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COUNTY of WAKE
ACTION IN PERSONAM
TO ESTABLISH MEMBERSHIP OF
COUNCIL OF REVIEW OF THE
NORTH CAROLINA DEMOCRATIC PARTY
John C. Brooks
516 North Blount Street
Raleigh, N.C. 27604
Jannet B. Barnes
1609 Cotton Street
Knightdale, N.C. 27545
William A. Franklin
806 Warwick Court
Burlington, N.C. 27215
Carolyn Q. Perry
103 Perry Lane
Marston, N.C. 28363
Michael A. Lawson
6838 Charette Court
Charlotte, N.C. 28215
Dr. Barbara Ann Hughes
4208 Galax Drive
Raleigh, N.C. 27612
_______________________________________
PLAINTIFFS
VS.
Lonnie Baucom
105 Brent Street
Wadesboro, N. C. 28170-2204
Ryan Townsend Butler
337 Gorrell Street
Greensboro, N.C. 27406-1635
1
District Conventions; and four members appointed by the chair of the State Democratic Party who serve
two-year terms co-terminus with the Congressional District Conventions that elect the thirteen
members.
Plan of Organization Section 9.02.
9.02 Composition
Members. The Council of Review shall consist of one (1) member from each congressional district who
shall be elected at the congressional district convention held in even-numbered years, and four (4)
members at-large to be appointed by the state chair.
....
Terms. Terms for members of the Council of Review shall begin upon the date of their election or
appointment and end on the date in the next even-numbered year set for district conventions or until
their successors are [duly] elected or appointed.**
**The terms of the appointed members of the Council of Review were confirmed by a letter of
understanding issue by the chair of the State Democratic Party in 2014 when he was appointing his four
members to the Council of Review.
CONGRESSIONAL DISTRICT CONVENTIONS
The Congressional District Conventions are constituted by delegates elected by the County
Conventions that are located within each of the established Congressional Districts established by the
North Carolina General Assembly. The maximum number of delegates elected is determined by the
vote cast in the previous gubernatorial election for the Democratic candidate for Governor.
Plan of Organization Sections 6.01
When and Where Held. An annual congressional district convention shall be held within the
geographical boundaries of each congressional district each year. . . . .
....
Order of Business Even Numbered Years. The congressional district convention held in evennumbered years shall: . . . .
2. Elect from among the active Democrats, one member of the Council of Review;
....
4. In each presidential election year, from among the active Democrats in the congressional district,
the number of delegates first and then alternates to the Democratic National Convention allotted to
each congressional district;
5. In each presidential election year, nominate from among the active Democrats in the Congressional
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District, one Presidential Elector from the congressional district; and then
6. Adopt the method for reviewing, editing, consolidating, adopting, and prioritizing resolutions most
appropriate for the district party that is best suited to district needs,
. . . .
This action arises from the occurrence of 13 Congressional District Conventions that were held
Saturday, May 21st, 2016 all across North Carolina at which members were elected to membership on
the Council of Review. These Congressional District Conventions were all constituted on the basis of
the North Carolina Congressional Districts that preceded the action by the North Carolina General
Assembly dissolving the existing Congressional Districts effective February 19, 2016 and establishing
new and different Congressional Districts effective as of February 19, 2016. Although there was a
judicial action filed challenging the Congressional Districts established by the General Assembly
February 19, 2016, there was no stay authorized stopping the implementation of these new districts
pending a judicial decision. [In fact, the judicial decision finally rendered upheld the earlier legislative
action.] The 13 Congressional District Conventions held May 21st, 2016 all acted without having
appropriate credential committees and therefore without any of these conventions having adopted
appropriate credential reports. None of these Congressional District Conventions were legally
constituted pursuant to the requirements of Plan of Organization of the North Carolina Democratic
Party. The Congressional Districts that they represented had all been dissolved months earlier. No
appropriate and legal Congressional District Conventions have since been convened.
THE 2014 COUNCIL OF REVIEW
The 2014 Council of Review is composed of the following members:
Mary Ebert Ostgaard
Charles R. Wallin
Andrew Ivester
Hughes A. Wilde
Carolyn Q. Perry
Jens L. Lutz
Michael A. Lawson
Carl K. Bond
Barbara Ann Hughes
Michael Shaul
John C. Brooks
Jannet B. Barnes
William A. Franklin
Nancy F. Clark-Shakir
Willie Fleming
Corine Mack
Signed:
Barbara Ann Hughes
Subscribed, sworn and acknowledged before me by Barbara Ann Hughes, plaintiff, this 27th
day of June, 2016.
___MARY PAINTER__
Notary Public
My Commission Expires October 9, 2019.
[SEAL]
[Additional Notarized Signatures for
Jannet B. Barnes; Michael A. Lawson; Carolyn Quick Perry,
John C. Brooks; and William Acree Franklin;
CERTIFICATE OF SERVICE
I hereby certify that copies of the foregoing Action were served upon each of the defendants this day
by mailing a copy thereof by certified mail, receipt requested, postage prepaid addressed as follows:
Lonnie Baucom
105 Brent Street
Wadesboro, N. C. 28170-2204
Ryan Townsend Butler
337 Gorrell Street
Greensboro, N.C. 27406-1635
William Darsie Carter
1431 Longleaf Court
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____________SIGNED____________
John C. Brooks