011. At the bottom are two ads placed in the local paper of record, the Tri-Valley Townsman, by the Chair of the Denning Democratic Committee, Frank Comando. Note also: the caucus date was later changed to Monday Sept. 19th, 2011.

From: Ed Mues <gardend@mountainair.us> Date: August 25, 2011 9:47:32 AM EDT To: Kathryn Tufano <kathryn@catskillartsocietv.org>, bob brief <rb950@aoLcom>, dave brooks <dwbrooks@lycos.com>, mary buchen <marybuchen@gmaiLcom>, dennis deyo <redhillservices@hotmaiLcom>, Patti Candelari <patticandelari@hotmaiLcom>, jack cox <jackcox@msn.com>, peter donnelo <klatu@gis.net>, patricia eakins <fabulara@earthlink.net>, steve ellis <steve@stevellis.com>, rudolph farm family <tchewiwi@pronetisp.net>, kate godici <katet5@hotmaiLcom>, troy hill <misterhill@earthlink.net>, Jim Hobbs <hobbsj@sunyulster.edu>, jerry huncosky <jhuncosky@frostvalley.org>, chris jardine <jardinechristopher@yahoo.com>, john kuhner <jbkuhner@gmail.com>, carllandon <writtendialogue@gmail.com>, LeeAnna Larison <Ieeannalarison@gmail.com>, jenny lee <ironmite@gmail.com>, Les Stone <Lesstonephoto@cs.com>, bruce lock <brucelock@hughes.net>, Peter Martin <petersmail@verizon.net>, rick pereira <cep2k4@gmail.com>, merrill piera <easysundown@gmail.com>, ron & naja <ronaI51@msn.com>, "William H. Schaap" <schaaplaw@aol.com>, alden thayer <alden@aldenscountrygardens.com>, Lynne Thermann <jswitzler@localnet.com>, Chaim Tolwin <chaimtolwin@gmaiLcom>, Eric Wood <romanymusic@earthlink.net>, naja zarzour <nzarzour@sprint.blackberry.net> Cc: Bill Bruning <rbruning@hvc.rr.com>, frank comando <denningdems@yahoo.com> Subject: the upcoming caucus
Fellow Democrats and perhaps a few not, The election for Town Supervisor is rapidly approaching (Nov. 8, 2011).

It appears that the

Party in the Town of Denning has no candidate for Town Supervisor.

There must be someone who can run for the position for the simple reason that if the current supervisor, Bill
1

!aaassseee 111:::111222---cccvvv---000000222444111---MMMAAADDD---AAATTTBBB DDDooocccuuummmeeennnttt 111---444 FFFiiillleeeddd 000222///000888///111222 PPPaaagggeee 111 ooofff 333 EXHIBIT C
,.

Where's our New Blood?

Our Supervisor and the members of the Town Board have been serving now for several decades. We need new ideas and new Why don't we have an electronics waste disposal at the Claryville dump? Why don't we have a dedicated dump truc.k in Sundown to deposit waste in separate sections of the truck bed so each it could deliver its cargo to the Claryville dump? Open the back of the Darth Vader Building so it could dump directly into the containers. And yes, the dump truck would have to be in a chain link cage to keep off the bears. It's thirty mile round trip from Sundown to Claryville. Not your problem? Well it sure is theirs, and they pay taxes like the rest of us. Why not have Town Board Meetings on Saturday so the weekend people who Jove this Town and pay Town taxes like the rest of us can participate? Why not eliminate health care benefits for all but full time workers and give the Supervisor a decent salary? As it is now only those in office two terms are eligible for health care - odd how the current administration fits that bill- eliminating any incentive for newcomers to run for office.

VOTE DEMOCRAT
VOTE

HLINICAN AND RIVERA

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High Speed Internet for All !!

For a couple of thousand bucks the Town could beam the cable signal in

Claryville up to Req Hill and disseminate it from there into two valleys, beam it from there to a small tower in Sundown which would disseminate it to our third valley.

Have the Republicans. lifted a finger to do this?

FAT CHANCEl!
More and more people are scraping by through working at home. For this they need high speed intern.et like the rest of the civilized world. We will appropriate the money to get this done! 1

VOTE DEMOCRAT
VOTE

HLINICAN & RIVERA

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Bruning, runs unopposed, then the Town of Denning appears to aU to be deeply flawed. No matter what the office, no one should run unopposed. It is un-American and unhealthy for the collective psyche of our town.
It doesn't matter that Bill gets elected. He is a very good fiscal manager, and over all, a good Town Supervisor. If someone runs against him, then and only then, will we have autonomy. You don't have to want to be town supervisor to run. Just to be part of a fair playing field. Please consider throwing your hat in the ring. See the announcement attached, FYI. Pass it on to other Dems you know.

peace and light, ed mues

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Frank Comando

POLITICAL SLANT
TOWN OF DENNING DEMOCRATIC COMMITTEE CAUCUS DATE SET - To all prospective political candidates who wish to run for an

THE TOWNSMAN LEGAL NOTICE: NOTICE IS HEREBY GIVEN, PURSUANT TO ARTICLE 6, SECTION 108 OF THE NEW YORK STATE ELECTION LAW, THAT A, DEMOCRATIC PARTY CAUCUS WILLBE HELD AT THE (PLACE) Sundown Church Hall IN THE TOWN OF penning. AT (TIME):um an COUNTY OF ULSTER, STATE OF NEW YORK ON THE jnJ:l. DAY OF TEMBER 2011. THIS CAUCUS IS CALLED FOR THE PURPOSE OF NOMINATED CANDIDATES TO FILL EXISTING VACANCIES FOR THE TOWN ELECTIONS TO BE HELD ON November 8. 2011

elected office in the 2011 November Election in the Town of Denning and in the Ulster County General Election, and are seeking nomination or endorsement by the Democratic Party, please contact Frank Comando, Democratic Committee Chainnan of the Town of Denning at 845.985.0501 or email denningdems@Yahoo.com or snail-mail to Frank: Comando, Democratic Committee Chair, 135 Peekamoose Road Sundown NY 12740. Please send your resume to be considered for Democratic Party nomination or endorsement at the Democratic Caucus on September 12, 2011, @7:00 pm Sundown Church Hall. AU resumes must be received by August 31, 2011 for consideration.

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Frank Comando, Chairman

POSTING DATE: August 25 2011