IN THE CIRCUIT COURT OF COOK COUNTY, ILLINOIS
COUNTY DEPARTMENT, COUNTY DIVISION
METROPOLITAN WATER RECLAMATION)
DISTRICT OF GREATER CHICAGO, aunit —)
of local government and body corporate and)
polite, )
)
Plaintith, ) No. 18 COEL 030
)
v }) Judge Patrick T. Stanton
)
DAVID ORR. in his official capacity, eal )
)
)
Defendants
NOTICE OF MOTION OF TONI PRECKWINKLE TO INTERVENE,
OR IN THE ALTERNATIVE, TO FILE AN AMICUS BRIEF
To: See a
iched Certificate of Service
PLEASE TAKE NOTICE that on October 11, 2018 at 9:30 am, the undersigned shall appeat
before the Honorable Patrick T. Stanton or any judge siting in his stead in courtroom 1706 of the
Richard J. Daley Center. 50 W. Washington, Chicago, Ifnois 60602, and then and there present
the attached MOTION OF TONI PRECKWINKLE TO INTERVENE, OR IN THE
ALTERNATIVE, TO FILE AN AMICUS BRIEF, «copy of which is attached and hereby
served upon you,
Dated: October 4.2018, Respectfully Submited,
st Mi
hae! Kreloft
Michael Kreloff (capitolation déxshov.com)
1926 Waukegan
Suite 310
Glenview, Iinois 60025
847-525-1139
ARDC # 1529560
David R. Melton (David. MelionJawdgmil.som)
Steven H. Fine (sine
‘Mhowrnai.eom)CERTIFICATE OF SERVICE,
Under penalties provided by law under section!-109 of the Illinois Code of Civil
Procedure, the undersigned, an attorney, certifies that copies ofthe Notice of Motion and Motion
to Intervene, Or In The Alternative, To File An Amicus Brief were served upon:
Board of Election Commissioner for the City of Chicago
hoe’ chicaoelections nt
David Walsh
ja
R, Cameron M. Davis
wistus@ gmail.com
Geoffrey Cubbage
Scots’ atL. GP.one
Michael Kasper
Mikasner6 an
Ed Mullen
[Ed Mullen dime com
Amy Crawford, Assistant Cook County State's Attomey
Amy.Crywfoud? acookcountsil
Via electronic mail before the hour of 4:00 pm. this 4* day of October 2018.
ss/ Steven H. FineIN THE CIRCUIT COURT OF COOK COUNTY, ILLINOIS
COUNTY DEPARTMENT, COUNTY DIVISION
METROPOLITAN WATER RECLAMATION
DISTRICT OF GREATER CHICAGO, a unit
‘of local government and body corporate and
>
)
>
politi, )
)
Plait, ) No, 18 COEL 030
)
v 5} ge Patrick T. Stanton
)
DAVID ORR. in his official capacity e al )
)
)
Defendants
MOTION OF TONI PRECKWINKLE TO INTERVENE,
ORIN THE ALTERNATIVE, TO FILE AN AMICUS BRIEF
Toni Preckwinkle, in her capacity as Chairperson ofthe Cook County Democratic Party,
‘moves to intervene asa party defendant in the above matter, pursuant to 735 ILCS i
8,
representing the interests of that Party. of the 60,691 Democratic Party voters who cast write-in
‘ois in the March 20, 2018 Primary Election to nominate a Democratic candidat run nthe
November 62018 General Election forthe Bradford Vacancy on the Board ofthe Metropolitan
Water Reclamation District of Greater Chicago ad ofthe many hundreds of thousands of voters
‘who are expected to paticipate in that election.
As less favored altemative, Chairperson Preckwinkle sec leave of court patticipate
as an amicus curiae in tis mate, on behalf ofthe Cook County Democratic Party and its voters.
In support of this motion, Preckwinkle states as Follows:
1) For offices where voters were to nominate candidates inthe March 20, 2018 Primary
candidates seeking o have their names appear upon the March ballot had 90 days to collect
signatures, fiom September 5,2017 to December 4, 2017. the las date to file nomination papers.
1OILCS 517-10.