Tuesday, March 10, 2015

Geoffrey M. Young's Lawsuit Against Kentucky's Top Democrats (Patrick Hughes, et al)

COMMONWEALTH OF KENTUCKY
FRANKLIN CIRCUIT COURT

DIVISION II (Judge Thomas D. Wingate)
CIVIL ACTION NO. 15-CI-214


Geoffrey M. Young PLAINTIFF

COMPLAINT RE CONSPIRACY TO DEFRAUD KENTUCKY'S
DEMOCRATIC VOTERS, CORRUPTION, CRONYISM,
AND INTENTIONAL VIOLATION OF PARTY BYLAWS

Steven L. Beshear, Jack Conway,
Alison Lundergan Grimes, DEFENDANTS
Dan Logsdon, and Patrick Hughes



* * * * *
Serve:
Mr. Steven L. Beshear
Office of the Governor
700 Capitol Avenue, Suite 100
Frankfort, Kentucky 40601

Serve:
Ms. Alison Lundergan Grimes
Office of the Secretary of State
700 Capital Avenue, Suite 152
Frankfort, KY 40601

Serve:
Mr. Jack Conway
Office of the Attorney General
700 Capital Avenue, Suite 118
Frankfort, KY 40601

Serve:
Dan Logsdon, immediate past Chair
Executive Committee
Kentucky Democratic Party
190 Democrat Drive
Frankfort, KY 40601 (or at his home address if unavailable there)
Serve:
Patrick Hughes, current Chair
Executive Committee
Kentucky Democratic Party
190 Democrat Drive
Frankfort, KY 40601


Plaintiff, Geoffrey M. Young, pro se, for his Complaint against the Defendants acting in their capacities as high-ranking, dominant, and influential officials and members of the Kentucky Democratic Party ("KDP"), respectfully states as follows:

I. Nature of Action

1. This is a civil action for monetary, declaratory and injunctive relief relating to Defendants' misconduct in the context of intra-party (i.e., KDP) politics that is so egregious that it could damage the reputation and fortunes of the KDP for years or decades to come, if not halted and corrected immediately by the Court. Plaintiff will prove at trial that all five Defendants have legally disqualified themselves, by their malicious and unlawful actions, from holding any office within the KDP for a period of two years after a jury finds them guilty of the misconduct alleged herein. Plaintiff will prove that Defendants Conway and Grimes have morally disqualified themselves from serving as Governor and Secretary of State, respectively, because of their unlawful and unethical actions and omissions over a period of several months.
II. The parties
2. Geoffrey M. Young is a citizen of the Commonwealth of Kentucky, a registered Democrat, a member of the KDP, and a Democratic candidate for Governor who filed timely on January 27, 2015, on a slate with his running mate, Johnathan Masters.
3. All five Defendants are being sued in their capacities as current or former high-ranking, dominant, and influential officials and members of the KDP. They are not being sued in their elected official capacities as Governor, Secretary of State, or Attorney General of Kentucky. Neither the KDP as an organizational "person" nor its Executive Committee (EC) is being sued at this time. No members of the EC, also known as the "State Central Committee," are being sued except any of the five named Defendants who are members of it.
4. All five Defendants are being sued for conspiracy to defraud Kentucky's Democratic voters, corruption, cronyism, and intentional violation of KDP bylaws.
III. Jurisdiction
5. Jurisdiction of the Franklin Circuit Court is proper pursuant to KRS 418.040, Section 112 of the Kentucky Constitution, and Section IX.G of the KDP Bylaws. Plaintiff holds that Bylaw Section IX.G is applicable without delay because of specific bad-faith actions and omissions committed by certain Defendants; details to be provided herein.
6. Plaintiff is demanding monetary damages that will far exceed the amount necessary to establish the Court's jurisdiction.
IV. Facts
7. On January 12, 2015, Jack Conway and his running mate filed as a slate for Governor and Lieutenant Governor on the Democratic ticket. Conway's and Plaintiff's slates are the only two Democratic Party slates this year. The Democratic primary election will be held on May 19, 2015 in all 120 counties.
8. On Saturday, February 7, 2015, the Associated Press, WPSD Local Channel 6 and other news outlets reported the following information:
The executive board of Kentucky Democratic Party has unanimously elected attorney Patrick Hughes as the party's new chairman. Hughes, of Edgewood, served as Chief Deputy Attorney General to Kentucky Attorney General Jack Conway in 2011 and 2012. He currently is a partner at Dressman, Benzinger and LaValle. In a news release on the election, Gov. Steve Beshear called Hughes "a passionate, dedicated and thoughtful leader who understands what's important to Kentucky families." Hughes succeeds Dan Logsdon, who served as party chair for four and a half years.

9. On Monday, February 9, 2015, the Defendants held a "Unity Press Conference" at the KDP Headquarters building in Frankfort, where Defendants Beshear, Conway and Grimes expressed their unity with and support for each other and the other Democrats attending the event. Before the speeches began, Plaintiff asked Defendant Hughes for permission to speak and was denied. Plaintiff went outside to his car, hand-lettered a sign, and stood outside the building showing it to everyone leaving the press conference as they walked back to their cars. The sign read, "With Grimes and Conway, Democrats LOSE." The sign clearly expressed the absence of complete unity within the KDP.
10. Starting the next day, Plaintiff repeatedly tried to contact Defendants Steve Beshear and Patrick Hughes, demanding a hearing by the KDP's Executive Committee as required by the KDP Bylaws when a Democrat accuses other Democrats of intentionally violating important bylaws. Plaintiff timely faxed, emailed and mailed an official accusation to Defendant Hughes on 2/10/15, which will be introduced as physical evidence at trial. As of 3/2/15, the filing date of this lawsuit, neither Steve Beshear nor Patrick Hughes has responded to Plaintiff in any way at all.
V. Legal Arguments
A. All five Defendants conspired to intentionally violate KDP Bylaw I.D.
That bylaw reads as follows:
No Discrimination in Party Meetings:
No Democrat [sic] Committee governed by these By-Laws, or any Democratic Party Officer acting in his or her official capacity, shall endorse or support one Democratic candidate over another Democratic candidate in a Democratic Primary Election. No assets of the Democratic Party shall be used in a Democratic Primary Election unless they are made available equally to all Democrat [sic] Candidates in that specific primary election.

11. All five Defendants were acting in their KDP capacities – proudly wearing their KDP hats – during the week before and on the day of the "Unity Press Conference."
12. As far as Plaintiff knows, Defendant Dan Logsdon was the Chair of the State Central Committee until 2/7/15, when his successor, Patrick Hughes, was unanimously elected by the EC. Evidence presented to the jury will prove that Logsdon was aware of the "Unity Press Conference" planned for two days later and had invested time and effort into helping organize it and making it as successful as possible. Logsdon never invited Plaintiff or informed him it was going to occur. Plaintiff found out about the press conference on 2/8/15 from a Democratic friend. Because Logsdon was fully aware that Plaintiff was an opponent of Jack Conway and would never express support for his candidacy until after the Democratic primary, if then, Logsdon's bad-faith actions and omissions blatantly violated the cited bylaw. No member of the KDP has ever offered Plaintiff the opportunity to speak at a second or third "Unity Press Conference" where Democrats such as Governor Beshear would support his candidacy and that of Charles Lovett, Alison Grimes' only Democratic opponent for Secretary of State.
13. In addition to Dan Logsdon, the other four Defendants were obviously complicit in putting on the "Unity Press Conference." They invited reporters, arrived on time, gave self-congratulatory speeches, refused to let Plaintiff speak, and used KDP resources, including the time of staff members, that were denied to Plaintiff.
14. The bogus "Unity Press Conference" illustrated all five Defendants' clear intention to violate not only the letter but also the spirit of KDP Bylaw I.D. The intent of the bylaw is to enable and encourage as many of Kentucky's registered Democrats as possible to participate in choosing the nominee they prefer to represent them in the general election campaign and in elected office if their preferred candidate wins. The clear intent of the press conference was not only to endorse Conway and Grimes but to convince the media and public that Plaintiff's candidacy should be dismissed out of hand and completely ignored for the next three months. The Defendants' intent was antidemocratic in nature. In the 1920s and 1930s, the faces of former Communist Party officials were erased from group photographs published in Soviet newspapers because those officials had fallen out of favor with the General Secretary of the Communist Party – Joseph Stalin, Nikita Krushchev, or whichever leader was ascendant at the time. The 2015 Kentucky equivalent of Stalin would be Defendant Steve Beshear.
15. The bogus "Unity Press Conference" made a mockery of democracy itself. Defendants Conway and Grimes have built up huge war chests of campaign contributions, but Plaintiff has not yet done so. The act of holding the "unity" press conference before any debates among Democratic candidates had been held means that the five Defendants are deeply committed to the immoral and undemocratic proposition that money should decide the outcome of primary elections, not the voters.
16. Perhaps the dirtiest campaign strategy of which Plaintiff is aware is to pretend that one's opponent doesn't exist. The dirty campaigner refuses to debate his or her less wealthy opponent, tries to avoid ever appearing on the same panel or in the same room with the opponent, and tries to coast to victory on the basis of a large war chest and a lot of TV advertising buys. Stan Lee (R-Fayette County) used this dirty strategy against Plaintiff in 2012 and won reelection to the Kentucky House of Representatives. Elisabeth Jensen (D-6th Congressional District) used the same dirty, unethical strategy in 2013 and 2014 and beat Plaintiff in the primary but was crushed by incumbent Andy Barr (R) on 11/4/14. In 2015, Defendant Jack Conway (D) is using exactly the same dirty, unethical strategy against Plaintiff. The strategy is particularly dirty and unethical when the rivals are members of the same party. Thus, Jensen and Conway ran and are running even dirtier campaigns against Plaintiff than did Stan Lee, who had no Republican rival in 2012. The intent of their strategy is always to enable money, not the voters, to decide the outcome of the coming election.
17. A political party that routinely and intentionally selects the richer, less qualified, less ethical, and politically weaker candidate to represent it in general elections is not long for this world.
B. All five Defendants conspired to intentionally violate KDP Bylaw I.D.
That bylaw reads as follows:
Publication of Party Election Procedures:
The KDP shall publicize fully and in such manner as to assure notice to all interested parties a full description of the legal and practical procedures for selection of Democratic Party officers and representatives on all levels. Publication of these procedures shall be done in such a fashion that all prospective and current members of the Democratic Party will be fully and adequately informed of the pertinent procedures in time to participate in each selection at all levels of the Democratic Party organization."

18. For months before 2/7/15, Plaintiff had been expressing intense interest in getting Logsdon deposed as KDP Chair and either replacing him himself or being named Chair of the Search Committee assigned to find a competent replacement for him. Evidence will be presented at trial. If he had been named Chair of the Search Committee, Plaintiff would have followed the KDP Bylaws to the letter, and Logsdon knew it. All five Defendants must have known that Defendants Hughes, Logsdon and Beshear were planning a choreographed changing of the guard and enthusiastically went along with the farce. To be clear, all five Defendants violated every clause of Bylaw I.D, and they did it willingly, knowingly, and maliciously.
C. Defendant Dan Logsdon participated in precisely the same stunt in 2014 when he conspired with certain powerful Fayette County Democrats to install a crony in the Chair position of the Fayette County Democratic Party (FCDP).
19. Plaintiff is able to express complete confidence in Argument B above because he's been through the whole sordid routine once before. The crony was one Bob Layton, and their modus operandi was exactly the same. The bylaws of the FCDP are modeled after those of the KDP. After failing to get Layton to follow the FCDP Bylaws and call a hearing, Plaintiff filed a civil lawsuit against the members of the FCDP Search Committee, Bob Layton, Dan Logsdon, and Elisabeth Jensen, the Democratic candidate Bob Layton was favoring in the 2014 race in Kentucky's 6th Congressional District. Plaintiff was Jensen's opponent at that time. The Civil Complaint was filed in the Franklin Circuit Court, Division II, on March 6, 2014, and was assigned the number 14-CI-260. The defendants, including Layton and Logsdon, did not respond to the lawsuit in any way. Worried that he might have made some kind of error in service of process, Plaintiff unilaterally withdrew his Complaint on 3/26/14. The Trial Court affirmed the Plaintiff's withdrawal of the lawsuit in an Order dated 4/2/14. Plaintiff now regrets his decision not to submit a motion for summary judgment pursuant to CR 56 in April, 2014, because the sooner one confronts and defeats bullies, the more likely they are to cease their bullying.
20. After the complaint had been withdrawn, neither Dan Logsdon nor Bob Layton changed their bad-faith behavior toward Plaintiff in any way. Defendant Logsdon refused to follow the applicable appeal procedure in the KDP Bylaws and never scheduled the required hearing of the state Executive Committee. Layton arranged a biased hearing in Fayette County that violated every common understanding of due process and, unsurprisingly, was found innocent of all wrongdoing. He resigned a few months later and moved to the Washington, DC area. The process the FCDP used to select Layton's successor in December 2014 to February 2015 conformed reasonably well to the requirements of the FCDP Bylaws. In Plaintiff's experience, the KDP has never followed its own bylaws in any important respect that affects his legitimate interests as a Kentucky Democratic candidate for any Party position or public office. Bad faith from the most powerful KDP leaders is the invariable norm he has come to expect.
D. Every influential Democrat in the KDP whom the Plaintiff has ever met seems to think the sitting Governor, if a Democrat, is the real boss of the KDP, but the Bylaws do not confirm that assumption.
21. Bylaw VIII.D states as follows with respect to the selection of a new Chairperson of the KDP (State Central Executive Committee): "If there is a sitting Democratic Governor or an elected Democratic Nominee for Governor, he or she may present an individual for consideration and vote to the State Central Committee." This is the only sentence in the KDP Bylaws that contains the word "Governor." Plaintiff reads this bylaw to imply that if a Democratic Governor were to "present" a candidate, the Executive Committee (EC) would be fully within its authority to tell both the Governor and her nominee to jump in the nearest river. Every other Kentucky Democrat Plaintiff has ever met who has an opinion on this question, however, seems to feel that a Democratic Governor may appoint or fire the KDP Chairperson at will. Even more remarkably, these Democrats tell Plaintiff that the Governor (if a Democrat) is the "leader of the Party." Discovery will reveal whether the EC ever goes against a Democratic governor's wishes with respect to who the KDP's chairperson will be. If Defendant Beshear can appoint and fire chairpersons at will, and the EC feels it must accept whatever decisions the Governor makes, as Plaintiff suspects, then democracy has been banished from a critically important part of the KDP – its very summit. A bad chairperson can cripple a political party in a much shorter period of time than the 4.5 years Defendant Logsdon was given.
22. Any governor, including Governor Beshear, has more personal power when it is universally assumed that he is the real boss of the KDP. "Power corrupts, and absolute power corrupts absolutely," however, and it is possible for Plaintiff to trace how the pernicious assumption noted above may have contributed to the Defendants' egregious violation of KDP Bylaws I.F and I.G, which call for a wide-open, statewide competition for the Chair position based on merit alone. Why go through a careful, impartial procedure to identify and vet the next Chairperson when the Governor's nominee always gets the job anyhow? The result in 2015 was a procedure more suited to the former Soviet Politburo than to a party that calls itself "Democratic." As of the date of this filing, Plaintiff must assume that when Defendant Steve Beshear asks the EC to jump, its normal response is to ask, "How high?"
23. Defendants' back-room conspiracy to shove Defendant Logsdon aside and install Defendant Hughes in his place severely damaged Plaintiff's interests as a candidate for Governor in 2015. Defendant Hughes' close association with Defendant Conway has been reported in the press. Plaintiff must assume that as long as Conway's crony occupies the position of KDP Chair, he will not be able to get the time of day from the KDP or any member of its Executive Committee or staff. That assumption has been amply borne out during the first two months of 2015.
E. Defendants Logsdon, Conway, Beshear, and Hughes conspired to intentionally violate KDP Bylaw I.G.
Publication of Qualifications for Party Office:
The Kentucky Democratic Party shall publicize fully and in such manner as to assure notice to all interested parties a complete description of the legal and practical qualifications for all officers and representatives of the State Democratic Party. Such publication shall be done in a timely fashion so that all prospective candidates or applicants for any elected or appointed position within the State will have full and adequate opportunity to compete for office.

24. Defendants violated every sentence and clause of this bylaw in the process of installing Patrick Hughes on 2/7/15. Plaintiff was eager to apply for the Chair position, but didn't even learn it had been up for grabs until a day after the EC did the Governor's bidding. There was probably no instant in time when the Chair position was vacant. There was probably an instantaneous transition between one corrupt Chairperson, Defendant Logsdon, and his corrupt successor, Defendant Hughes. Despite the clear bylaw language, apparently the main qualification to be elected Chairperson of the KDP is to be a crony of the Governor, a crony of the Governor's favored candidate for Governor, or a crony of both of them.
F. All five Defendants chronically shred KDP Bylaw II.P.
Adequate Notices of Times and Places for Party Meetings.
The time and place for all meetings of the Kentucky Democratic Party at all levels shall be publicized fully, and in such manner as to assure adequate notice to all interested persons. Such meetings shall be held in places accessible to all Party members and large enough to accommodate all interested persons.

25. Plaintiff was looking diligently for advance notice of the EC meeting that ended up being held on 2/7/15. Plaintiff had called the KDP weeks earlier and asked to be appointed as Chair of the Search Committee to replace Defendant Logsdon. The secretary expressed astonishment at the idea that Plaintiff thought Logsdon was planning to resign. Plaintiff would surely have attended the EC meeting if he had known it was going to occur or that Logsdon was thinking of stepping down. He never saw any notice or agenda of the EC meeting on the KDP web site or anywhere else. No Democrat told him it was imminent, although several well-connected Kentucky Democrats had known of his intense interest in replacing Defendant Logsdon since a day or two after the 11/4/14 general election, which was a disaster for Kentucky's Democrats. Plaintiff learned only on 2/8/15 that the pivotal meeting had occurred the day before, and that Defendant Hughes had been handed the reins of the KDP by a unanimous vote. In Plaintiff's experience dealing with the KDP between October, 2013 and the present day, it almost never publicizes its upcoming regular or special meetings and never publishes the proposed agenda, thereby shredding this bylaw on an ongoing basis.
26. The KDP's malicious failure or refusal to inform Plaintiff and hundreds of other interested Democrats of the upcoming changing of the guard severely damaged his interests as a candidate for Governor. One year before, Plaintiff had experienced the unlawful installation as FCDP Chair of Bob Layton, a crony of his unethical rival for US Congress, Elisabeth Jensen (D-Fayette County). That railroad-like procedure had been the central theme of his civil lawsuit that had been in effect from 3/6/14 through 4/2/14. If he had known in advance that the Defendants were planning exactly the same stunt on 2/7/15, Plaintiff would have moved heaven and earth to attend the EC meeting and object to the Beshear-Conway-Hughes Railroad in the strongest possible terms. He would have announced before the rigged "vote" of the EC that a lawsuit about intentional violation of the KDP Bylaws would surely result if Hughes were to be coronated as the new Chair that day.
27. Since at least before November, 2013, and probably for decades previously (unobserved by Plaintiff), the KDP has operated like some kind of undemocratic, secretive junta. The Governor, if a Democrat, dominates it to an unhealthy extent. When a Democratic governor is a decent, fair-minded person, that degree of undemocratic control is problematic. But when the Governor is corrupt and pigheaded, as the current one is, the very survival of the KPD as a going concern is seriously endangered. Since Plaintiff got heavily involved in Democratic Party activities in October, 2013, it has seemed to him that Governor Beshear, Alison Lundergan Grimes, Jack Conway, Dan Logsdon, and now Patrick Hughes have been intent on running our once-proud, once-successful party straight into the ground as fast as possible. The sign Plaintiff displayed outside the KDP Headquarters building on 2/9/15 after the "Unity Press Conference" had ended was accurate: "With Grimes and Conway, Democrats LOSE."
G. The Defendants' bad faith was demonstrated by their absolute refusal to respond to Plaintiff's accusation of wrongdoing.
28. Plaintiff timely submitted the accusation that is required by the Bylaws, in writing, to Defendant Hughes on 2/10/15, the day after the fraudulent "Unity Press Conference." The document, which demanded that the mandatory hearing of the EC be held as soon as possible – Plaintiff proposed 2/21/15, which came and went without any action – will be submitted at trial as material evidence. Hughes and the four other Defendants immediately imposed on themselves a complete ban on communication with Plaintiff on this controversial subject.
29. Plaintiff included the following paragraph in his written accusation:
Mr. Hughes is now required by Bylaw IX.F. to call a meeting of the State Central Committee within 30 days of today's date. He should not preside over the mandatory hearing because of his obvious conflict of interest. The Vice-Chair should preside. I demand to be present to present my case; that too is a Bylaw requirement. I propose that he schedule the hearing for February 21, 2015 at the Headquarters building in Frankfort.

Plaintiff left several messages and notes to the same effect for Defendant Steve Beshear in the Governor's Office in the State Capitol. Not only did Defendant Hughes refuse to schedule the mandatory hearing, he and Defendant Beshear completely cut off all communication with Plaintiff. The Defendants' bad faith and intention to continue to shred the pertinent KDP bylaws could not possibly be more plain.
H. The word "cronyism" in the style of this Complaint refers to Defendant Patrick Hughes, who was installed in an unlawful and clearly illegitimate procedure on 2/7/15.
30. Because Plaintiff wasn't informed of the upcoming EC meeting, as the Bylaws required, he is unable to specify with precision exactly how fraudulent the coronation process was, which of the Defendants besides Mr. Hughes was present, what the EC members were told about their duty as good Democrats, whether any protest was raised by anyone about the clearly unlawful procedure, and related details. Plaintiff expects that these and other pertinent questions will be answered during discovery.
I. The word "corruption" refers to the following motive of all five named Defendants:
31. When a candidate who is opposed in a primary election campaign does not have to spend much or any money to defeat his or her opponent, that candidate has more money to spend against his or her opponent in the general election. Many Kentucky Democrats have expressed glee about how much money the four Republican candidates for Governor will have to spend or waste on their primary election campaigns and how bruised and battered the winner is likely to be by 5/19/15. Both Defendants Grimes and Conway have Democratic primary opponents in 2015. The actions and omissions of all five Defendants have clearly been motivated by their desire to enable Conway and Grimes to coast to victory on 5/19/15 without spending any money or risking their reputations in any debates with Plaintiff and/or Charles Lovett (D).
32. The fraudulent "Unity Press Conference" was potentially worth a tremendous amount of money to Defendants Grimes and Conway. If Plaintiff had behaved as Defendants had wanted and had politely faded away, Mr. Conway could have avoided spending much money or appearing in the same room with Plaintiff before May 19th. He would have been granted a no-cost, no-risk primary campaign by the other four Defendants and his supine opponent. But Plaintiff is not that kind of doormat, never has been, and never will be. Unlike the five Defendants, Plaintiff is a strong, principled, and courageous Democrat.
J. The phrase, "conspiracy to defraud Kentucky's Democratic voters" refers to the following unethical actions and omissions by Defendants:
33. The intentional violation of critical KDP bylaws, some egregious instances of which have been detailed above, constitutes fraud by any reasonable definition. The fraud consists of trying to convince Kentucky's Democrats that the most powerful leaders of the KDP conduct party affairs in an open, legitimate, and ethical way. When the public learns the truth, many Democrats will be enraged that they have been deceived for so long. All five Defendants have participated in this fraud over time periods ranging from weeks to years.
34. Defendants Steve Beshear and Dan Logsdon did everything they could to rig the Democratic primary election for Kentucky's 6th Congressional District in May, 2014 in favor of Elisabeth Jensen (D). The predictable result – the reelection of the appalling Andy Barr (R) on 11/4/14 by a landslide to a second two-year term – constituted a disaster for every resident of Kentucky, not just Democrats. If Ms. Jensen had dropped out of that race and supported the Plaintiff, he is almost certain he would now be serving as a Democratic member of the US House of Representatives. The more the Defendants use the dirty campaign strategy of refusing to debate any substantive issues with their primary election opponents, the more elections Kentucky Democrats will lose.
35. On 2/9/15, cn|2 political writer Kevin Wheatley reported, "Conway will almost certainly head the Democratic ballot this fall as his former chief deputy attorney general, Edgewood attorney Patrick Hughes, leads the Kentucky Democratic Party in his first election cycle as chairman, an appointment announced Saturday." [http://mycn2.com/politics/jack-conway-takes-reins-of-party-as-kentucky-democrats-rally-behind-new-generation-of-candidates] Plaintiff finds it interesting that Wheatley referred to Defendant Hughes' installation as an "appointment" rather than an "election." Plaintiff sees no way other than the filing of this lawsuit and a timely favorable verdict by a jury to correct the impression held by Kentucky's media professionals and voters of all parties that Defendant Conway's victory in the 5/19/15 primary election is virtually inevitable.
36. Kevin Wheatley's article continued, "Conway isn’t the only one with a heavy workload in the next eight months. Hughes said he plans to extend his message of unity to the party as a whole, not just in supporting this latest crop of candidates." Id. Defendant Hughes' "message of unity" is a fraud against Kentucky's Democratic voters, and all five Defendants are perfectly aware of that fact.
37. Wheatley wrote that several Democrats did not address the crowd, including "Conway’s opponent, retired engineer Geoff Young. He stood outside KDP headquarters holding a sign mocking Conway and Grimes as the event ended." Id. Plaintiff's hand-lettered sign read, "With Grimes and Conway, Democrats LOSE." Plaintiff asks the Court to take judicial notice that a sign of that nature does not reflect party unity.
38. Wheatley wrote, "Hughes said holding such an event for Conway and Grimes, who have not secured the party’s nominations, did not violate KDP bylaws." Id. Defendant Hughes was lying through his teeth that day.
39. Confirming Plaintiff's allegation that the Defendants' main concern is amassing the largest piles of money they can, as opposed to doing the will of Kentucky's Democratic voters, Hughes reportedly said, "Democrats will have 'plenty of money' for the fall campaign." Id.
40. Per Kevin Wheatley, “It’s clear that Jack Conway’s going to be our nominee for governor; it’s clear that Alison Grimes is going to be our nominee for secretary of state,” Hughes said. “So we’re comfortable moving forward on that. We’ve got a great team.” If Defendant Hughes meant by his last statement that he and the other four Defendants constitute an outstanding team of partisan crooks, he finally told the reporter something true.
VI. Claims for relief
41. Plaintiff seeks a huge amount of monetary damages pursuant to CR 8.01.
42. Plaintiff seeks a judicial determination declaring the following:
(a) That all five Defendants intentionally, willfully and maliciously violated several critical KDP bylaws during the course of the last 14 months;
(b) that these violations severely damaged Plaintiff's legitimate interest as a Democratic candidate for elected office;
(c) that all five Defendants should immediately be dismissed from any offices or positions they hold in the Democratic Party for intentionally violating certain key Bylaws and shall be prohibited from holding any office or position within the KDP for two years; [see KDP Bylaw I.H.]
(d) that the KDP's Executive Committee shall advertise the position of KDP Chairperson and search the Commonwealth for a qualified individual pursuant to the provisions of Bylaws I.F and I.G;
(e) that Governor Steve Beshear shall play no role in the election of the new Chairperson, notwithstanding any provision of the KDP Bylaws, because of his blatant betrayal of the trust of Kentucky's Democrats;
(f) that the KDP shall schedule one "Unity Press Conference" in each Congressional district, to be held before the 5/19/15 primary election, and shall invite the media and all Kentucky Democrats. The purpose of each event shall be to express Democrats' unity in support of the campaigns of Geoff Young for Governor, Charles Lovett for Secretary of State, and any other Democratic candidates they choose to support;
(g) that all five Defendants be required either to speak in favor of Plaintiff's and Mr. Lovett's candidacies in 2015 or protest by not attending any of the "Unity Press Conferences" described above;
(h) that all five Defendants be required to issue public apologies for betraying the trust of Kentucky's Democrats by attempting to make their primary election decisions for them in the cases of the constitutional offices of Governor and Secretary of State in 2015; and
(i) that the EC be required to ask its Bylaws Committee to overhaul the KDP Bylaws within the coming twelve (12) months to make them more democratic and less subject to abuse by a future Democratic Governor or any other individual.
43. Plaintiff has previously filed a case in this district.
44. Plaintiff requests a jury trial and an oral argument even though he is not an attorney.

Respectfully submitted,


Geoffrey M. Young, Plaintiff, pro se
454 Kimberly Place
Lexington, KY 40503
telephone number: (859) 278-4966
email address: energetic@windstream.net



Certificate of Service
I, Geoffrey M. Young, hereby certify that I have hand-delivered six copies of this Complaint to the Clerk of the Franklin County Circuit Court, paid the required fee, and caused her to serve Steven L. Beshear, Jack Conway, Alison Lundergan Grimes, Dan Logsdon, and Patrick Hughes pursuant to CR 4 and CR 5.

Delivered on this 2nd day of March, 2015, to:

Sally Jump, Clerk

Franklin County Circuit Court

222 St. Clair Street
Frankfort, KY 40601


by:

Geoffrey M. Young, pro se
454 Kimberly Place
Lexington, KY 40503


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