Hearing Start: No hearing scheduled
FILED
                                                                              2/28/2024 11:53 PM
                 APPEAL      TO THE APPELLATE COURT OF ILLINOIS FOR THE FIRST Iris
                                                                               DISTRICT
                                                                                   Y. Martinez
                                                                              CIRCUIT CLERK
                             FROM THE CIRCUIT COURT OF COOK COUNTY, ILLINOISCOOK COUNTY, IL
                                   COUNTY DEPARTMENT, COUNTY DIVISION         2024COEL000013
               STEVEN DANIEL ANDERSON, CHARLES J.                       )
               HOLLEY, JACK L. HICKMAN, RALPH E.                        )
               CINTRON, and DARRYL P. BAKER,                            )
                                                                        )
                        Petitioners,                                    )      Case No. 2024 COEL 13
                                                                        )
                                 v.                                     )      Hon. Tracie R. Porter
                                                                        )
               DONALD J. TRUMP, the ILLINOIS STATE                      )      Calendar 9
               BOARD OF ELECTIONS sitting as the State                  )
               Officers Electoral Board, and its Members                )
               CASSANDRA B. WATSON, LAURA K.                            )
               DONAHUE, JENNIFER M. BALLARD CROFT,                      )
               CRISTINA D. CRAY, TONYA L. GENOVESE                      )
               CATHERINE S. MCCRORY, RICK S.                            )
               TERVIN, SR., and JACK VRETT,                             )
                                                                        )
                        Respondents.                                    )
                                                NOTICE OF APPEAL
                        Pursuant to Illinois Supreme Court Rule 303, Respondent-Appellant Donald J.
               Trump hereby appeals to the Appellate Court of Illinois for the First District from the
               Circuit Court’s February 28, 2024 Memorandum of Judgment and Order (the
               “Judgment”), which reversed the January 30, 2024 decision of the Illinois State Board of
               Elections, sitting as the duly constituted State Officers Electoral Board (the “Electoral
               Board Decision”) and ordered the Illinois State Board of Elections to remove
               Respondent-Appellant Donald J. Trump “from the ballot for the General Primary
               Election on March 19, 2024, or cause any votes cast for him to be suppressed.”
                                                                                FILED
                                                                                2/28/2024 11:53 PM
       By this appeal,   Respondent-Appellant respectfully requests that the Appellate
                                                                                Iris Y. Martinez
                                                                                CIRCUIT CLERK
                                                                                COOK COUNTY, IL
Court: (a) reverse and   vacate the Judgment; (b) affirm and reinstate the Electoral  Board
                                                                                2024COEL000013
Decision, which overruled and dismissed Petitioners-Appellees’ January 4, 2024
objection to the nomination papers of Donald J. Trump, Republican Party primary
candidate for the office of President of the United States; (c) stay the effect of the
Judgment pending resolution of this appeal; and (d) grant such other relief as the
Appellate Court deems just and proper.
Dated: February 28, 2024                     Respectfully submitted,
                                             RESPONDENT-APPELLANT DONALD J. TRUMP
                                             By:   /s/ Adam P. Merrill
                                                   One of his attorneys
Scott E. Gessler                             Adam P. Merrill (6229850)
GESSLER BLUE LLC                             WATERSHED LAW LLC (No. 64892)
7350 E. Progress Place, Ste. 100             55 W. Monroe, Suite 3200
Greenwood Village, CO 80111                  Chicago, Illinois 60603
720-839-6637                                 312.368.5932
sgessler@gesslerblue.com                     AMerrill@Watershed-Law.com
Nicholas J. Nelson (pro hac vice)
CROSS CASTLE PLLC
333 Washington Ave. N.,
STE 300-9078
Minneapolis, MN 55401
612.429.8100
nicholas.nelson@crosscastle.com
                                               2
                              CERTIFICATE OF SERVICE
       I, Adam P. Merrill, hereby certify that on February 28, 2024, I caused a true and
correct copy of the foregoing NOTICE OF APPEAL to be served upon all parties/
counsel of record via the Court’s Electronic Filing System.
       Under penalties as provided by law pursuant to section 1-109 of the Code of Civil
Procedure, the undersigned certifies that the statements set forth in this certificate of
service are true and correct, except as to matters therein stated to be on information and
belief and as to such matters the undersigned certifies as aforesaid that he verily believes
the same to be true.
                                                     /s/ Adam P. Merrill
                                                          Adam P. Merrill