North Carolina Democratic Party

Council of Review
220 Hillsborough Street
Raleigh, NC 27603

Petitioner 1. Perry Graves, Member

African-American Caucus Rockingham
County Democratic Party AAC-NCDP
365 Brooks Rd. Reidsville, NC 27320
336-432-4788; theperryg@hotmail.com
Petitioner 2. Valeria Conyers,
2nd Vice President AAC-NCDP
702 Lake Shore Dr. Goldsboro, NC 27534
919-750-2242; valgma4@hotmail.com
Petitioner 3. Chenita Johnson, 1st Vice President
African American Caucus Forsyth County Democratic Party (AAC-FCDP)
2411 N PATTERSON AVE WINSTON SALEM, NC 27105
; chenitajohn@hotmail.com, and
The attached names and signatures of additional Petitioners
of NC Democratic Party members from 52 African-American Counties, Specifically,
Halifax, Edgecombe, Wilson, Nash, Mecklenburg, Pitt, Guilford, Rockingham,
Alamance, Durham, Orange, Granville, Chatham, Roberson, the State African
American Caucus Auxiliary, African-American Caucus of Union County Democratic
Party, African-American Caucus of Wayne County Democratic Party, African-American
Caucus of Forsyth County Democratic Party and Various African-American Caucus
County Members, and other NC Minority Caucus Auxiliary and Democratic members et al

Petitioners

VS

NCDP Chairperson Patsy Keever-Aycock, individually and

17 Braddock Way, Asheville, NC 28803
E-mail address: patsykeever@gmail.com
Phone No. 828-274-0114, and collectively
All other SEC Elected Executive officers, named and unnamed participants in rendering
the decisions in the Hardee, Dylan Fisk cases and the Council of Review Petition and decisions.

Respondents

VERIFIED GRIEVANCE and PETITION FOR REMOVAL FROM OFFICE

ARISING UNDER SECTION 6, 9, 10 and 11 OF THE NCDP PLAN OF
ORGANIZATION
Petitioners Grievance pursuant to Section 6.01 and 9.01, and the Petition arise Under
Section 6.01, 9.01-09, 9.06, 10.01-04, 11.02 and in accordance with Section 4.05 Duties of
the State Chair and Certain Officers of the Plan of Organization (POO)
Party Officer sought to be removed: Patsy Keever Aycock and all of the Elected Executive
officers, named and unnamed participants that conspired in rendering the decisions in the
Hardee, Dylan Frick cases, as well as the Council of Review Petition.
Position sought to be vacated: Chair, Patsy Keever Aycock, of the North Carolina Democratic
Party (NCDP), Zack Hawkins 1st VP, Valeria Levy 2nd VP, Andy Ball 3rd VP, Melvin Williams
Secretary and other Elected Executive Council officers, named and unnamed participants that
devised a scheme to disregard and/or complying with the essential elements adopted in the NC
constitution, the provisions of the North Carolina Democratic Party (NCDP) Plan of
Organization (POO), Roberts Rules of Order, and for knowingly conspiring to overlook the rule
of law when they rendered unfair, bias and partial decisions in the Hardee, Dylan Fisk cases,
and their wrongful acts and conduct in rendering decisions in the Council of Review Petition.
Most relevant witnesses: Same as signatories to petition for removal, plus the list of named
Individuals attach hereto the Verified Petition and each of the NCDP elected executive officers
named herein this petition. There are approximately 125-250 plus petitioners and witnesses
from roughly 25 to 46 NC Counties, depending on the particular allegation stated in the
Petition, and the attached signatures as filed herein and as follows or thereafter before the
hearing. Specific witnesses are Lee and Diane Littles Union County, NC resident voters,
Gracie Galloway, former NCDP 8th District Chairperson, Ryan Butler, Ms. Amy Strange,
Deputy Director of the State Board Of Election (SBOE), Ms. Eursula Gwyniece George, SBOE,
Sheryll A. Harris, SBOE Compliance Specialist, Willie Fleming as a Charlotte, NC resident
voter, NC State Senators Floyd Mc Kissick (D-Durham), NC State Senator Angela Bryant (DNash) and Don Davis, Keisha Lovelace, Esq. an attorney and a Wake County, NC resident
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voter, Linda Daniels a Wayne County, NC resident voter , Sondra Smith-Merida a Charlotte,
NC resident voter, Vice President of Fifth Third Bank, Valeria Levy, Charlie Reece, former
NCDP treasurer, Melvin Williams current NCDP Secretary, Betty McCain Wilson County
chairperson, NC Pitt County Commissioner, Mary Perkins Williams; James Powell, a Wake
County, NC resident voter; Barbara Mc Koy, Commissioner and NC resident voter, Reggie
Elliott a Pitt County, NC resident voter, Ms. Ernestine Wotten, Wayne County, NC Democratic
Chairperson and resident voter, Hope Hart Wayne County resident voter, Eunice Delores Jones,
Wake County Resident voter, and others as stated herein and the unnamed and unknown at time
of filing. Especially Each of the installed 46 County and 13 congressional District chairpersons
that held 2016 conventions May 21, 2016, when they each knew or should have known, that the
Court had ruled/decided the NC congressional districts were unconstitutional, violate the 14th
Amendment of equal protection and violated the Voting Rights Act; that they be redrawn and
filed with the Court no later than Feb. 19, 2016. The 13 congressional Districts were redrawn
and the State Board of Election (SBOE) did comply with the Court order and prepared the 13
Congressional District for elections to take place. Yet, the NCDP Chairperson Patsy Keever
Aycock, and the State Elected Executive Committee and Council directly/indirectly refused and
disregarded the Courts rulings, decision and order, as is more clearly identified and stated
herein this Grievance and petition.
COMES NOW THE ABOVE NAMED AGGRIEVED active Democrat Petitioners and
Grievant members respectfully move the North Carolina Democratic Party (NCDP), State
Executive Committee (SEC) Elected Officers and Executive Council members via 1st Vice
Chairman Zack Hawkins, and the Council of Review Chairman John Brooks to receive this
Verified Grievance and Petition of factual and documentary evidence, pursuant to NCDP Plan
of Organization (POO) Section 6.01, 9.01, 9.06, 10.1, 10.2. 11.1.
The Petitioners, representatives from/of the family/friends and neighbors, of the 53 NC African
American Democratic Counties, herein set forth in full and complete detailed verifiable facts
and evidence against Respondent Patsy Keever-Aycock and her conspirators and participants
herein named and unnamed respectfully states as follows:
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Grounds for Removal:

1. NCDP Chairperson Patsy Keever-Aycocks wrongfully, direct/indirect, without authority,
deliberately and recklessly imposed her personal and family designed racial discriminatory
practices against the AAC-NCDP Auxiliary Caucus Administration and Operation. The
following identified grounds herein this Grievance and Petition, are as alleged:
A. As an officer and/or committee member of the Democratic Party level, the Chairperson, Patsy
Keever-Aycock, failed and/or refused to perform her required duties, as stated herein and pursuant to
NCDP Plan of Organization (POO) Section (s) 4.3, 4.5, 4.6, 4.8 (7), 9.01, 9.06 and 10.01, 10.02.
Exhibit

1 Points of Authority

B. As an officer and/or committee member of the Democratic Party level, the chairperson directly or
indirectly, gave support and aid to Dylan Frick who was convicted of a crime of moral turpitude.
The Chairperson manipulated and conspired to wrongfully have ex Parte communications with
Respondent Dylan Frick and others to persuade and influence a majority vote decision from the State
Executive Council members; that the facts and evidence in the Petition from the 8th District residents
and voters against Respondent Dylan Frick did have Sufficient Merit to warrant a full hearing.
Such intentional, wrongful and deliberate conduct on the part of Chairperson Keever Aycock, was
violative of the POO provisions, requires removal of the Chairperson of NCDP. See Exhibit 2
Decision of Dylan Frick case.
C. It appears from the basic facts now known, contained in this Verified Grievance and Petition, and
other cases on file, did raise issues and matters which cause grievous damage and harm to NC
African American Caucus and minority Voters liberty, civil rights and social justice (social
inequality). To include, but not limited to Direct disenfranchisement (explicitly prevent African
American and other minority voters from voting or having their votes counted) and/or indirect
techniques which attempt to prevent NC African American Caucus and minority voters votes from
having an impact on political outcomes such as holding the NC 13 Congressional District
Conventions and conduct election of Delegates and Members of the NCDP Council of Review from
the 13 congressional Districts the Federal Court decided and ruled unconstitutional, violate the 14
Amendment of equal protection, and violate the voting Rights Act. (e.g., gerrymandering, ballot box
stuffing (fraud), stripping elected officials of their powers)
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D. The Chairperson failed/refused to monitor and ensure the Chair of Minority Affairs served as a
liaison between the party and the Democratic Minority African-American Auxiliary Caucus, the
Native American communities and other minority voters in the state of North Carolina. Also, the
Chairperson Keever Aycock failed and/or refused to invite and encourage the AAC Auxiliary
Caucus, and did deliberately deny the Auxiliary and its members the opportunity to fully participate
and be represented in all NCDP party affairs. The Chairperson totally ignored AAC and other
minority Auxiliary Caucuses invitations and inquiries sent/delivered to her and other NCDP
executive officers and staff, requesting their attendance in Auxiliary meetings, concerns, or
educational sessions conducted by AAC and other minority (Asian American Pacific Island,
Hispanic American Caucus) Auxiliaries. Although, the NCDP Chairperson Patsy Keever-Aycock is
duty bound, she fail/refused to perform her duties in these respects as indentified in the POO Section
4.05 mandate. Such acts and conduct by Chairperson Keever Aycock, are clear and ever-present
violations of the POO, she deliberately failed to perform her duties, and totally ignored her
Democratic Party Oath of Office. See Exhibits 4 and 4A memo letter from AAC-NCDP president
Brandon Johnson in response to 4-A NCDP chair Patsy Keever Aycock stating AAC-NCDP
Aug. 1 meeting was not an authorized called meeting.
E. NCDP Chairperson Keever Aycocks deceitful manipulation, fraudulent acts, deliberate disruption
and obstruction of the AAC Auxiliary Voter Political Education programs for the member County
Caucus communities are just a few of her negligent acts and destructive conduct that did
directly/indirectly affect and violated their equal protection and denied their voting rights. NCDP
Chairperson Keever Aycocks along with her accomplices, daily plan of action targeted various AAC
Auxiliary County Caucuses to discourage and ignore rather than encourage, the 53 NC Counties of
under represented resident voters, and/or its groups to participate in the NC Political and delegate
process, among other functions. Such acts and conduct by the chairperson Patsy Keever Aycock and
her accomplices are akin to excluding NC AAC Auxiliary voter communities similar to that which
has been demonstrated in Ferguson, Ill. Especially, May, 2015, dated July 22 published 24, 2015
unauthorized abuse of authority memo letter from chair Patsy Keever Aycock, August 2015, October
4, 2015, November 14, 2015 meeting/program wherein the DNC hosted and/or participated in. Such
acts and conduct by the Chairperson Patsy Keever Aycock, are clear and ever-present violations of
the POO, civil rights, social justice, and her oath of office.
F. Chairperson Patsy Keever Aycock, refusal, directly or indirectly to comply with the provisions of the
Plan of Organization (POO), her failure or, and her having deliberately written, without authority, a
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fraudulent letter recognizing Willie Fleming and Linda Daniels, as the President of the AAC-NCDP
Auxiliary, was clear and ever present fraud, deceitful and manipulation. See Exhibit 4-A NCDP
chairpersons unauthorized published 7-24-2015 Memo letter
G. NCDP Chairperson Patsy Keever-Aycock promoted divisiveness by interfering in AAC-NCDP
Executive Officers disciplinary decisions. The Chairperson knew or should have known the NCDP
POO did not: 1.) authorize her to entertain, address or receive a verbal Appeal from Willie Fleming,
or Linda Wilkinson Daniels or resolve any Auxiliary Caucus grievance, dispute or controversies, 2.)
authorize her to appoint, elect or recognize Willie Fleming (or any individual) as President of any
Auxiliary officer or as an elected official. Yet she wrongfully ignored and refused to comply with the
POO provisions, as stated in Section 4.08 (7) and 9.01. See Exhibit 1 POO provisions 4.08 (7), 9.01
Points and Authority.
H. AAC-NCDP Auxiliary in the midst of attempting to rectify the damages and resolve their internal
grievance (regarding malfeasance and fraud issues), the NCDP chairperson Keever Aycock ignored
the POO provisions. Chairperson Keever Aycock, without authority, did aid, abet and encouraged
Willie Fleming and Linda Daniels to run rampant across the State of NC, in violation of the AACNCDP By-laws, dividing the organized County Auxiliary Caucuses, improperly/illegally collecting
monies under false pretense and auspices (selling AAC-NCDP Auxiliary endorsement) while serving
as President and 1st VP of the AAC-NCDP Auxiliary. Such wrongful and illicit behavior is not the
caliber or type of integrity and character the AAC Auxiliary or NCDP desires or condones.
Chairperson Keever Aycock without personal knowledge, wrongfully condoned said acts, conduct
and behavior, and she refused to give full faith and credit to AAC Auxiliary Caucus Elected
Executive Officers disciplinary decisions. Such acts and conduct on the part of the Chairperson is a
clear and ever present non-compliance with the POO provisions. Additionally, NCDP chairperson
Keever Aycock created a false and fraudulent letter for Willie Fleming and Linda Daniels to use as a
means to intimidate and threaten registered certified County Auxiliary Caucuses to join his/her rogue
group. The Chairperson in concert with Willie Fleming and Linda Daniels deliberately, directly
and/or indirectly, without authority, deceitfully called various certified, and unregistered AAC
Auxiliary Caucus for improperly noticed meetings in Wake, Wayne, Lenoir and Wilson Counties
sowing seeds of discord and turmoil to include issuing false intimidating letters to NCDP
Congressional or District County chairpersons alleging, an AAC-NCDP County Caucus is suspended
or on suspension.

I. NCDP Chairperson, Patsy Keever-Aycock deliberately encourage a divisive leadership battle

between Fleming vs Brandon Johnson, Linda Daniels vs Jannet Barnes AAC Auxiliary Presidents to
hinder AAC Auxiliary Caucus from protecting its integrity and Character as established pursuant to
their By-Laws. Chairperson Keever Aycock directly and indirectly deliberately refused to comply
with the POO Section 002, failed/refusal to perform her duties indentified in the POO Section 4.05
(10, 11, 12 and 20). Such reckless, yet intentional acts, conduct and behavior on the part of
Chairperson Keever Aycock are grounds for removal. See Exhibit 1 Points and Authority
J. Chairperson Keever Aycock solicited and enrolled NC State Senators Floyd Mc Kissick, Don Davis,
Paul Lowe, Larry Hall and NC House of Representative Rodney Moore to conspire and sow seeds of
discord among the African-American NC House of Representatives and Senators, under the false
pretense and auspices of resolving the false concocted dispute and controversies in the 53 African
American County communities. The Chairperson Keever Aycock and other NCDP members,
especially Senator Floyd Mc Kissick, conspired to mislead and misrepresent the 53 impoverished
African American county communities. Senator Floyd Mc Kissick misled Medicaid enrolled seniors
and low income families with children, including the physically and mentally disabled citizens, in
need of NC health care programs, and sort to hood-wink said NC citizens to benefit the-for-profit
medical care business. See Exhibit 5 news article of Senator Floyd McKissick Medicaid to for profit
contractors.
K. The Chairperson directly/indirectly intentionally and deliberately created turmoil, within the AACNCDP Auxiliary communities, which caused irreparable harm and damages to the NC AfricanAmerican Caucuses and the N C and National Democratic Party institution as a whole. Such conduct
and behavior was in total opposition to the POO/By-Laws Section 002. The Chairperson deliberately
failed/refused to perform her duties indentified in the POO Section 4.05 (11). The Chair Keever
Aycock directly/indirectly fostered false representations and deceitful interpretation of AAC
Auxiliary By-Laws Article 7 and NCDP Plan of Organization Section 3.4 and 10.4 by State senator
Don Davis unethical/illegal conduct and behavior towards an AAC-NCDP Wayne County Caucus
officer. He was also accompanied by Pitt county Commissioner Mary Perkins, and the removed
AAC Auxiliary former member Linda Daniels. These named individuals worked in concert with
Willie Fleming, as he and Linda Daniels continued to engage in unethical/illegal conduct and
behavior. Such as selling the AAC-NCDP endorsements (for a fee) to political Candidates, issue
threats, coercion, fraudulent representation and voter intimidation thereby causing mental and
emotional damages to AAC County Caucus Auxiliary members, which ultimately placed Valarie

Conyers under duress, and force her to submit a resignation from African American Wayne County
Democratic Party Caucus as Secretary? See Exhibit 3 memo letter from Valarie Conyers
L. NCDP Chairperson, Patsy Keever-Aycock deliberately directly/indirectly obstructed AAC-NCDP
Auxiliary Caucus management and Audit of their Auxiliary Caucus funds. Specially to aid and abet
Willie Flemings to remove $1,800 of AAC-NCDP funds without the knowledge or authorization of
the Elected officers. Such acts and conduct on her part are grounds for removal. See Exhibit SBOE
document of $1,800 Willie Fleming mismanaged AAC-NCDP funds. Candidates solicited by
Fleming and Linda Daniels that paid for AAC-NCDP endorsements.
M. NCDP Chairperson, Patsy Keever-Aycock covertly, directly/indirectly, influenced Willie Fleming,
Linda Daniels, and Sondra Smith-Merida to commit malfeasance, and to violate rather than comply
with the AAC-NCDP Auxiliary by-laws; Willie Fleming with the assistance of the chairperson also
sought out Senator Mc Kissick, Eunice Jones, Mary Perkins Williams, and Barbara McKoy along
with others to conspire, and fraudulently replace three lawfully elected officers (Brandon Johnson,
President, Donna Johnson 2nd VP, Chenita Johnson, Secretary and Perry Graves, Parliamentarian) in
order to hold a fraudulent unauthorized meeting (May 2, 2015) to cover up their wrongful conduct
and violations of the NC State Board of Election regulations and NC state laws. NCDP Chairperson
Patsy Keever-Aycock failed/refuses to perform her duties indentified in the POO Section 4.05 (12)
See Exhibit 1 Points and Authority.
N. NCDP Chairperson, Patsy Keever-Aycock refused to encourage, but rather divisively
disenfranchised AAC Auxiliary Caucus member communities with the intent to deceive, persuade
and encourage a divisive development of a separate, and rogue AAC Auxiliary Caucus within the
NCDP. Another example of the Chairperson Keever Aycock intentionally reckless conduct and
behavior occurred October 4, 2015 wherein a much needed DNC focused group voting rights session
was held and the AAC Auxiliary (some 53 County Caucus communities) was deliberately excluded
from participation. Such conduct is not in accord with the POO Section 002, to perform her duties,
also indentified in the POO Section 4.05 (20). Such acts and conduct by the chair are grounds for
removal.
O. The NCDP Chairperson Patsy Keever Aycock conspired with the State Executive Council, without
authority, and deceitfully provided Willie Fleming an appeal from the AAC-NCDP Auxiliary
decision removing Willie Fleming for malfeasance and illicit acts, conduct and behavior. Such acts,
conduct and behavior on the part of the chairperson Keever Aycock and her participants did usurp
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the authority of the AAC-NCDP Auxiliary, and was not in compliance with the AAC-NCDP By-law
articles and the NCDP POO provisions. See Exhibit 4, 4-A and 4-B Unauthorized Memo Letter
from chairperson Patsy Keever Aycock. See Exhibit 1 Points and Authority
P. NCDP Chairperson, Patsy Keever-Aycock fostered a racist environment in the NCDP not in
accordance with the POO Section 003. The chairperson refuse to give full faith and credit to the
AAC-NCDP lawfully elected Executive Officers disciplinary grievance decisions as the mechanism/
discipline identified in the POO Section 4.08 (7) require. Such acts and conduct are grounds for
removal of the NCDP chairperson. See Exhibit 1 Points and Authority
Q. NCDP Chairperson, Patsy Keever-Aycock failed and/or refused to encourage African American
democratic candidates, but rather attempted to obstruct and prohibit the African American
Candidates from pursuing a candidacy for Public Office. Specifically, but not limited to the elections
in Pitt, Wayne, Wilson and Halifax County, Scotland Neck Precinct, Lt. Governor candidate, U.S.
Senate Candidate and U.S. Congress candidate. These acts, conduct and behavior are grounds for
removal.
R. NCDP Chairperson, Patsy Keever-Aycock directly/indirectly wrongfully manipulated and persuaded
the Elected Executive SEC officers to deny, without proper justification, the Union County African
American democratic community Petition to remove Dylan Frick in spite of his egregious conduct
and behavior. Their Petition had sufficient facts documented with evidence that Dylan Frick was
found guilty of a crime of moral turpitude among other violations of the POO for wrongfully casting
a proxy vote in the 6th Congressional District while remaining as 3rd Vice Chair of the 8th
Congressional District and being registered to vote in, as and casting a vote in 2 different states at the
same period of time. See Exhibit 9 Frick Union Petition and & 9A NCDP Executive Committee
Decision.
S. The preponderance of the preliminary factual evidence was more than required to satisfy the term
Sufficient Merit (probable cause) to believe that a violation had likely occurred; or his/her conduct
was of an egregious nature that required a hearing of the facts and evidence for removal. Dylan
Fricks integrity and character was in question and he could not be a member of the Democratic
Party in good standing as required to hold office in the NCDP. A proper review of the facts and
evidence presented in the petition was Sufficient Merit to warrant a hearing. Such acts, conduct

and behavior on the part of Chairperson Patsy Keever Aycock are grounds for removal. See Exhibit
9-A Frick Petition Decision
T. In the case of the Council of Review (COR) Petition, the preponderance of the preliminary
verified factual evidence was more than required to satisfy the term Sufficient Merit (probable
cause) to believe that a violation had likely occurred; that chairperson Patsy Keever Aycocks
conduct was of an egregious nature that required a hearing of the facts and evidence for removal.
Also, On February 12, 2016, John Brooks left a written and signed request in the NCDP Kimberly
Reynolds, Executive Director, chair at the State Democratic Party Headquarters on Hillsborough
Street. John Brooks, the COR committee chairperson, asked Kimberly Reynolds for copies of all
pending petitions filed for consideration by the Council of Review (COR) as well as up to date
copies of the State Plan of Organization as amended by the State Executive Committee the previous
Saturday, and a list of delegates in attendance at the State Executive Committee meeting held the
previous Saturday. John requested that Kimberly call me as soon as possible, so he could pick this
material up at the Headquarters. Thus far, as of June 5th, 2016, John has not heard anything and
John have not have received anything requested from the North Carolina Democratic Party. John
have also checked repeatedly at the Goodwin House to see if this material is available there with his
name on it and he was told that nothing of the sort has yet been prepared. John and all of the COR
Committee members have been ready willing and able to perform their duties as stated in the POO
provisions. Although, the COR committee members are waiting to perform their duties, it appears
and reasonable to believe the NCDP chairperson Keever Aycock has issued a directive do not
provide any materials, case files and meeting rooms to the COR committee to prohibit the
committee from functioning as required.

The chairpersons integrity and character was and is in question of being a member of the
Democratic Party in good standing as required to hold office in NCDP. A proper review of the facts
and evidence presented by the members of the COR petition was more than Sufficient Merit to
warrant a hearing. Such deceitful and manipulative acts, conduct and behavior on the part of
Chairperson Patsy Keever Aycock and her conspirators are grounds for removal of each of them.
U. The actual decision of the State Executive Committee for the COR Petition clearly stated there
was not sufficient merit to warrant a hearing before the COR when in fact the decision language
further stated there was sufficient merit to understand and satisfy Executive Officers ability and
desire to accommodate the chairperson need to change the POO to allow the NCDP chairperson to
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remove and/or replace the COR members. But, because the current language in the POO did not
permit her to do so, the chairperson and the state executive council decision clearly stated and
suggested the POO be change to accommodate the Chairpersons desire. This decision contradicts
the essence of the original decision. If there were sufficient merit to determine there was a need to
change the POO. then there was also sufficient merit to allow for a hearing simply because the
Chairperson did, without authorization, send a letter removing the COR Chair John Brooks, and
did install a replacement of the COR Chairperson with Ryan Butler, not in accordance with the POO
as fully stated in the Petition filed in accordance with Section 10 of the POO. The Chairperson acts
and conduct should have been based on a preponderance of all the facts and evidence and the POO
which clearly identifies the proper procedures and process to remove or appoint the members of the
COR. Therefore, there was sufficient merit to warrant a hearing that the chairperson more likely
than not did not comply with, and did, more than likely, violate the POO. So the decision on the part
of the State Executive Committee was rendered based on bias, prejudice, and/or undue influence
rather than the facts and evidence before the committee. Such deceitful and manipulative acts,
conduct and behavior on the part of Chairperson Patsy Keever Aycock and her conspirators are
grounds for removal of each of them.
V. The NCDP Chairperson Patsy Keever Aycock ignored the Federal Court Order stating that the NC
Congressional Districts were unconstitutional and violated the Voting Rights Act and the Districts
had to be redrawn. The chairperson having personal knowledge and fully understood that the
Congressional Districts had to be redrawn that no congressional election can be held until the maps
are redrawn. The Federal Court also denied a stay of the Courts original decision. See Exhibit 25
article of the Federal Courts ruling and decision that the NC Congressional Districts were
unconstitutional, violate the 14 Amendment equal protection {clause} and in violation of the
Voting Rights Act.
W. The NCDP Chairperson Patsy Keever Aycock having personal knowledge of the Courts orders held
Press Conferences one (1) Entitled NCDP STATEMENT OF FEDERAL COURT REDISTRICTING
RULING stating Todays decision marks an important step towards ensuring the integrity of North
Carolinas democratic process. Its clear that Republicans in Raleigh have sought to suppress the
vote of those with whom they disagree and rig the electoral process through partisan
gerrymandering. This decision is welcome news that should begin to restore basic fairness to North
Carolinas congressional elections. See Exhibit 26-B

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X. The Chairperson Patsy Keever Aycock having personal knowledge of the Courts orders held Press
Conference two (2) Entitled NCDP STATEMENT ON DENIAL OF STAY IN REDISTRICTING
CASE and stated The Court has now spoken once again, The Republican districts are
unconstitutional and must be redrawn immediately. Is time for Governor Mc Cory and legislative
Republicans to quit stalling and restore integrity and basic fairness to North Carolinas
congressional elections. See Exhibit 26-A
Y. On or about February 17, 2016 the new Congressional Districts were redrawn and filed as ordered
by the Court. See Exhibit 26-.
Z. The NCDP Chairperson Patsy Keever Aycock having personal knowledge of the 13 redrawn
congressional Districts, she deliberately ignored the Courts decision and Directed the Chairpersons
in the 13 unconstitutional Congressional Districts to hold their District Conventions and to conduct
Delegate and other elections knowing full well that the District lines violated both the 14th
amendment of equal protection and the Voting Rights Act. The 13 newly drawn Congressional
Districts were available and the court had not ruled them unconstitutional, or they violated the equal
protection clause of the 14th Amendment equal protection or violated the Voting Rights Act. See
Exhibit 26 NCDP chairperson Press release regarding the two (2) Federal Court Judges
decisions
AA.

The NCDP chairperson Keever Aycock, 6th, 8th, 12th, 4th and the 13th District Chairperson Berger

and her other District Chairpersons/conspirators that wrongfully and deceitfully set out to manipulate
and target various COR committee members to be replaced by/with individuals of their choosing,
and did conduct an unfair election to accomplish the NCDP and District chairpersons directive.
BB.

We incorporate by reference the Complaints, Grievances, and Petitions on filed with the COR

from 2013 to 2016.

2. The NCDP Auxiliary Caucus Petitioners (aggrieved active Democrats) herein state their Verified Petition has
sufficient merit to warrant a full hearing, and respectfully request, pursuant to the NCDP Plan of Organization
(POO) Section 9.1, 9.6 and 10, the Elected Officers of the NCDP SEC call a meeting of the Council of Review
to hear the Petitioner(s), the Respondent, and other interested parties and witnesses identified herein, at the
earliest convenient date.
3. This Verified Petition herein sets forth the Details, creditable facts, allegations and evidence against NCDP
chairperson Patsy Keever-Aycock, and all other (named and un-named individuals that participated in and was
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complicit in the wrongful and reckless acts, conduct and behavior as fully described in detailed herein this
Verified Petition.
4. At various dates and times beginning approximately March and April 2015 through September 26, 2015,
May 26-27, 2015, June 11, 2015, July 26, 2015, August 7, 2015November14, 2015 and other
approximate dates and times as stated in this Verified Petition, to wit:
5. The Petitioners allege Chairperson Patsy Keever-Aycock with deliberate intent, wrongfully interfered with
AAC-NCDPs right to discipline one of its alleged members (Willie Fleming and Linda Daniels) for wrongful,
egregious acts, conduct and behavior. Such deliberately reckless acts and behavior on the part of the
Chairperson directly/indirectly wrongfully blocked the AAC-NCDP Auxiliary Members Constitutional property
rights, civil rights and their rights afforded pursuant to the POO. Such wrongful/ negligent and reckless conduct
by the NCDPs Chairperson ultimately deprived (disenfranchised) the NC African-American member
community their right to vote or select and support African American candidates from their community
without having their candidates being intimidated or dissuaded with such statements as you do not have the
experience and you are not able to raise enough funds, which is nothing more than wink..wink, if you run I
will not support nor allow or encourage NCDP members to endorse or support you. Then the Chairperson and
her co-conspirators would actively search and select another female/male European individual (Deborah K.
Ross) with less or equal experience and knowledge as a candidate prior to the primary election. The
Chairperson also directly/indirectly held a fundraiser for Mrs. Ross See Exhibit 10-10A WordPress Blog
Article.
6. Chairperson Patsy Keever-Aycock knowingly and calculatingly ignored the NCDP Plan of Organization
(POO) directives and procedures, and her Oath of Office. The Chairpersons (Keever Aycock and her coconspirators) conduct and behavior displayed/exhibited a lack of truth, Justice and a total disrespect for the
African American voters, the Auxiliary Caucus its members and NC Minority Democratic Communities.
7. NCDP Chairperson Patsy Keever-Aycock knowingly and intentionally refused to comply with, respect her
Oath of Office, or comply with the provisions outlined and mandated in the NCDP Plan of Organization (POO),
its Preamble, Sections 00.2-3, 5.05 (10, 11, 12, 20), and provisions contained in the Chair of Minority Affairs,
Sections 4.08 (7) and 9.01, and Rule of law. See Exhibit 1 Points & Authority
8. Specifically, the NCDP POO Section 4.8 (7) and 9.01 is the primary governance that excludes the NCDP
Council of Review (COR), the legal body of NCDP, and its chairperson from hearing or rendering a decision on
disputes and controversies of an Auxiliary. The Auxiliary organizations of the NC Democratic Party shall
provide for their internal resolution of disputes within their respective organizations and shall not be subject to
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section 9.0. NCDP Chairperson Patsy Keever-Aycock with her co-conspirators, the State Executive Council and
specific State Executive Committee members failed and deliberately refused to comply with POO Section 4.08
(7) and 9.01, they totally ignored the AAC-NCDP Auxiliary By-Laws, and the Federal District Court Judges
ruling and decision regarding the 13 NC Congressional Districts, among other reckless acts and conducts as
identified herein this Grievance and Petition.
9. NCDP Chairperson Patsy Keever-Aycock deliberately submitted a blatantly false representation of the actual
facts, and the fraudulent evidence she identified and used to craft the deceitful letter sent to the North Carolina
State Board of Election (SBOE) bearing her Signature under an oath of truthfulness. The Chairperson, without
authority, declared she recognized Willie Fleming as President of AAC-NCDP, knowing full well or should
have known she wrongfully rendered a subjective decision (based on fraudulent documents) on a dispute and/or
controversy she received from Willie Fleming and Linda Daniels false verbal communication. She also had
personal knowledge the NCDP POO specifically excludes such authority from her duties and other provisions
of the POO. The Chairpersons letter was bogus on its face, and she deliberately and intentionally sent it to
deceive the SBOE, stating that Willie Fleming IS President of AAC-NCDP Auxiliary, all based on fraudulent
intent to deceive documents and false hearsay information. The Chairperson published and distributed another
false and fraudulent letter on behave of Willie Fleming and Linda Daniels wherein she made a determination
that the AAC-NCDP could not have a proper election (as authorized by the AAC-NCDP General Body in the
June 2015 Meeting) in August 2015. See included Exhibits
10. The Chairperson had personal knowledge that: 1.) Willie Fleming and Linda Daniels, on January 31, 2015
and February 2015, was removed from the position as president and 1st. Vice president; 2.) Willie Fleming or
Linda Daniels did not deny the charges and they both refused to attend their hearings; 3.) or appeal their
removal Decision (to the AAC-NCDP General Body) that was rendered by the AAC-NCDP in accordance with
the Auxiliary By-Laws; 4.) the chairperson knew or should have known the POO Section 4.08 (7) and 9.01
prohibits such interference with an auxiliary or writing such letters. The AAC-NCDP Auxiliary Caucus
members filed a complaint and request for investigation against NCDP and its chairperson and others with the
SBOE. See Exhibit 11, 12. Letters from Chairperson Keever Aycock.
11. Its no dispute that: 1.) Willie Fleming or Linda Daniels were not a member of a registered certified AACNCDP County Caucus when they applied to run for President and 1st. Vice President of the State Auxiliary
Caucus; 2.) Willie Fleming and Linda Daniels committed malfeasance; 3.) Willie Fleming and Linda Daniels
failed or refused to comply with AAC-NCDP Auxiliary by laws and various State Board of Elections rules and
regulations to include, refusing to file financial reports as required; 4.) that such non-compliance with the SBOE
rules and regulations subjected the state (AAC-NCDP) Auxiliary Caucus to penalties in excess of $3,500, and
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approximately $500 to $10,000 plus penalties for other County Caucuses based on his negligent advice and
leadership. See Exhibit 13 Statement by Rodney Moore filed with the SBOE.
12. Also, Willie Fleming deceitfully created a fraudulent state Auxiliary committee (African-American Caucus
of NC) SBOE ID No. STA-9TAJWK-C-001, to avoid paying the penalties, resulting from Flemings
unlawfully raising and misappropriating, for personal use, AAC-NCDP Auxiliary funds, which jeopardized the
GOOD STANDING integrity and character existence to continue for the AAC-NCDP State Auxiliary. See
Exhibit

13-A statement filed by Willie Fleming with the SBOE.

13. Additionally, the Chairperson and her co-conspirators such as Senator Floyd Mc Kissick, Don Davis,
Charlie Reece and Larry Hall among others named, unnamed and unknown, aggravated the matter. Many
AAC-NCDP members voiced their dissatisfaction with how the AAC-NCDP funds were handled while
organizing their County Caucus. Many members were infuriated to the degree of requesting a refund and
wanting to withdraw their participation in the AAC-NCDP Auxiliary and NC Democratic Party, when the
required financial reports were not published and their funds not made available. See Exhibit PRESS
RELEASE
14. The AAC-NCDP Auxiliary Caucus properly removed Willie Fleming on January 31, 2015 and Linda
Daniels in February 2015. The AAC-NCDP attempted to rectify the damages and resolve their Auxiliary
Caucus issues. However, the NCDP Chairperson Keever Aycocks false and fraudulently concocted letters
recognizing Willie Fleming as AAC-NCDP Auxiliary Caucus President encouraged him to run rampant across
the state from County to County inciting disturbance and turmoil among the County voters. Such acts and
conduct is attributable, solely directly/indirectly to Chairperson Keever-Aycock distribution of the
false/fraudulent, with the intent to deceive, memo/letters resulting in Willie Fleming and Linda Daniels
persistent collection of monies under false pretense of being the President of the AAC-NCDP Auxiliary, they
both continued to sow seeds of discord. Such false and fraudulent recognition ultimately caused confusion and
divided the African American voters to the point that they did not wish to participate in the NCDP or
Democratic Party.
15. The conduct and behavior displayed by Willie Fleming and Linda Daniels is not the caliber of character
desired for the members of AAC-NCDP Auxiliary Caucus. The NCDP Chairperson Keever-Aycock in
association with Willie Fleming, Linda Daniels and others, designed to cause divisive maneuvering, in-fighting,
and persistent turmoil which ultimately destroys the very core of the AAC-NCDP Auxiliary Caucus. See Exhibit
14 Notice to Remove for Cause.

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The Chairperson had not ever been involved in any other Auxiliary disputes and controversies during her tenure
as a NCDP member. The LBGT Auxiliary, the unorganized Hispanic-American and Young Democrats have
had a number of serious disputes and controversies, along with their current one, yet the Chairperson did not
intrude or interfere with their administration and operation.
16. On or about May 2015, the AAC-NCDP State Auxiliary Caucus Former President Brandon Johnson notified
NCDP chairperson Keever Aycock that she failed and/or refused to comply with the POO Section 9.01 and give
full faith and credit to the AAC-NCDP disciplinary decision. The NCDP chairpersons wrongful acts, conduct
and behavior ultimately constituted disenfranchising NC African-American Auxiliary Caucus voters. See
NCDP chairperson Memo/letters Exhibits
17. In light of the discoveries of Willie Fleming and Linda Daniels malfeasance within the state AAC-NCDP
Auxiliary amongst its elected officers, former President Brandon Johnson and Current President Jannet Barnes,
of the auxiliary Caucus, was forced to restructure its Caucus in an effort to solidify its existence, defend its
character and integrity and attempt to ensure its continuation as a prolific voice for African Americans in the
State of NC.
18. At various times and occasion during January 31, 2015 through May, 2016, Chairperson Keever Aycock
without authority, justifiable or reasonable cause, refused to acknowledge and respect the official authority of
the AAC-NCDP Executive Officers and their January 31, 2015, February 2015, June 6, 2015 General Body
Caucus members decision confirming the removal of Willie Fleming and Linda Daniels and the August 1, 2015
General Body meeting and election. The NCDP Chairpersons conduct violated the POO, usurped and ignored
the Authority of the AAC-NCDP Auxiliary Caucus By-Laws. The Chair Keever Aycocks refusal is a clear
violation of all the applicable provisions of the POO as identified herein this Verified Petition and requires
her removal as stated herein and the Points and authority Exhibit 1
19. The NCDP Chairperson knowingly and deliberately ignored the February 2016 Federal Court ruling and
decision, that the NC Congressional Districts were unconstitutional. The Federal Court ordered that District
maps be redrawn and submitted to the Court by February 19, 2016. The Chairwoman also knew that the
unconstitutional Districts suppress the vote, especially the African American voters, and were drawn to rig the
electoral process through gerrymandering. Chairperson Keever Aycock acknowledged the unconstitutional
Districts needed to be redrawn immediately because they did not provide basic fairness to the NC Congressional
elections. Having this personal knowledge, Chairperson Keever Aycock deliberately directed the 13
Congressional District Chairpersons to conduct their May 21, 2016 Congressional District Conventions be held
using the unconstitutional Districts continuing the rigged process and unfair elections. Additionally, the
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District Conventions did not comply with or conduct the Conventions in accordance with the POO or Roberts
Rules of Order. The 13 unconstitutional Districts Conventions did not have the required credential committee,
credential committee reports and did not have occasion for the approval of credential committee reports to
certify the actual County and District Delegates in order to conduct a fair and proper election in accordance with
the POO. There was no determination of the legitimacy of the Delegates on the list submitted. In essence there
was no verification of the accuracy of the multiplier numbers used. In the absence of valid adopted credential
committee reports there can be no validating of any balloting to be used in the State NCDP Convention to be
held June 11, 2016. The 13 NC Congressional District Conventions were held in unconstitutional Districts and
not the redrawn districts the Federal Court ordered. THESE DISTRICT CONVENTIONS AND
ELECTIONS WERE NOT LAWFUL OR CONSTUTIONAL AND WERE CONDUCTED IN
VIOLATION OF THE POO, THE FEDERAL COURT RULING AND DECISION THAT THE
DISTRICTS VIOLATED THE 14TH AMENDMENT EQUAL PROTECTION CLAUSE AND
VIOLATED THE VOTING RIGHTS ACT. The results of the wrongful deliberate acts, conduct and behavior
of the NCDP Chairperson, her co-conspirators, and the 13 District chairpersons that conducted the unlawful
delegate and COR committee members elections, in the unconstitutional Districts, are complicit, because
they knew there were 13 NC redrawn congressional Districts and should have had known their acts, conduct
and behavior was not proper in lite of the Federal Courts Ruling the Congressional Districts were
unconstitutional violated the 14th Amendment and the Voting Rights ActTHEREFORE ALL ELECTIONS
ARE NULL AND VOID.
20. On or about February 19, 2016 the 13 Congressional Districts were redrawn and filed with the Court as
required, and the Court did not enter an order staying the Courts February 19, 2016 order that the old
Congressional Districts were unconstitutional, And the Court did not issue an order or decision that the newly
redrawn Districts were unconstitutional. Therefore, the newly redrawn Congressional Districts were the
legitimate District to hold and conduct the 13 Congressional District Conventions and not the old 13
unconstitutional Congressional Districts.
21. The NCDP chairperson knowingly and deliberately ignored the 13 newly redrawn Congressional Districts
and continued to direct the old District Chairs to wrongfully hold illegitimate delegate and the Council of
Review (COR) elections in the 13 unconstitutional Congressional District Conventions, which were identified
rigged electoral process through gerrymandering. Yet, the use of the newly drawn Court ordered Districts were
constitutionally proper. Therefore, each of the 13 Congressional District Conventions held May 21, 2016 were
not legitimate to include the Delegate and COR elections were not proper and should be VOID ABINITIO!

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Such acts and conduct by Patsy Keever Aycock, was clear and ever-present non-compliant with the NCDP Plan
of Organization Constitution and her oath of office, therein being grounds to remove her from the position as
Chairperson of the NCDP.
22. No NCDP official, elected officer or member is allowed to: ignore or refuse to adhere to and comply with
the provisions of the POO, including the duties of the NCDP chairperson; to grant (a verbal, exparte, written or
otherwise) Appeal to an Auxiliary Caucus member; directly/indirectly discourage and/or obstruct the AACNCDP auxiliary administration operations or any auxiliary with impunity. Such acts, conduct and behavior of
the chairperson Keever Aycock, the SEC elected officers (State Executive Council) constitute a denial of the
AAC-NCDP Auxiliary members liberties, civil rights, social justice (social inequality) and right to justice and
redress pursuant to the rule of law.
23. The named Petitioners listed herein, verify under the penalties of perjury, state that the allegations and facts
stated herein this Verified Petition are true and accurate based on our person knowledge, creditable information
and belief, and the attached exhibits of evidentiary documents are also true and accurate documents based on
our personal knowledge, creditable information and belief.
IN CONCLUSION THE PETITIONERS submit this Verified Petition has sufficient merit to warrant a full
hearing, and pursuant to the Plan of Organization, the 1st vice Chair, upon a majority vote of the elected
officers of the state executive committee agreeing shall call a meeting of the Council of Review to hear
the Petitioner(s), the Respondent(s), and other interested parties or witnesses.
That the Petitioner(s), aggrieved active democrats, pursuant to NCDP POO Section 9.01, respectfully request
that a call meeting of the Council of Review warrant calling, to hear this Petition and render a decision based on
the facts and evidence presented therein. That the NCDP Chairperson Patsy Keever Aycock and others
participants be removed, based on the evidence contained herein and submitted at the hearing, from their elected
Position of office as requested herein this Petition.
Respectfully Submitted,
NOTARY
Signature attached hereto this document
________________________________________
Petitioner 1. Perry Graves, President
African-American Caucus of Rockingham County
Democratic Party. AAC-RCDP
NOTARY
Signature attached hereto this document
________________________________________
Petitioner 2. Valeria Conyers, 2nd Vice President AAC-NCDP
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NOTARY
Signature attached hereto this document
_____________________________________
Petitioner 3. Chenita, 1st Vice President
African-American Caucus of the Forsyth Democratic County AAC-FDP

Certificate of Service
I, Jannet Barnes, President or Chenita Johnson, Secretary of the AAC-NCDP do state that this Petition was
mailed to the 1st Vice Chair Zack Hawkins of the NCDP, first class postage prepaid, certified return receipt
requested to Zack Hawkins on June, ____, 2016.
__________________________________

Jannet Barnes or Chenita Johnson

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EXHIBIT 1

POINTS AND AUTHORITY

Petitioners submits these Points and Authorities relied upon to reveal and present the factual and evidentiary
Petition summarizing NCDP Chairperson Patsy Keever-Aycocks wrongful, unethical and/or illegal acts,
conduct and behavior. Chairperson Patsy Keever-Aycocks individually and/or in concert with other
accomplices failed or refused to comply with the Preamble and other mandatorily required duties stated in
Sections of NCDP Plan of Organization (POO), and stated as follows:
PREAMBLE
We, the members of the North Carolina Democratic Party, in order to make
more effective the principles of our Party, to embrace and serve all peoples of
our party without regard to race, age, gender, color, creed, national origin, religion, ethnic identity, sexual
orientation, gender identity, economic status, or physical disability (hereinafter referred to as status), to insure
the blessings of liberty and equal opportunity, and to work together for the welfare and happiness of all citizens,
do hereby adopt and establish this Plan of Organization.

PRINCIPLES FOR ALL LEVELS OF THE DEMOCRATIC PARTY

Section 0.02 Encourage participation
Special efforts shall be made to encourage traditionally under-represented
groups to participate in delegate selection processes and in party organizations
at all levels to the end that all elected or appointed Democrats to any positions reasonably reflect the
Democratic electorate of the unit with regard to status.

0.03 Non-Discrimination
No test for membership in or any oath of loyalty to, the North Carolina Democratic Party shall be required or
used which has the effect of requiring prospective or current members of the Democratic Party to acquiesce in
condone or support discrimination based on status.

4.05 Duties of The State Chair and Certain Officers State Chair.
The duties of the state chair shall include:
10. Raise funds necessary for the state party to meet its goals;
11. Encourage communication to all interested persons and organizations relating to party activities and political and policy
positions of the state party;
12. Encourage and facilitate the establishment and continuity of state auxiliary organizations;
20. Inspire and mobilize vigorous grassroots public and party support of all major legislation which reflects and implements
the Policy and Political Agenda of the state Democratic Party.

4.03 Appointed Officers [By The NCDP Chair]

The state chair shall appoint a chair for minority affairs. whom shall serve at the
pleasure of the state chair as appointed officer[s] and. who shall be voting members
of the state executive committee.

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Chair for Minority Affairs. The state chair for minority affairs shall serve as a liaison between the party and
the Democratic minority communities in the state and shall encourage full participation and representation in all
party affairs.

4.06 - Composition. The members of the state executive council shall be:
1. the state presidents of all state auxiliary organizations with by-laws approved by the state executive committee
state chair;
2. and three at-large members appointed by the state chair. These three members
appointed by the state chair shall reasonably reflect the geographic, racial, ethnic
and gender makeup of registered Democrats in North Carolina

4.08 Order of Business of the State Executive Committee Meeting Held Prior to March 1
Each year, the state chair shall convene the state executive committee prior to March 1. At such meeting, it shall be the
duty of the state chair to publicly announce and enter into the proceedings of that meeting the following as the first order
of business:
7. The state chair, in odd-numbered years, will submit the constitutions and/or by-laws of each state auxiliary
organization for approval of the state executive committee which shall issue or reaffirm the charters of such
organizations upon approval of such by-laws and/or constitutions. As a part of the constitution and/or by-laws of
each state auxiliary organization, there shall be a statement indicating that a primary mission of the organization
is the promotion of the Democratic Party, its nominees for elective office, and its elected officials. In addition, the
constitution or by-laws of each state auxiliary organization must provide a mechanism for dealing with county
chapters of state auxiliary organizations that deviate from the mission outlined above.

6.01 Congressional District Conventions

Presiding Officer. All district conventions shall be called to order by the chair, who shall serve as convention
chair, but in his or her absence, the vice chairs of the district executive committee in order of succession, the
secretary and the treasurer shall, in order of succession, preside over the convention, and in case none of the
foregoing persons shall be present, then any delegate to the convention may preside and serve as convention
chair until a permanent convention chair is elected by the convention.
Allocation of votes.
Each county in a congressional district shall be entitled to cast at a congressional district convention one (1)
vote for every three hundred (300) votes, or major fraction thereof, cast in that county or in the applicable
portion thereof, for the Democratic nominee for Governor at the last proceeding gubernatorial election;
provided, that each county shall be entitled to cast at least one vote. Each county shall be entitled to its full
voting strength only if the county has elected its full voting strength; if not, the county shall be entitled to the
number of votes equal to the number of delegates they have elected.
Election of Delegates.
The congressional district convention shall be composed of delegates elected by the several county conventions
held annually. Each county or appropriate portion thereof shall elect one (1) delegate for each vote it is entitled
to cast at the congressional district convention.
Roll of Delegates.

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The state chair shall direct the make-up of a roll of all delegates from the several counties to the district
convention and transmit the same to the congressional district chair.
Division of Votes Among Delegates Present
The delegates who attend a district convention shall be entitled to vote the full strength of their county upon all
matters of business which come before the respective district convention, and each such delegates present from
a particular county shall cast an equal number of votes which the county is entitled to cast. All votes, which the
county is entitled to cast, shall be divided equally among all the delegates in attendance representing that
county.
Vote May Not Be Changed.
In a District convention, after a vote is cast, there shall be no change in such vote final results of the ballot
shall be announced by the chair of the district convention.
Reporting and Challenging a Vote.
In all district conventions, it shall be the duty of the delegates from the several counties to choose one of their
numbers as chair, whose name shall be reported to the chair of such convention, and whose duty it shall be to
cast the vote of his or her county as directed. The vote, as announced by that person, shall be recorded unless
some delegate from that county challenges its accuracy. In the event of a challenge, it shall be the duty of the
chair of the convention to cause the roll of delegates from that county to be called, upon which the vote of such
county shall be tabulated and recorded according to the response of its delegates. In no event shall the vote of
one county be challenged by a delegate from another county.
Order of Business Even Numbered Years.
The Congressional district convention held in even numbered years shall:
1. Elect, from among the active Democrats of the congressional district, one (1) member of the biennial
State Conventions Committee on Credentials and Appeals;
2. Elect, from among the active Democrats, one member of the Council of Review;
3. Elect, from among the active Democrats, one member of the Resolutions and Platform Committee.
4. In each presidential election year, elect, 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
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.
7. Conduct any other business related to the affairs of the Congressional District.
Certification.
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9.00 Council of Review

9.01 Purpose
There is hereby established a Council of Review for the purpose of hearing and rendering fair and impartial decisions on
such disputes and controversies which may arise within the Party when the same are made known, in writing, to said
Council of Review by the state chair, or by the state executive committee, or by an aggrieved active Democrat. Auxiliary
organizations of the Democratic Party shall provide for the internal resolution of disputes within their respective
organizations and shall not be subject to this section.

9.06 Jurisdiction
The Council of Review Shall Assume jurisdiction of all matters and disputes but in no event shall the
Council of Review consider any incident or event occurring more than six (6) months prior to the alleged
grievance...The Council of Review Shall also assume jurisdiction of all matters and disputes referred to it by
the state chair.
10.00 Removal and Vacating of Officers and Committee Members
10.01 Grounds for Removal
Any officer or committee member of the Democratic Party at any level, including the precinct, the county, the
congressional district, the prosecutorial district, the state senatorial district, the state house of representatives
district, the state executive committee, the state executive council or any committee, subcommittee, or council
thereof, who directly or indirectly, gives support to, aids or helps any opposing political party or candidate of
any opposing party, or either a write-in or unaffiliated candidate regardless of voter registration when there is
a Democratic Nominee, or who refuses or fails to perform his or her duties, or who is convicted of a crime
involving moral turpitude, may be removed from office.
State Chair as Respondent. When the state chair is a Respondent under this section, the first vice chair of the
state executive committee shall receive the petition and perform the duties as set forth in this Section in place of
the state chair.

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