August 16,2006
Robert Batchelor
Coshocton County Prosecuting Attorney
318 Chestnut St.
Coshocton, Ohio 43812
Mr. Batchelor,
This complaint filed this day, August 16,2006 is a full and accurate accounting of events resulting from my first hand knowledge and direct involvement in the 2004 Presidential Vote Recount.
All allegations of misconduct are corroborated in public records, transcripts and correspondence between the Coshocton County Board of Elections and me. Due to your role as counsel for the Coshocton County Board of Elections, it is appropriate that a special prosecutor be named to investigate this matter immediately and that you neither begin an investigation nor serve as counsel for those named hi this complaint. The appointment of a special prosecutor in matters concerning members and employees of county boards of election represented by the office of the County Prosecutor was reaffirmed by the Cuyahoga County Prosecutor with the appointment of Special Prosecutor Kevin Baxter of Erie County to investigate similar allegations filed against members and employees of the Cuyahoga County Board of Election, with subsequent indictments then issued in April, 2006 against three employees of the Cuyahoga County Board of Election due to that investigation.
It is also necessary that the presiding court immediately move to issue an order to preserve all documents pertinent to the General Election of November 2, 2004 and the 2004 Presidential Vote Recount in Coshocton County. This order should include all records at the Coshocton County Board of Election as well as the Office of The Ohio Secretary of State and any and all relevant records that may be stored elsewhere.
Although only those actions and events that transpired as verifiable acts of misconduct are addressed in this complaint, it is important to note the intent of the Coshocton County Board of Election, the Director of the Coshocton County Board of Election and the Deputy Director of the Coshocton County Board of Election to misrepresent the outcome of the General Election of November 2,2004 as well as their intent to violate not only the "Outline of Recount Procedures" as directed by the Secretary of State, but the spirit of the Recount as well. In statements to the media by the Director intended to cover up the failure of tabulating equipment on Election Day, as well as official record documenting the Board's intent to ignore the Secretary of State's Directive requiring random selection of precincts to be recounted it is apparent that there was a sense among the Board and it's employees that they need not comply with the law.
Please contact me at your earliest convenience if you would like to discuss this complaint further.
29674 Township R Warsaw, Ohio 43844 (740) 824-3828
Thank you for your prompt attention to this matter, Timothv