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February 14, 2022 <br />Page 9 <br />applied to the Citizens' Petition, Minn. R. 8205.1050, subp. 2 provides, as follows, the procedure <br />for verifying petitions to determine whether they comply with Minn. R. 8205.1010, including the <br />requirement that the filing officer — in this case City Clerk Ewald — declare the Citizens' Petition <br />sufficient as long as it "substantial[ly]" complies with type size requirements: <br />Subp. 2. Verifying petitions. The filing officer shall verif each etition usin the <br />method in items A to C. <br />A. The filing officer shall inspect the form of the petition to determine <br />whether it complies with part 8205.1010. The filing officer need only <br />determine substantial com liance with regard to any a size on the form. <br />B. The filing officer shall inspect the petition to determine whether it has <br />been signed by the required number of signatories and whether the <br />signatories meet the applicable eligibility requirements. <br />If the petition has not been signed by the required number of qualified <br />signatories, the filing officer must notify the person who filed the petition: <br />(1) that the petition has not been signed by the required number of <br />signatories; and <br />(2) of the number of additional signatures needed. <br />If the time for circulating the petition has not expired, the <br />petitioners may collect additional signatures and submit <br />them at one time to the filing officer before the circulation <br />period expires. <br />C. If the petition satisfies the form requirements in part 8205.1010 and has <br />been signed by the required number of qualified signatories during the <br />applicable time period, the filing officer shall notify the person whose name <br />is on the RLtition receipt that the petition is sufficient. <br />(Emphasis added). Minn. R. 8205.1050, subp. 3 adds that "[t]he filing officer shall complete the <br />verification of a petition as soon as practicable but no later than ten working days after the day_ <br />on which the petition was filed." (Emphasis added). <br />Here, City Clerk Ewald not only (1) never determined that there was not substantial <br />compliance with regard to any type size on the Citizens' Petition form but also (2) did not even <br />inspect the Citizens' Petition within 10 working days to determine whether it had been signed by <br />