BEFORE THE DULY CONSTITUTED ELECTORAL BOARD FOR THE HEARING

AND PASSING UPON OF OBJECTIONS TO THE PETITION PAPERS FOR

CANDIDATES OF NEW POLITICAL PARTIES IN THE STATE OF ILLINOIS

SHARON ANN MERONI, )

)
Petitioner-Objector, )
)
vs. )
)
MICHAEL L. WHITE as a Candidate for ) No. 10 SOEB GE
Governor, )
)
Respondent-Candidate.

MOTION TO STRIKE AND DISMISS

NOW COMES the Respondent-Candidate MICHAEL L. WHITE as a Candidate for

Governor, by his Attorney, DOUG E. IBENDAHL, and pursuant to the Illinois Election Code,

moves to dismiss this action, and in support thereof, states as follows:

1. On June 21, 2010, Respondent-Candidate MICHAEL L. WHITE (“Candidate”)

filed new political party petition papers in association with the CONSTITUTION PARTY as a

candidate for the office of Governor (“Nomination Papers”).

2. On June 28, 2010, SHARON ANN MERONI (“Objector”) filed a Verified

Objector’s Petition (“Objection”) to the Nomination Papers of the Candidate alleging that such

Nomination Papers “are insufficient because they fail to demonstrate and/or provide

documentation that the candidate meets the constitutional requirements for office.”

3. Objector provides absolutely no evidence to support the allegation set forth in the

Objection, and further the Objection fails to state a legal cause of action.

4. The Objection is inconsistent and at variance with both the intent and spirit of the

Illinois Election Code.

WHEREFORE, for all the reasons set forth above, the Candidate moves that the

Objector’s Objection be dismissed and stricken in its entirety.

Respectfully submitted,

/s/ Doug E. Ibendahl

___________________________________________
DOUG E. IBENDAHL, Attorney for Respondent-Candidate
DOUG E. IBENDAHL
165 N. Canal Street
Suite 1215
Chicago, IL 60606
(312) 648-0061
 CERTIFICATE OF SERVICE

I certify that a copy of the foregoing was served upon the following this 6th day of July,
2010:

Sharon Ann Meroni

Petitioner-Objector
One Surrey Lane
Barrington Hills, IL 60010

Office of the General Counsel

of the Board of Election Commissioners
Room 200
33 N. LaSalle Street
Chicago, IL 60602

/s/ Doug E. Ibendahl

_______________________________________________
DOUG E. IBENDAHL, Attorney for Respondent-Candidate