Verified complaint seeking Bitter Smith ouster from Corp Comm Updated with 2nd video 1:20am MST 9-3-15

As promised, attorney Thomas Ryan, acting on his own behalf, filed a verified complaint at the Office of the Arizona Attorney General this morning.

This image has the opening paragraph of the 25-page complaint.

It states:
Thomas M. Ryan, a citizen, a taxpayer, a ratepayer, and elector of the State of Arizona, submits his Verified Complaint Quo Warranto to the Attorney General of the State of Arizona to remove Commissioner Susan Bitter Smith from the office of Commissioner of the Arizona Corporation Commission. Commissioner Bitter Smith has engaged in substantial violations of A.R.S. § 40-101 which make her a usurper of the office. In addition, her conduct has violated A.R.S. § 38-503. This verified complaint is submitted pursuant to A.R.S. § 12-2041.

A.R.S. §40-101 establishes the law concerning conflict of interest by a Corporation Commissioner. A.R.S. §38-503 further expounds on conflict of interest by any public officer or employee of the State of Arizona. And A.R.S. §12-2041 states,

A. An action may be brought in the supreme court by the attorney general in the name of the state upon his relation, upon his own information or upon the verified complaint of any person, in cases where the supreme court has jurisdiction, or otherwise in the superior court of the county which has jurisdiction, against any person who usurps, intrudes into or unlawfully holds or exercises any public office or any franchise within this state.

B. The attorney general shall bring the action when he has reason to believe that any such office or franchise is being usurped, intruded into or unlawfully held or exercised.

This complaint would seem to present Attorney General Brnovich, pursuant to Arizona law, an obligation to initiate legal action to remove Bitter Smith from office unless he determines that the evidence presented does not demonstrate that she has violated the conflict of interest statutes.

I have video from today's press conference and pdf files of the 40 exhibits attached to the verified complaint. When I get those posted, I will update this post to provide links thereto.

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UPDATE 1 -- 2:55 pm, 9/2/15

You may read each (any or all) of the 40 exhibits at this link. Video uploading at this time.

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UPDATE 2 -- 1:20 am, 9/3/15

A The second video is now finished uploading. Tom Ryan answers questions about the complaint after filing it.