FILED

5/8/2018 5:05 PM
ERIN CARTWRIGHT WEINSTEIN
Clerk of the Circuit Court
Lake County, Illinois
EXHIBIT C
 IN THE CIRCUIT COURT OF THE NINETEENTH JUDICIAL CIRCUIT
LAKE COUNTY, ILLINOIS
CHANCERY DIVISION

GUNS SAVE LIFE, INC. and JOHN

WILLIAM WOMBACHER III,

Plaintiffs,

v. Case No. 18CH498

VILLAGE OF DEERFIELD, ILLINOIS, and

HARRIET ROSENTHAL, solely in her
official capacity as Mayor of the Village of
Deerfield,

Defendants.

AFFIDAVIT OF JOHN BOCH

I, John Boch, pursuant to 735 ILCS 5/2-1005, Ill Sup. Ct. R. 191, and 735 ILCS 5/1-109,

state as follows:

1. I make this declaration of my own personal knowledge and, if called as a witness,

I could and would testify to the truth of the matters set forth herein.

2. I am the Executive Director of Guns Safe Life, Inc. (“GSL”), and I have held this

position since 2015. I served as the president of GSL from 2010 to 2014 and as vice president for

over a dozen years prior to that. I am the editor emeritus of GunNews Magazine, the monthly

journal of GSL, which has a circulation of roughly 20,000+ copies. I am also a member of GSL.

GSL is a plaintiff in the above-captioned case.

3. GSL is an independent not-for-profit organization that is dedicated to protecting

the right of Illinois citizens to defend themselves with firearms.

4. At least one GSL member who resides in the Village of Deerfield holds a valid

Firearm Owner’s Identification Card and Concealed Carry License. This individual owns one or

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more magazines that qualify as “Large Capacity Magazines” under Ordinance O-18-06 as well

as a handgun that accepts such magazines. The magazine and handgun in question were lawfully

acquired by the GSL member prior to April 2, 2018. This individual is not a law enforcement

officer or agent or employee of any government, a member of the military, or a retired law

enforcement officer. This individual keeps the magazine and handgun in question at home in

Deerfield for self-defense and would continue to do so if permitted by Deerfield law.

5. Because Deerfield officials have indicated that Ordinance O-18-06 bans

possession of magazines capable of holding more than 10 rounds, prior to June 13, 2018, the

Deerfield resident and GSL member described in the preceding paragraph will do one of the

following with the magazine in question: (1) remove, sell, or transfer it from within the limits of

the village; (2) modify the magazine to render it permanently inoperable or so that it permanently

no longer qualifies under Ordinance O-18-06’s definition of a “Large Capacity Magazine”; or (3)

surrender this magazine to the Deerfield Chief of Police or his or her designee for disposal.

6. At least one GSL member who resides in Deerfield owns a firearm that qualifies

as an “assault weapon” under Ordinance O-18-06’s definition of that term and keeps this firearm

at their home in Deerfield. They acquired this firearm prior to April 2, 2018 and would continue

to possess it in Deerfield so if permitted to do so by Deerfield law. This individual is not a law

enforcement officer or agent or employee of any government, a member of the military, or a

retired law enforcement officer.

7. In accordance with Ordinance O-18-06 § 15-90, prior to June 13, 2018, the GSL

member described in the preceding paragraph will be required to do one of the following with

the firearm in question: (1) remove, sell, or transfer the firearm from within the limits of the

village; (2) modify the firearm to render it permanently inoperable or so that it permanently no

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longer qualifies under Ordinance O-18-06’s definition of an “assault weapon”; or (3) surrender

this firearm to the Deerfield Chief of Police or his or her designee for disposal.

8. Because Ordinance O-18-06 will cause GSL members to cease possessing or

permanently alter their lawfully acquired magazines and firearms, they will be irreparably

harmed by the ongoing deprivation of their right to possess and use commonly used magazines

and firearms.

9. Because Ordinance O-18-06 will force GSL members to physically dispossess

themselves of or permanently alter magazines and firearms that they lawfully acquired and

possess, they will be irreparably harmed by the unconstitutional taking of their property without

government compensation.

10. Because Ordinance O-18-06 will force GSL members to give up possession of or

permanently alter magazines and firearms that they lawfully acquired and possess, the law strips

these magazines and firearms of their use. GLS members will be irreparably harmed by the

unconstitutional taking of their lawfully acquired and possessed property without government

compensation.

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 Under penalties as provided by law pursuant to Section 1-109 of the Code of Civil

Procedure, the undersigned certifies that the statements set forth in this instrument are true and

correct.

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4
EXHIBIT D
 IN THE CIRCUIT COURT OF THE NINETEENTH JUDICIAL CIRCUIT
LAKE COUNTY, ILLINOIS
CHANCERY DIVISION

GUNS SAVE LIFE, INC. and JOHN

WILLIAM WOMBACHER III,

Plaintiffs,

v. Case No. 18CH498

VILLAGE OF DEERFIELD, ILLINOIS, and

HARRIET ROSENTHAL, solely in her
official capacity as Mayor of the Village of
Deerfield,

Defendants.

AFFIDAVIT OF JOHN WILLIAM WOMBACHER III

I, John “Jack” William Wombacher III, pursuant to 735 ILCS 5/2-1005, Ill Sup. Ct. R.

191, and 735 ILCS 5/1-109, state as follows:

1. I am a plaintiff in the above-entitled action. I make this declaration of my own

personal knowledge and, if called as a witness, I could and would testify to the truth of the

matters set forth herein.

2. I am a current resident of the Village of Deerfield and Lake County, Illinois.

3. I am a member of Guns Save Life, Inc.

4. I am a law-abiding adult who is not prohibited from owning firearms under the

laws of the United States or the State of Illinois.

5. I hold a valid Firearm Owner’s Identification Card issued by the Illinois

Department of Police. I also hold a valid Illinois hunting license.

6. I am not a law enforcement officer or agent or employee of any government, a

member of the military, or a retired law enforcement officer.

1
 7. Prior to April 2, 2018, I lawfully acquired a magazine capable of holding more

than 10 rounds in accordance with state and federal law. This magazine has not been temporarily

altered to be incapable of accepting more than 10 rounds, it is not a .22 caliber tube ammunition

feeding device, and it is not a tubular magazine contained in a lever-action firearm. I keep this

magazine at my home in Deerfield for use in a handgun, which I also acquired prior to April 2,

2018 and keep at my home in Deerfield for self-defense. I selected this particular magazine in

part because I believe that a firearm with a magazine capable of holding more than 10 rounds is

useful for in-home self-defense and hunting.

8. I wish to purchase additional magazines capable of holding more than 10 rounds

and to keep them at my home in Deerfield. But Deerfield officials have said that Ordinance O-

18-06 prohibits possession of such magazines. Accordingly, I will not acquire additional such

magazines so long as Ordinance O-18-06 remains in effect and no court has said that possession

of such magazines is lawful in Deerfield.

9. But for Ordinance O-18-06, I would possess a magazine capable of holding more

than 10 rounds within the Village of Deerfield for lawful purposes, including in-home self-

defense and hunting, after June 12, 2018. If this Court declares Ordinance O-18-06 invalid or

otherwise enjoins enforcement against possession of magazines capable of holding more than 10

rounds, I will continue to possess such magazines within the Village of Deerfield.

10. Because Deerfield officials have indicated that Ordinance O-18-06 bans

possession of magazines capable of holding more than 10 rounds, prior to June 13, 2018, I will

do one of the following with my magazine: (1) remove, sell, or transfer it from within the limits

of the village; (2) modify the magazine to render it permanently inoperable or so that it

permanently no longer qualifies under Ordinance O-18-06’s definition of a “Large Capacity

2
Magazine”; or (3) surrender this magazine to the Deerfield Chief of Police or his or her designee

for disposal.

11. I own an AR-15. I selected this particular firearm in part because I believe it is a

very good firearm for self-defense and can also be used for hunting. This firearm qualifies as an

“assault weapon” under Ordinance O-18-06’s definition of that term, and its possession in

Deerfield is accordingly prohibited. But for Ordinance O-18-06, I would keep this firearm at my

home in Deerfield for self-defense.

12. I wish to purchase additional firearms that qualify as “assault weapons” under

Ordinance O-18-06’s definition of that term and keep these firearms at my home in Deerfield for

self-defense and hunting. But Ordinance O-18-06 prohibits possession of such firearms in

Deerfield. Accordingly, I will not acquire additional such firearms so long as Ordinance O-18-06

remains in effect and no court has enjoined its enforcement.

13. In accordance with Ordinance O-18-06 § 15-90, I have been required to do one of

the following with my AR-15: (1) remove, sell, or transfer this firearm from within the limits of

the village; (2) modify the firearm to render it permanently inoperable or so that it permanently

no longer qualifies under Ordinance O-18-06’s definition of an “assault weapon”; or (3)

surrender this firearm to the Deerfield Chief of Police or his or her designee for disposal.

14. But for Ordinance O-18-06, I would possess an AR-15 within the Village of

Deerfield for lawful purposes, including in-home self-defense and hunting. If this Court declares

Ordinance O-18-06 invalid or otherwise enjoins enforcement, I will possess an AR-15 within the

Village of Deerfield.

15. Because Ordinance O-18-06 will cause me to cease possessing or permanently

alter my magazine capable of holding more than 10 rounds and my AR-15, I will be irreparably

3
harmed by the ongoing deprivation of my right to possess and use commonly used magazines

and firearms for in-home self-defense and hunting.

16. Because Ordinance O-18-06 will force me to physically dispossess myself of or

permanently alter a magazine and firearm that I lawfully acquired and possess, I will be

irreparably harmed by the unconstitutional taking of my property without government

compensation.

17. Because Ordinance O-18-06 will force me to give up possession of or

permanently alter magazines and firearms that I lawfully acquired and possess, I believe the law

strips my magazines and firearms of their use. I will be irreparably harmed by the

unconstitutional taking of my lawfully acquired and possessed property without government

compensation.

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 Under penalties as provided by law pursuant to Section 1-109 of the Code of Civil

Procedure, the undersigned certifies that the statements set forth in this instrument are true and

correct.

Date:_______________________

__________________________
John William Wombacher III