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5/8/2018 5:05 PM
ERIN CARTWRIGHT WEINSTEIN
Clerk of the Circuit Court
Lake County, Illinois
EXHIBIT C
IN THE CIRCUIT COURT OF THE NINETEENTH JUDICIAL CIRCUIT
LAKE COUNTY, ILLINOIS
CHANCERY DIVISION
Plaintiffs,
Defendants.
I, John Boch, pursuant to 735 ILCS 5/2-1005, Ill Sup. Ct. R. 191, and 735 ILCS 5/1-109,
state as follows:
I could and would testify to the truth of the matters set forth herein.
2. I am the Executive Director of Guns Safe Life, Inc. (“GSL”), and I have held this
position since 2015. I served as the president of GSL from 2010 to 2014 and as vice president for
over a dozen years prior to that. I am the editor emeritus of GunNews Magazine, the monthly
journal of GSL, which has a circulation of roughly 20,000+ copies. I am also a member of GSL.
4. At least one GSL member who resides in the Village of Deerfield holds a valid
Firearm Owner’s Identification Card and Concealed Carry License. This individual owns one or
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more magazines that qualify as “Large Capacity Magazines” under Ordinance O-18-06 as well
as a handgun that accepts such magazines. The magazine and handgun in question were lawfully
acquired by the GSL member prior to April 2, 2018. This individual is not a law enforcement
officer or agent or employee of any government, a member of the military, or a retired law
enforcement officer. This individual keeps the magazine and handgun in question at home in
possession of magazines capable of holding more than 10 rounds, prior to June 13, 2018, the
Deerfield resident and GSL member described in the preceding paragraph will do one of the
following with the magazine in question: (1) remove, sell, or transfer it from within the limits of
the village; (2) modify the magazine to render it permanently inoperable or so that it permanently
no longer qualifies under Ordinance O-18-06’s definition of a “Large Capacity Magazine”; or (3)
surrender this magazine to the Deerfield Chief of Police or his or her designee for disposal.
6. At least one GSL member who resides in Deerfield owns a firearm that qualifies
as an “assault weapon” under Ordinance O-18-06’s definition of that term and keeps this firearm
at their home in Deerfield. They acquired this firearm prior to April 2, 2018 and would continue
7. In accordance with Ordinance O-18-06 § 15-90, prior to June 13, 2018, the GSL
member described in the preceding paragraph will be required to do one of the following with
the firearm in question: (1) remove, sell, or transfer the firearm from within the limits of the
village; (2) modify the firearm to render it permanently inoperable or so that it permanently no
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longer qualifies under Ordinance O-18-06’s definition of an “assault weapon”; or (3) surrender
this firearm to the Deerfield Chief of Police or his or her designee for disposal.
permanently alter their lawfully acquired magazines and firearms, they will be irreparably
harmed by the ongoing deprivation of their right to possess and use commonly used magazines
and firearms.
themselves of or permanently alter magazines and firearms that they lawfully acquired and
possess, they will be irreparably harmed by the unconstitutional taking of their property without
government compensation.
10. Because Ordinance O-18-06 will force GSL members to give up possession of or
permanently alter magazines and firearms that they lawfully acquired and possess, the law strips
these magazines and firearms of their use. GLS members will be irreparably harmed by the
unconstitutional taking of their lawfully acquired and possessed property without government
compensation.
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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 instrument are true and
correct.
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EXHIBIT D
IN THE CIRCUIT COURT OF THE NINETEENTH JUDICIAL CIRCUIT
LAKE COUNTY, ILLINOIS
CHANCERY DIVISION
Plaintiffs,
Defendants.
I, John “Jack” William Wombacher III, pursuant to 735 ILCS 5/2-1005, Ill Sup. Ct. R.
personal knowledge and, if called as a witness, I could and would testify to the truth of the
4. I am a law-abiding adult who is not prohibited from owning firearms under the
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7. Prior to April 2, 2018, I lawfully acquired a magazine capable of holding more
than 10 rounds in accordance with state and federal law. This magazine has not been temporarily
altered to be incapable of accepting more than 10 rounds, it is not a .22 caliber tube ammunition
feeding device, and it is not a tubular magazine contained in a lever-action firearm. I keep this
magazine at my home in Deerfield for use in a handgun, which I also acquired prior to April 2,
2018 and keep at my home in Deerfield for self-defense. I selected this particular magazine in
part because I believe that a firearm with a magazine capable of holding more than 10 rounds is
and to keep them at my home in Deerfield. But Deerfield officials have said that Ordinance O-
18-06 prohibits possession of such magazines. Accordingly, I will not acquire additional such
magazines so long as Ordinance O-18-06 remains in effect and no court has said that possession
9. But for Ordinance O-18-06, I would possess a magazine capable of holding more
than 10 rounds within the Village of Deerfield for lawful purposes, including in-home self-
defense and hunting, after June 12, 2018. If this Court declares Ordinance O-18-06 invalid or
otherwise enjoins enforcement against possession of magazines capable of holding more than 10
rounds, I will continue to possess such magazines within the Village of Deerfield.
10. Because Deerfield officials have indicated that Ordinance O-18-06 bans
possession of magazines capable of holding more than 10 rounds, prior to June 13, 2018, I will
do one of the following with my magazine: (1) remove, sell, or transfer it from within the limits
of the village; (2) modify the magazine to render it permanently inoperable or so that it
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Magazine”; or (3) surrender this magazine to the Deerfield Chief of Police or his or her designee
for disposal.
11. I own an AR-15. I selected this particular firearm in part because I believe it is a
very good firearm for self-defense and can also be used for hunting. This firearm qualifies as an
“assault weapon” under Ordinance O-18-06’s definition of that term, and its possession in
Deerfield is accordingly prohibited. But for Ordinance O-18-06, I would keep this firearm at my
12. I wish to purchase additional firearms that qualify as “assault weapons” under
Ordinance O-18-06’s definition of that term and keep these firearms at my home in Deerfield for
self-defense and hunting. But Ordinance O-18-06 prohibits possession of such firearms in
Deerfield. Accordingly, I will not acquire additional such firearms so long as Ordinance O-18-06
13. In accordance with Ordinance O-18-06 § 15-90, I have been required to do one of
the following with my AR-15: (1) remove, sell, or transfer this firearm from within the limits of
the village; (2) modify the firearm to render it permanently inoperable or so that it permanently
surrender this firearm to the Deerfield Chief of Police or his or her designee for disposal.
14. But for Ordinance O-18-06, I would possess an AR-15 within the Village of
Deerfield for lawful purposes, including in-home self-defense and hunting. If this Court declares
Ordinance O-18-06 invalid or otherwise enjoins enforcement, I will possess an AR-15 within the
Village of Deerfield.
alter my magazine capable of holding more than 10 rounds and my AR-15, I will be irreparably
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harmed by the ongoing deprivation of my right to possess and use commonly used magazines
permanently alter a magazine and firearm that I lawfully acquired and possess, I will be
compensation.
permanently alter magazines and firearms that I lawfully acquired and possess, I believe the law
strips my magazines and firearms of their use. I will be irreparably harmed by the
compensation.
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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 instrument are true and
correct.
Date:_______________________
__________________________
John William Wombacher III