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February 14, 2022 <br />Page 11 <br />(upholding challenged absentee ballots). And we have been reluctant to exclude <br />such petitions "on mere technicalities," because the can be "the result of <br />democracy working at the Uassroots level." Bogen v. Sheedy, 304 Minn. 62, 229 <br />N.W.2d 19, 24 (1975). But we also recognize that we must adhere to mandatory <br />statutory requirements, such as a voter's "affidavit of residence and eli ibilit " to <br />vote, to ensure that only those who are qualified to participate do so. Bell, 227 <br />N.W.2d at 803 (concluding that absentee voters "must be held to a strict <br />compliance" with all substantial requirements of absentee voter statutes). <br />(Emphasis added). And, in Butler, the Supreme Court upheld St. Paul's determination that the <br />petition was insufficient because it did not adhere to the mandatory statutory requirement for <br />minimum number of valid signatures from registered voters. <br />Here, City Clerk Ewald not only (1) did not determine whether the Citizen Petitioners had <br />met their required number of valid signatures in the Citizens' Petition but also (2) refused to even <br />calculate the required number. City Clerk Ewald must, therefore, immediately reverse the February <br />4, 2022 Insufficiency Letter and accept the Citizens' Petition as sufficient. <br />Sincerely, <br />TAFT STETTINIUS & HOLLISTER LLP <br />/s/ Jack Y. Perry <br />Jack Y. Perry <br />JYP:fcb <br />cc: Brian & Valerie Amundsen <br />Scott Riggs, City Attorney <br />Emily Hunt, Elections Office <br />