Friday, February 14, 2014


TO: Steven P. Okey, Esq.

FROM: Craig T. Conley, Esq.

RE: Cynthia Balas-Bratton's Protest Against Maier Candidacy

I am in receipt of your faxed correspondence of earlier today and must respectfully disagree with the opinion you have given your client, Mr. St. John; and, I do not believe that his self-serving (and I would suggest disingenuous) Affidavit “saves the day" for him here.

Indeed, as a long-time litigator yourself, I cannot imagine you would not have very aggressively demanded the disqualification of a juror and/or of a judge in any of your cases who had expressed the same predisposition as your client (who, for purposes of the instant Protest, is both a judge and a juror) has already done here.

I note also that you, as an attorney, have previously strongly aligned yourself with Mr. Maier and his "I'm statutorily qualified" position by, inter alia, signing the same letter to the DCC as had your instant client, Mr. St. John; by directly and/or indirectly (via, among others, Chairman Gonzalez) advocating that same position before and/or during and/or after one or both of the subject DCC meetings (noting that your client, by voting twice for Mr. Maier at those meetings, also thereby essentially advocated that same position; by appearing with Mr. Maier on November 15, 2013 for a post-removal interview with The Alliance Review, where you concurred with Mr. Maier's assessment that he is now statutorily qualified; and, by representing the DCC (of which Mr. St. John is a member) before the Ohio Supreme Court in Messrs. Swanson's and Darrow's mandamus action against Chairman Gonzalez and the DCC involving closely related issues to those now before the Board via my client's Protest.

Ironically, I believe your aforesaid pro-Maier activity provides yet another basis for Mr. St. John's disqualification.

Specifically, all of Mr. St. John's prior activities and statements aside, I do not believe he may sit in judgment on the Protest and thereby decide an issue strongly advocated (as aforesaid) in Mr. Maier's favor by his own counsel, you.

Accordingly, it. is respectfully suggested that you should immediately reconsider the legal advice you have given Mr. St. John and/or that he should immediately reconsider his "damn the torpedoes" decision.

In any event, if Mr. St. John continues "on course", I will seek his recusal and/or removal via judicial process. (emphasis added by SCPR)

Please very promptly advise.

Thank you.

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