DUTCHESS COUNTY BOARD OF ELECTIONS

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IN THE MATTER OF THE APPLICATION OF

CANDIS SAINT ANGEL,

                                                PETITIONER                       

     -against-                                                                                                                                      AFFIDAVIT

VIRGINIA A. BUECHELE, GEORGE J. FINN JR,       

DUTCHESS COUNTY BOARD OF ELECTIONS,

COMMISSIONER DAVID GAMANCE, AND

COMMISSIONER FRANCES KNAPP,                                                         

                                        RESPONDENTS.

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RICHARD SAINT ANGEL, being duly sworn, deposes and says:

1. I reside at 72 Marple Road Ext, in the Town of Poughkeepsie.
2. At all times mentioned herein, I duly registered to vote with the Dutchess County Board of Elections as a member of the DEMOCRATIC PARTY.
3. At all times mentioned herein, I declared myself publicly as a candidate for the office of Town Supervisor of the Town of Poughkeepsie.
4. Privately, I received statements of support from a considerable number of members of the Town of Poughkeepsie Democratic Committee, all of whom indicated that they could not take on the Executive Committee.
5. Nevertheless, from time to time, I received emails, and forwards of emails, from members of the Town of Poughkeepsie Democratic Party Committee.
6. Among these emails, I received copies of emails sent by Frederick Bunnell, in connection with his holding Town of Poughkeepsie Democratic Party Committee Meetings.
7. I did not, and do not, disclose the identities of the many individuals who emailed him, as I reasonably fear that the members of the alleged Town of Poughkeepsie Executive Committee would retaliate against them.

8. I received an email forwarded to him from FREDERICK BUNNELL announcing a meeting to be held on or about June 2, 2005.

9. I felt interested in this meeting because the announcement indicated that, at the meeting, the Committee would endorse a candidate for the Town Supervisor.  I decided to go to the meeting, in order to make his pitch for the endorsement.

10. Although the notice stated the meeting would start at 7:00 p.m., when I arrived at 7:15 p.m. the meeting had not yet started.  Frederick Bunnell was present, as was Rick Keller-Coffey and A. William Cass.

11. When I entered the room where the meeting was to take place, Frederick Bunnell approached me, and told me I would have to leave.  A polite discussion ensued between Frederick Bunnell and myself, in which I made my arguments as to why the Committee should allow me to stay for the meeting.  We talked for approximately fifteen (15) minutes.

12. Each time I made a point during the discussion, Frederick Bunnell would leave my immediate presence to consult with Rick Keller-Coffey and A. William Cass who stood together in the corner of the room.  Rick Keller-Coffey held a stapled packet of papers, which was at least five pages long, and no longer than 10 pages.

13. After I made my first point and Frederick Bunnell returned from his consultation, FREDERICK BUNNELL explained that my presence was against “their By-Laws”.

14. After I made several points and Bunnell walked back and forth this way, Frederick Bunnell took the By-Laws from Rick Keller-Coffey and brought them over to where I stood.  He showed me specific language which he said applied that provided that only members of the Committee, or invited guests of members of the Committee, could attend.  At this point I could do little to change anyone’s mind, so I thanked Frederick Bunnell and told Frederick Bunnell he intended to leave.

15. As I walked out to my vehicle, Frederick Bunnell ran out of the meeting room to talk with me in the parking lot.  He said that “maybe they would not like this” but that he would me speak to the committee, if I would leave afterwards.

16. At about 7:35, Frederick Bunnell called the meeting to order, and he distributed an attendance sheet which I, and others present signed.  I could see every person at the meeting, and did not see anyone taking notes or minutes.

17. At that time, I counted the people in the meeting.  There was a table in front of the room where four people sat.  Those four people included Frederick Bunnell, Alice Bunnell, Walter Jablonski, and Theresa Brown. 
18. Walter Jablonski is not, or could not, be a member of the Town Committee, in that he resides the City of Poughkeepsie, in a different Assembly District.
19. In the “audience” section of the room, I counted 13 people, including George Finn and Virginia Buechelle, both of whom I know to be duly registered REPUBLICANS, and could not be members of the Town Committee.
20. I saw eighteen (18) people which, minus Walter Jablonski, Virginia Buechelle, George Finn, and myself, totals fourteen (14).
21. I did not recognize the remaining eleven (11) people at the meeting, so I do not know if some of them also might not have been committee members, but assuming, for the purposes of argument that they were, fourteen (14) did not meet the committee’s quorum requirement.
22. I think it quite possible that of the remaining eleven people, some of them were not committee members.  It seems reasonable to me to think that Diane Jablonski was among them, as I would not recognize her by sight, but know that she collected signatures for the candidates selected by Rick Keller-Coffey, in the Town of Poughkeepsie, and is the wife of Walter Jablonski, who was present at the meeting.
23. In any case, the attendance sign in sheet, with my signature on it, would clarify who appeared at the meeting.
24. After I spoke, I left the meeting as I promised to Frederick Bunnell.  I believe I spoke for about ten minutes, leaving the meeting at 7:45. 
25. Seeing Frederick Bunnell call the meeting to order, without anyone even questioning whether a quorum presented, and without anyone taking minutes, leads me to wonder if the same held true for the May 2, 2005 meeting.