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,
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
Frankfort, Kentucky 40601
Serve:
Ms. Alison Lundergan Grimes
Office of the Secretary of State
700 Capital Avenue, Suite
152
Frankfort, KY 40601
Frankfort, KY 40601
Serve:
Mr. Jack Conway
Office of the Attorney General
700 Capital Avenue, Suite
118
Frankfort, KY 40601
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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