When civil right government investigators need to be investigated for corruption, there is a serious issue in the ability of people to have and exercise their civil rights.

1. BEFORE THE SPRINGFIELD MISSOURI
CIry COUNCIL MEMBERS
CHRISTOPHER CROSS
Petitioner,
V.
COMMISSIONER CHARITY JORDAN
COMMISSIONER CHASE SNIDER,
COIVIMISSIONER MI KE GARTON,
COMMISSIONER GAIL HERBERT,
COMMISSIONER JASMINE ALLEN,
COIVIIVIISSIONER JAfvlEA CRUM, and
COIUMISSIONER RACHEL NAAB
Petition for impeachment of Commissioner's
of the Springfield, Missouri Mayor's
Commission on Human Rights & Community
Relations.
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VERIFIED PETITION TO IMPEACH RESPONDENTS,
REQUEST FOR HEARING & ATTACHED AFFIDAVIT
COI/IES NOW, Christopher Cross, in his capacity as a Springfield citizen with a vested interest
and with his Verified Petition To lmpeach Respondents, as herein avened
STANDING
(1) Petitioner Christopher Cross, (hereinafter "Cross" or "Petitioner") is and on all relevant
dates, has been a citizen of the City of Springfield (hereinafter "City").
(2) Petitioner, is a qualified individual with disabilities and therefore a constituent of the City
Mayor's Commission on Human Rights & Community Relations (hereinafter "MCHR").
(3) Petitioner meets the requirements set forth in Article ll S 243(b) of the City Code, to ad-
dress the City Courrcil with his petition to impeach the Respondents.
(4) Petitioner has standing pursuant to $ 2-43(c) to address members of the City Council in
redress of grievance and comes now, with his petition.
CAUSE OF ACTION
(5) As more fully explained in this petition and Petitionefs forensic Revised lnvestigative Re-
port, on all relevant dates Respondents and all of them, have and continue to violate state laws,
City ordinances, City Charter provisions, case law rulings, and the public's best interest.
(6) On all relevant dates, the Respondents and all of them, whether individually, collectively

2. or by the acts or omissions of others engaged in the following conduct:
(A) habitually violated Missouri open records laws;
(B) conducted a secret meeting to discuss regular order public business;
(C) held a public meeting and made, took and adopted votes without a quorum;
(D) arbitrarily sought out and pursued amending or repealing City ordinances;
(E) declared and acted on their declaration to refuse to be trained and educated;
(F) declared and acted on their declaration to refuse to comply with City ordinances;
(G) declared and acted on their declaration to refuse to act in public's best interest;
(H) declared and acted on their declaration to refuse to avoid conflicts of interests;
(l) declared and acted on their declaration to refuse to abide by ethical obligations;
(J) engaged in conduct allowing or causing abuse, neglect and exploitation; and
(K) engaged in turpitude, misconduct, malfeasance, misfeasance and/or nonfeasance.
(7) A reasonable cause to believe exists, and a reasonable inference can be drawn, that it is
a carnal duty of every Respondent to know the laws and ordinances they operate by, under and
are enforcing. The conduct of the Respondents and all of them necessitates and qualifies for
their removal by impeachment, pursuant to Art. ll, S 2.16(29) and Art. XV, S 15.6 of our Charter.
(8) ln this context, "the "common maxim, familiar to all minds, that ignorance of the law will
notexcuse any person, eithercivilly orcriminally."'U.S. v. Hutzell,217 F.3d 966,968 (8th Cir.
2000). See also Jermanv. Carlisle etal, 559 U.S. 573, 581-83 (2010) (pointing outthat "an act
may be deemed "intentional" for purposes of civil liability, even if the actor lacked actual knowl-
edge that her conduct violated the law.")
FACTUAL ALLEGATIONS
(9) Petitioner herein incorporates and realleges fl 1 to fl 8 above, by reference and in full
force and effect, as if originally pleaded below.
A. MCHR as a whole body is a City public governmental body.
(10) The MCHR is a City public governmental body and Commissioner's are city government
officials, in that pursuant to or in accordance with:
(A) Commissioner's are sworn into office by the City and thereby operate under color of
of law, in accordance with and pursuant to their oath of office and its mandates;
(B) The Commission and Commissioner's are bound to the ltlissouri open records laws.
See lipfon v. Bar7on,747 S.W.2d 325,329 (Mo. App. E.D. 1988);
(C) Chapter 62, Article lV, S 2-221 declares the MCHR is a permanent body of the City
government;
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3. (D) Pursuant to Art. IV, Div 1 , S 2-161(b), Commissioners are appointed by the Mayor of
the City and confirmed by consent of the City Council.
(11) As a direct or proximate result and on all relevant dates, the MCHR and Commissioner's
operated under color of law and as actors of the City.
(12) The MCHR and its Commissioners are required to act in accordance with the laws and
ordinances that govern them. See Yellorry Freight Sysfems, lnc. v. Mayors Commission On
Human Rights 791 S.W.2d 382 (Mo. en banc 1990),
(13) The City Codes governing the MCHR and Commissioners include, but are not necessar-
ily limited to, Art. lV,S2-221to $ 2-223 (General Powers & Duties); Art. ll, S 62-31 to $ 62-42
(Fair Employment Practices); Art. lll, S 62-131 to $ 62-151 (Fair Housing Practices) andArt. lV,
S 62-181 to $ 62-187 (Public Accommodations).
(14) The City Codes governing the tt/CHR and its Commissioners ethical obligations and that
prohibit conflicts of interests, include, but are not necessarily limited to, Art. lV, S 2-161 ef seq.
B. City owes a duty to protect people in protected classes of citizens
(15) Relevant to this petition, pursuant to $ 2-16(20) of our City Charter, the City is required to
"[d]o all things whatsoever necessary or expedient for promoting and maintaining the comfort,
education, morals, safety, peace, government, health, welfare, trade, commerce, or industry of
the city and its inhabitants."
(16) Relevant to this petition, pursuant to $ 2-16(29) of our City Charter,, the City Council is
required to "[e]nact adopt, and enforce all ordinances, rules, and regulations; do all things, and
exercise all governmental and municipal authority necessary, needful, and convenient, con-
tributing to, or bearing a substantial relation to the full and complete exercise of all the powers in
this Charter enumerated."
(17) Relevant to this petition, pursuant to $ 2-16(36) of our City Charter, the City is required to
provide for the "support, maintenance, and care of the sick, aged, or insane poor persons. . ." by
and through the prescribed duties and powers of the MCHR and its Commissioner's, as set forth
in, but not limited to, the City Codes in Art. lV, S 2-221 to S 2-223; Art. ll, S 62-31 to S 62-42; Art.
lll, S 62-131 to $ 62-151; and Art. lV, S 62-181 to $ 62-187.
C. City Gouncil is authorized to assign an investigator and conduct public hearing.
(18) Relevant to this Petition and pursuant to Art. l, S 1 .3 of the City Charter, the City Council
is authorized to conduct a hearing on this Petition.
(19) Relevant to this Petition and pursuant to, Article ll of the City Charter, af $ 2-15, "[t]he
council may appoint an investigator who shall serve for such term as the council may prescribe.
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4. He shall make such other investigations as the council may direct."
(20) ln accordance with and pursuant to $ 2-16(20),(29) and (36) and Yellow Freight Sys-
tems,Inc. ruling and outcomes on public tax revenue spent litigating the case, it will constitute a
gross dereliction of duty owed for the City Council not to assign an investigator and conduct the
hearing.
(21) Moreover, it will constitute turpitude, misconduct, malfeasance, misfeasance and/or non-
feasance to the duty owed, and a declaration of the City Council that the rights of citizens of the
City who have disabilities, and any violation thereof, is of no care or concern of the City Council,
as this class of citizens is unworthy to have inclusion, equity, and equality in this City.
INCORPORATIONS
(22) Petitioner herein incorporates and realleges fl 1 to fl 21 above, by reference and in full
force and effect, as if originally pleaded below.
(23) Petitioner herein incorporates and realleges, by reference and in full force and effect, his
40-page forensic Revised lnvestigative Report, previously submitted to the City Council, TVICHR
and Respondents, by electronic mail.
(24) Petitioner herein incorporates and realleges, by reference and in full force and effect, the
allegations, claims, assertions, statements, citations of law, ordinances, case laws, electronic
mails, and media reports.
(25) Petitioner herein incorporates and realleges, in full force and effect, any and all elec-
tronic mails from and to the Petitioner and Garrett Mees, form or to City officials whether publicly
elected or appointed, which the City has access, control or custody of said electronic mails.
(26) Petitioner herein incorporates and realleges, in full force and effect, the sworn affidavit of
and by Garrett [/ees, which is attached hereto.
STATEMENT OF FACTS
(27) Petitioner herein incorporates and realleges fl 1 to !f 26 above, by reference and in full
force and effect, as if originally pleaded below.
A. Respondents declared and acted on their declaration to refuse to be educated.
(28) On February 12,2024 and then again, on February 21,2024, Respondents declared and
acted on their declaration by casting, counting, and adopting the affirmative votes to refuse to
receive necessary, just and proper training and education to discharge their duties and powers.
(29) The conduct of Respondents and by extension, the MCHR, is ultra vftes as their conduct
has the purpose, design, or intent to repeal or amend, undermine or circumvent, or flatly violate
S 2-16(20),(29) and (36) of our City Charter and/or S 2-221 to $ 2-223 of our City Codes.
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5. (30) The conduct of Respondents and by extension, the tt/CHR, is ultra vires as their conduct
has the purpose, design, or intent to repeal or amend, undermine or circumvent, or flatly violate
their ethical obligations set forth in $ 2-161(aX1Xa) and/or (b).
(1) Respondents acted on their own self-interests in refusing to be educated.
(31) Respondents assert the following reasons for refusing to pursue and receive training and
education provided by the State of Missouri, Human Rights Commission:
(A) They are volunteers and thus, do not have time and should not have to devote their
time conducting investigations;
(B) They are not properly trained and educated to be state certified;
(C) The City Council refuses to appropriate funds to hire a full time investigator so they
do not have to do investigations;
(D) The City should supply someone else to investigate instead;
(E) lt requires too much personaltime to be trained and educated;
(F) They only serve three year terms, so what is the point;
(G) They should only be referring people to someone else to investigate;
(H) lf they are certified then they will have to be experts,
(l) lf they get trained, educated and certified, there will be an increase of complaints; and
(J) lt is the responsibility of the state to investigate and not theirs;
(2) Respondents are their own and the public's, worst enemy.
(32) The Respondents and all of them knowingly, willingly and intentionally filed out and filed
their application to be nominated and appointed, and accepted their appointed positions.
(33) The Respondents and all of them owed a duty to the City and its citizens to understand
the duties of a Commissioner before accepting appointment to be a Commissioner.
(34) The Respondents and all of them owed a duty to the City and its citizens to understand
the laws, ordinances and case law rulings governing the MCHR before accepting appointment.
(35) The Respondents assert they are not or they complain about not being properly trained
and educated but then, cast, count and adopt votes to refuse to be trained and educated.
(36) The Respondents and atl of them do not comply with $ 2-223(7) and (8) duties to petition
the City Council to appropriate funds to hire a fulltime investigator
(37) The Respondents and all of them do nof comply with $ 2-223(4) and (9) to see what the
public wants and to draw public support to get what Respondents want, in hiring an investigator.
(38) The Respondents instead, arbitrarily, capriciously or unreasonably decided to cast, count
and adopt votes in the affirmative, to do as they want regardless of the public's best interests.
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6. (39) ln 2020, the MCHR and the City conducted a citizen survey to see what the citizens want
done and yet, the MCHR and Respondents now ignore what was communicated to them, in that
of investigating, resolving and preventing discrimination because of a protected class status.
(40) lf all the Respondents want to do is provide the City and themselves some "feel good"
cosmetic appearance for a bullet point to brag about lhen they are worthless because this is not
about them - itis about people who are victimized by discriminatory conduct.
B. Respondents and all of them violate ordinances prohibiting conflicts of interests.
(41) As set out in the Petitioner's forensic Revised lnvestigative Report, on Pp.15 and 16, the
Respondents and all of them violate S 2-161(c)(1)a., and/or (cX2)a of the City Codes.
(42) The conduct of the Respondents and all of them permit third-parties, including a religious
organization, to have the opportunity to wiretap electronically transmitted records, documents,
information and communications, which also violates Mo. Rev. Stat. S 542.402 ef seq.
(43) Likewise, any document, record, communication or information wiretapped that contains
the information of a state Safe-At-Home participant violates Mo. Rev. Stat. $ 589.669(2) which
can endanger the life, health, safety or welfare of a Safe-At-Home participant.
C. Respondents are negligent in curing defects that are brought to their attention.
(44) On January 5,2024, Petitioner submitted the report Respondent Mike Garton requested,
about the defects, deficiencies and violations of law, the MCHR website pages contain.
(45) On February 21,2024, Petitioner informed the Respondents that in overthirty days, no
corrective actions had been made to the issues Petitioner identified in his report.
(46) As set out on Pp^18 to 20 of the Petitioner's forensic Revised lnvestigative report, there
are numerous defects, deficiencies and violations of law existing.
(47) Even the simplest deficiency of not listing who the Chairperson of the MCHR is, on the
website page, has not been implemented.
(48) Some defects involve lnternet web links not working, but these defects have also gone
unfixed, and audio-video recordings that violate the Americans with Disabilities Act remain.
(49) Thus, even when Respondents are made aware of defects, deficiencies and violations of
law existing, that adversely affects their public image, the rights of people, and prevent people
from participating in their government, Respondents are negligent in fixing the issues.
D. Respondents habitually engage in violations of Missouri's Sunshine laws.
(50) As discussed on Pp.25, 28 and 30 af fl 1 to fl 8, of Petitioners forensic Revised lnves-
tigative Report, numerous issues are discussed about the custom, pattern or practice of Re-
spondents violating Missouri's open records and open meetings laws.
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7. (51) Missouri's open records and open meetings laws are not mere suggestions, as they are
instead, requirements. The lack of transparency, accessibility and the shroud of secrecy that the
Respondents engage in, demonstrates a flagrant disregard for the law and intentional violations
of the law, that seriously damages the credibility and image of the MCHR.
(52) Respondents conduct meetings that are secret, that do not contain the required quorum,
that have not produce published minutes for nearly two consecutive years.
(53) Rather than Respondents owning their illegal, unlawful and unethical conduct, the Peti-
tioner is chastised for criticizing them for their conduct, by condescending, passive-aggressive
and arrogant electronic mails from Respondent Mike Garton.
(54) Moreover, by the so-called Director of Diversity, Equity & lnclusion engaging in conduct
that is prohibited by Art. lV, Div. 1 $ 78-92 of the City Code, when the Director saw fit to publicly
humiliate and reprimand the Petitioner for speaking when Respondent Jordan called Petitioner
to speak, and Petitioner informed Respondents they are ultra vries to repeal ordinances.
(55) On February 15, 2024, the City publiclv admitted that the Petitioner is right about public
records on ftICHR meetings being and continuing to be concealed.
(56) On February 21,2024, the City publiclv admitted Petitioner is right, that Respondents
conducted a public meeting without the required quorum.
(57) On February 21,2024, the City publiclv admitted Petitioner is right about Respondents
seeking to use their votes to repeal or amend City ordinances, and reprimanded them for such.
(58) The Western District Appellate Court for Missouri held that conducting secret polls with
members of a public governmental body violates Missouri's open meetings laws. See Colombo
v. Buford,935 S.W.2d 690,695 (Mo. App. W.D. 1996).
(59) Petitioner's forensic Revised lnvestigative Report, on p.33, quotes the Missouri Attorney
General: "[A] public governmental body may not purposely meet in groups with less than a quo-
rum to discuss public business and then ratify those decisions in a subsequent public meeting."
(60) On February 22,2A24, Respondent Mike Garton admitted this is exactly what happened
by Respondents conducting the February 12,2024, meeting without a quorum and then ratifying
the decisions made in the subsequent February 21, 2024, public meeting with a quorum.
(61) The Missouri Supreme Court holds that the MCHR and Respondents cannot act beyond
the authority given to them in law. See Yellorry Freight Sysfems, lnc. v. Mayors Commission
on Human Rights,791 S.W.zd 382 (tt/o. en banc 1990)"
E. Discrimination is a form of abuse, neglect or exploitation of protected classes.
(62) As explained on Pp. 2 to 6 of the Petitioner's forensic Revised lnvestigative Report, the
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8. citizens of the City have positively, specifically, absolutely expressed that they want City officials
to actively address, investigate and prevent discrimination because of a protected class status.
(62) The City's Five Pillars of Change is predicated on the 2022'final report by the 15 to 18
member panel of the Mayor's lnitiative on Equity and Equality, which, as Petitioner's forensic in-
vestigative report points out, on p.5, makes recommendations that mirror the results of the 2020
inclusion survey of citizens. See Pefitroner's forensrc Revrsed lnvestigative Repoft on p.4.
(64) Discrimination is a factual and provable form of abuse. neglect or exploitation Petitioner
cites one state law demonstrating that the denial or abridgment of services or goods constitutes
abuse or neglect of people in the identified three protected classes. Of course, since police will
not arrest Respondents, they are free to abuse and neglect people by denying services.
(65) By Respondents refusing to pursue opportunities and credentials, to be properly trained
and educated, in providing competent governmenl investigative seruices, the Respondents then
deprive or abridge government seryrbes to profecfed c/asses and thereby engage in abusing or
neglecting people with disabilities, senior citizens and vulnerable people.
(66) The Respondents refusal to be properly trained and educated to provide competent and
required government investigative services, violates S 2-16(36) of our City Charter, to "provide
for the "support, maintenance, and care of the sick, aged, or insane poor persons. ."" as this is
relevant to and applicable to investigating discrimination because of a protected class status.
(67) ln other words by Respondents refusing to be trained and educated, to give competent
government investigative services, the Respondenls themselves discriminate against people
because of aoe. disabilitv or vulnerability and thus, the Respondents are @
and/or neglect of these statutorily protected classes.
F. Respondent Rachel Naab represents MCHR with City Council.
(68) Respondent Rachel Naab is identified as the Communications Officer for the MCHR, to-
wit, is the liaison between the MCHR and Respondents and that of the City Council.
(69) Pursuant to $ 2-222(b) of the City Code, Respondent Rachel Naab is ultra vr'res in the
right to preside over any MCHR meeting, This ordinance only permits the chair and vice-chair to
preside over MCHR meetings"
(70) On February 21, 2024, the assistant to the Director of Diversity, Equity & lnclusion asked
Respondent Rachael Naab to preside over the MCHR monthly meeting, when and because the
assistant thought Respondent Charity Jordan, who is the Chainrvoman, might not show up.
(71) lt is yet another example of the incompetence about or the refusals to follow ordinances
that govern the Respondents, the MCHR and its meetings.
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9. (72) Pursuant to $ 2-223(7) and (8), Respondent Rachel Naab is required and responsible for
addressing the City Council in both policy and legislative recommendations, that empowers the
MCHR and the Respondents to discharge their duties and exercise their powers.
(73) There is no known and no minutes published on the City's website for the past two-years
that shows the MCHR, by and through Respondent Rachel Naab, has pursued and therefore,
complied with $ 2-223(7) and (8), to redress the Respondents grievances and find resolutions.
G. Respondent Mike Garton's electronic mails fail or refuse to dealwith facts and law.
(74) ln a series of electronic mails from Respondent Mike Garton, while he asserted that he is
not speaking for the MCHR, he certainly demonstrated he is the self-appointed defender of the
MCHR and the self-appointed savior of the Respondents.
(75) ln paraphrasing the attached sworn affidavit of Garrett Mees and his electronic mails, he
describes Respondent Mike Garton as an incompetent official who habitually uses deflection,
gas-lighting and subterfuge tactics to habitually ignore the facts and evade the law.
(76) Petitioner describes Respondent Mike Garton's electronic mails as being habitual pretext
excuses with passive-aggressive efforts and condescending and arrogant responses, to evade
the law by ignoring the facts and the applicable laws and ordinances.
(77) Moreover, the Petitioner describes Respondent Mike Garton's electronic mails as efforts
to sidestep the violations of law by flip-flopping around in his claims and assertions, and looking
for any exouse he can manufacture or manipulate to seemingly rationalize and justify dissenting.
(78) Respondent Mike Garton argues citizens should not criticize government, as they should
instead follow the Skinner behavioral response philosophy, which is to say, citizens should use
positive reinforcement to get desired results by soft approaches and natural consequences.
(79) lt is the right and natural consequence to criticize government officials who violate laws,
and using so-called positive reinforcement in politics and adversarial bureaucratic systems is, by
its very cause and effect, contrary to the reality of what exists.
(80) Garrett Mees and Petitioner spent considerable time, effort and energy explaining the
facts to Respondent Mike Garton, who, at every opportunity that he could look for, manufacture
or manipulate, used whatever unsubstantiated pretext excuses he could, that are disputed by
City officials, the facts, and the evidence, just to argue for the sake of arguing and antagonize.
(81) His arguments are nof based on due diligence in research, in speaking with city officials
before making his allegations, in obtaining an opinion from City legalstaff, in reading laws, ordi-
nances and case laws, or examining records. Rather, they were argumentative coniectures that
lack credibility and failed to show his having any true desire to address the issues.
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10. H. Respondents were required to bring recommendations to Gity Council.
(82) On November 18, 2A23, Respondents Jordan, Naab, Garton, Allen, Snider and Crum all
discussed the need to have a future focus group on whether to pursue training and education, to
become state certified in performing their investigatory duties.
(83) On November 27, 2024, Respondents met without the required quarum and discussed
regularorderbusiness, in violation of law. On November 18,2023, six (6) Respondentswere at
the meeting. However, on November 27,2023, only four attended and one left early.
(84) On December 20, 2023, Respondents Snider, Allen, Garton, Jordan and Naab talked on
the subject of training, education and certification. Respondent's Snider and Garton agreed to
continue researching. Respondent Jordan agreed to write the meeting agenda with the [/layor.
(85) On January 17,2A24, Respondent Jordan reported the meeting with the Mayor had not
yet occurred and would be rescheduled.
(86) On February 12,2A24, Respondents Allen, Snider, Herbert and Crum conducted a meet-
ing without the required quorum and yet, they disl cast, count and adopt their votes to nof pur-
sue training, education and certification to conduct investigations.
(87) On February 21,2024, Respondent Jordan reported the second scheduled meeting with
the Mayor had again been canceled. Adriana Faillia told Respondents the February 12,2024,
meeting violated the law. Respondents g[g[ cast, count and adopt votes ratifying the decisions
in the Febrtrary 12,2024, to not pursue training, education and certification to do investigations.
(88) On February 22,2024, Respondent Garton sent Garrett Mees and the Petitioner an elec-
tronic mail, discussing the February 12, 2024 vote and the February 21, 2024, vote. Respondent
Garton wrote, "[t]he city reposted the same two agenda items, a new meeting was gaveled (sic)
in, the two items were discussed, and the outcomes of the two votes last night were identical to
the outcomes of the votes on the 12th."
(89) Missouri Attorney General, Andrew Balley, points out that a "public governmental body
may not purposely meet in groups with less than a quorum fo discuss public business and then
ratify those decrsrbns rn a subsequent public meetingll" (emphasis added). And Respondent
Garton admits this what the Respondents 4d on February 12, 2024 and February 21 , 2024.
(90) Respondents admit they never spoke with the Mayor [and City Council], as they agreed
to do, on November 18, 2023, to discuss the training, education and certification. Rather, the
Respondents arbitrarily, capriciously and unreasonablv decided they would proceed to cast,
count and adopt votes to nof obtain the training, education and certification, instead.
(91) Thus, Respondents decided to repeal. amend. undermine or circumvent City Codes and
10

11. our Charter and the evidence shows they knowinglv. intentionally, willfullv, intentionally and ma:
ticiousty engaged in and pursued this course of conduct without ever having first consulted the
Mayor and City Council, and obtained consent by the proper and reauired legislative processes.
CONCLUSION
(92) Petitioner herein incorporates and realleges fl 1 to fl 9't above, by reference and in full
force and effect, as if originally pleaded below.
(93) The Mayor's Commission on Human Rights, by its very name, is supposed to be and it is
required to be the flagship of the City. in protecting rights. lt has a positive, specific and absolute
duty to promote, carry out and ensure the Council's duties prescribed in $ 2-16(20) and (36) of
our City Charter to ensure every citizen is receives diversity, equity, equality and inclusion.
(94) ln listening to one former Commissioner and Respondents talk, on February 21,2024,
the assertion was made that city ordinances do not give the MCHR subpoena powers, whereas,
if the Respondents were certified, they would have this power. The former Commissioner and
Respondents do 4q!l even know City Codes already oive the MCHR subpoena powers. See
Art. ll, S 62-40; see also Art. lll, S 6243; see also Art. lV, S 62-183(a),
(95) The blatant refusal of the Respondents to pursue competent and qualified training and
education shocks the conscience. lt is arbitrary, capricious, unconscionable and danqerous.
(96) Their turpitude, misconduct, malfeasance, misfeasance and/or nonfeasance is paltern
or practice, and shocks the conscience. The failure or refusal of this City Council to put an end
to the illegal and/or unlawful conduct of the Respondents and ensure citizens have a viable and
effective and efficient place to redress grievances locally, will also shock the conscience and
further endanger public safety, if City Council decides to pursue this illegal and/or unlavuful path.
WHEREFORE, Petitioner Christopher Cross submits his petition for this City Council to
impeach the Respondents, whether individually or collectively; to restore the MCHR to its proper
functioning, and take all further actions, policy decisions and legislative efforts that are just and
proper, based on our City Code and City Charter, to ensure the MCHR as a whole body, has the
tools, supports, training and education required, to act in the public's best interests.
Respectfully submitted,
Cror.k rrrulr* L oarx
C h n sto pheiffiss, Fetitio ne r
Secretary of State Participant # 430039
P.O. Box 1409
Jefferson City, MO 65102
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12. AFFRIMATIONS OF VERIFICATION
l, Christopher Cross, do herein affirm and attest that I am the Petitioner requesting and
seeking the removal of the named Respondents in the above petition, and that I file my petition
without malice, without agenda, without beneflts or other consideration, and without interests in
stake of appointment or employment.
I further affirm and attest that the claims, assertions, statements and allegations in both
my petition, my forensic Revised lnvestigative Report and my ten (10) page typed audit of the
MCHR website pages, are true and correct, based on the known evidence, reasonable informa-
tion and reasonable belief, any and all reasonable inferences that can be drawn therefrom, and
in my researching state laws, city ordinances, city Charter provisions, case law rulings, media
reports, public records, and electronic mails, that I received from and that I sent to city officials
and Respondents whether individually or collectively.
I also affirm and attest that I have reasonable cause to believe that I have a meritorious
and submissible cause of action against the Respondents, whether individually or collectively for
their removal by impeachment, and that impeaching them is the just and prudent course of act
or actions to take based on the evidence, statements in public meetings, and their conduct.
Finely, I affirm and attest that based on the known evidence, reasonable information and
reasonable belief, any and all reasonable inferences that can be drawn therefrom, and in my re-
searching state laws, city ordinances, city Charter provisions, case law rulings, media reports,
public records, and electronic mails, that I received from and that I sent to city officials and Re-
spondents whether individually or collectively, the Respondents, whether individually or collec-
tively violated one or more state laws, one or more city ordinances and one or more provisions
of the city Charter, whether directly, indirectly, proximately or by acting in concert with another.
Respectfully submitted,
C hui"t$r'.,l"srs- t s.cxL
Cfrrisiopner Cross, Petitioner
Secretary of State Pafiicipant # 430039
P.O. Box 1409
Jefferson City, MO 65102

13. CERTIFICATE OF SERVICE
I, Christopher Cross, affirm that on the 26th day of February 2024,1 provided a true and
complete copy of the above petition, to the parties below and by hand delivery to the City Clerk
of the City Springfield, during the regular order monthly meeting of the City Council.
l, Christopher Cross, further affirm that my Revised lnvestigative Report was previously
submitted to City officials either directly or by and though the City Clerk, Custodian of Records,
on February 19, 2024, by electronic mail, and I delivered a copy to Respondents Charity Jordan,
Mike Garton, Rachel Naab and Chase Snider on the same date, means and manner. The re-
maining Respondents are served a copy by attachment to the petition they receive.
City Council (Collectively) Respondent Charity Jordan Respondent Gail Herbert
840 North BoonvilleAve. 840 North BoonvilleAve. 840 North BoonvilleAve.
Springfield, MO 65802 Springfield, MO 65802 Springfield, MO 65802
City Attorney Jordan Paul
840 North Boonville Ave.
Springfield, MO 65802
City Manager, Jason Gage
840 North Boonville Ave.
Springfield, MO 65802
Director Taj Suleyman
Diversity, Equity & lnclusion
840 North Boonville Ave.
Springfield, MO 65802
Respondent Mike Garton
840 North Boonville Ave.
Springfield, MO 65802
Respondent Chase Snider
840 North Boonville Ave.
Springfield, MO 65802
Respondent Jasmine Allen
840 North Boonville Ave.
Springfleld, MO 65802
Respondent Jamea Crum
840 North Boonville Ave.
Springfield, MO 65802
Respondent Rachel Naab
840 North Boonville Ave.
Springfield, MO 65802
Respectfully submitted,
Christopher , Petitioner
Secretary of State Participant # 430039
P.O. Box 1409
Jefferson City, MO 65102

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15. SWORN AFFIDAVIT OF
GARRETT MEES
l, Garrett Mees, do hereby make my forlhcoming declaration of statements and claims under oath and
penalty of perjury, and affirm thai my staternents and claims are true to the best of my knowledge and belief,
and are *uppo*eO by a series of eleitronic mail communications sent to and received from Mike Garton'
I believe tVlr. Garlon's actions consisting of deflection, subterfuge, and gas-lighting tactics, are, based
on the totality of the electronic mails and the freponderance of the evidence, that either Mr. Garton is either
completely inept in his duties or complicit witlr the maleficence of the Ivlayor's Commission on Human Rights
and'Communiiy Relations, as a whoie body and/or the individual Respondents named in Christopher Cross'
petition.
For example, but not limited to, Mr. Garton asserting he performed due diligent research to ascertain
the truth of the evidence and Mr. Cross' forensic investigative repo(, and he found that no illegal and/or unlaw-
ful acts were done by Respondents. However, as one example only, based on the evidence and the prepon-
derance of such.
One example is that on February 21, 2024, ItIr. Garton sent me and Mr. Cross an electronic mail time
and date stamped at 12.51 PM, in which he wrote, "[a]t the time of the February Meeting, Mr. Furtak had not
yet been sworn in and the committee existed of 7 members, therefore by your own analysis, that was a quo-
rum."
However, during the Februa ry 21, 2024, Commission meeting the City of Springfield admitted that lVlr.
Cross is right in his allegations and assertions the February 12, 2A24, Commission was illegal andlor unlawful
because it did not contain the required quorum.
ln spite of this, on February 2?, 2A24 at 04:03 PM, Mlr. Garton wrote in his final electronic mail to both
me and Mr. Cross that because a new Commissioner, Dan Furtak was sworn in on short notice and purpo(-
edly no Respondent, the Director of Diversity, Equity & lnclusion and his assistant had no knowledge about this
ociurring, and given a new vote was taken on February 21, 2A24, then no harm * no foul occurred and the
February 12,2A24, meeting not illegal and/or unlaMul.
Based on amount of time and effort that I applied, and based on my experiences as a School Board
member since 2010 and my being a member of the Special School District Governing Council, in St. Louis, it is
my belief that Mr. Garton summarily dismissed and ignored my professional opinion as a publicly elected gov-
ernment official, as well as the extensive efforts the Petitioner went to educate MIr. Garton, the inability and/or
the unwillingness of IMr. Garton to acknowledge the errors of the situation, combined with the arrogance of ftl'lr.
Garton in continuing to deny the facts and truth about the situations occurring, in efforl and attempt to shield
the Respondents and himsetf from culpability, I believe he does not have the capacity to retain his position as a
Commissioner
3715 Risch Avenue
St. Louis, Missouri 63155
{314) s23-5625
STATE OF MISSOURI
COUNTY
to before me day of February 2024,
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