Kentucky Democratic Party Federal Denial Due Process Complaint 10.28.16

UNITED STATES DISTRICT COURT
EASTERN DISTRICT OF KENTUCKY

FRANKFORT DIVISION
CIVIL ACTION NO. 3:16-CV-62-GFVT
GEOFFREY M. YOUNG, pro se,
454 Kimberly Place
Lexington, KY 40503
Phone: (859) 278-4966
Email: energetic@windstream.net
Plaintiff ]
]
]
]
]
]
v.
]
]
SANNIE OVERLY, CLINT MORRIS,
]
]
ANDY BESHEAR, ALISON LUNDERGAN
]
]
GRIMES, JACK CONWAY, THE STATE
]
]
CENTRAL EXECUTIVE COMMITTEE
]
]
OF THE KENTUCKY DEMOCRATIC PARTY, ]
]
AND THE EXECUTIVE COMMITTEE OF
]
]
THE FAYETTE COUNTY DEMOCRATIC
]
]
PARTY,
Defendants ]
]
]
]
]
42 U.S.C. 1983 CIVIL RIGHTS

COMPLAINT FOR DAMAGES,
DECLARATORY AND
INJUNCTIVE RELIEF
JURY TRIAL DEMANDED
1. Electoral fraud sham elections
2. Denial of due process sham or no
procedures for resolving disputes
3. Official misconduct in the first degree
4. Deprivation of honest services
5. Violation of Executive ethics codes
6. Nullifying valid statutes
7. Intimidation by means of sanctions
8. Threats of physical force
Plaintiff alleges as follows:

JURISDICTION AND VENUE
1.
Jurisdiction is conferred on this Court by Title 42 U.S.C. 1983, Civil Action for
Deprivation of Rights; 18 U.S.C. 241, Conspiracy Against Rights; 18 U.S.C. 242, Deprivation of Rights Under Color of Law; 18 U.S.C. 245, Federally protected activities; 18 U.S.C.
1346, Deprivation of Right of Honest Services; and numerous state statutes. Venue is proper in
COMPLAINT FOR DAMAGES & INJUNCTIONS Page 1 of 48
the Eastern District of Kentucky because all the Defendants reside or hold regular meetings in
this district, and because a substantial part of the acts and omissions giving rise to the Plaintiffs
claims occurred in this district. Plaintiff seeks declaratory and injunctive relief and damages in
excess of the amount needed to establish the jurisdiction of this Court.
INTRODUCTION
2.
This is an action for damages, declaratory relief, and injunctive relief arising out
of a conspiracy by powerful Democrats, both in and out of Kentucky government, which

deprived Plaintiff of his due process rights guaranteed by the United States and Kentucky
Constitutions and statutory law. The rights that were violated included Plaintiff's rights to
compete for the nomination or election to certain offices for which he was otherwise eligible; to
appeal apparent violations to certain bodies tasked with resolving appeals and civil and criminal
complaints; to have those appeals heard on their merits; to be free of the exercise of arbitrary
power as guaranteed by Section 2 of the Kentucky Constitution; and to enjoy free and equal
elections (that are not sham elections) as guaranteed by Section 6 of the Kentucky Constitution.
THE PARTIES
3.
Plaintiff is a registered Democrat living in Lexington, Fayette County, Kentucky,
and is therefore a member in good standing of the Kentucky Democratic Party (KDP) and the
Fayette County Democratic Party (FCDP). He has lived in Lexington continuously since 1982,
and has been a Democrat during the time when all of the acts and omissions giving rise to the
Plaintiff's claims occurred, i.e., from November, 2013 to the present.
4.
The individual Defendants are highly influential, well-known members of the
KDP, the FCDP, or both. Defendant Andy Beshear has been Kentucky's Attorney General since
January 4, 2016, and he is being sued in that capacity as well as in his individual capacity as a
powerful Democrat. Defendant Grimes has been Kentucky's Secretary of State since January,
2012, and she is being sued in that capacity as well as in her individual capacity as a powerful
Democrat. Defendant Conway was Kentucky's Attorney General for eight years ending on
January 4, 2016, and he is being sued in his individual capacity as a powerful Democrat and
former Kentucky Attorney General. Defendant Sannie Overly, a Democratic member of the
Kentucky House of Representatives, fraudulently claims to be the Chair of the KDP, and
Defendant Clint Morris fraudulently claims to be the Chair of the FCDP. The State Central
Executive Committee (SCEC) of the KDP is a quasi-governmental Defendant that is the highest
deliberative and decision-making body of the KDP except for the few hours once every four
years when the Democratic State Convention is in session (presidential election years). The
Executive Committee (EC) of the FCDP is a quasi-governmental, organizational Defendant that
is the highest deliberative and decision-making body of the FCDP except for the few hours once
every four years when the Fayette County Convention is in session. By custom, county conventions in Kentucky are held a few weeks before the quadrennial Democratic State Convention.
5.
The organizational Defendants are not purely private or voluntary organizations
but semi-public, quasi-governmental institutions that have statutory duties assigned by the
Kentucky General Assembly. Kentucky's two major political parties have no members in the
sense that private organizations do. Voters affiliate with either (or neither) major party on their
own volition when they register to vote. No one admits a voter to membership nor may either
established party legally exclude anyone for any reason. The two parties receive public funds via
a tax return checkoff box. In return, the Democratic and Republican Parties have a legally
enforceable obligation to carry out their election-related duties in conformance with the laws and
regulations of the Commonwealth. Plaintiff will prove to the Court and jury that the KDP and
FCDP violated their most important contractual obligations to the Commonwealth and the
people of Kentucky.
6.
All five of the individual Defendants are alleged to be co-conspirators with each
other, in that each agreed to participate and participated in the furtherance of the objective of the
civil wrongs alleged in this Complaint. The KDP and FCDP encouraged their violations.
7.
Plaintiff is informed and believes and thereupon alleges that each individual
Defendant entered into a conspiracy and agreement with the other Defendants and/or
subsequently joined said conspiracy and ratified the prior acts and conduct of the Defendants
who had previously entered into said conspiracy. Plaintiff is currently unaware of when each
Defendant joined said conspiracy and, upon information and belief, alleges that all Defendants
have knowingly, maliciously, and willfully entered into said conspiracy, which are ongoing. The
purposes of this ongoing conspiracy include, but are not limited to, the wrongs alleged herein.
All of the Defendants acts and failures to act as alleged herein were perpetrated in furtherance
of the ongoing conspiracy.
8.
There are other co-conspirators not named as Defendants in this Complaint, who
may be called as witnesses.

9.
Plaintiff is informed and believes and thereupon alleges that at all times material
herein, each Defendant was completely dominated and controlled by his or her co-Defendants
and co-conspirators, each was the agent, representative, and alter ego of the others, and all aided
and abetted the wrongful acts of the others.
10.
Whenever and wherever this Complaint refers to any act or omission by a
Defendant or Defendants, such allegations and references shall also be deemed to mean the acts
and failures to act of each Defendant acting individually, jointly, and/or severally. To the extent
that said conduct and omissions were perpetrated by certain Defendants, Plaintiff is informed
and believes and thereupon alleges that the remaining Defendant and/or Defendants confirmed
and ratified said conduct and omissions.
11.
Whenever and wherever reference is made in this Complaint to any act by a
Defendant and/or Defendants, such allegations and references shall also be deemed to mean the
acts and failures to act of each Defendant acting individually, jointly, and/or severally.
12.
Whenever and wherever reference is made to individuals who are not named as
Defendants in this Complaint but are or were co-conspirators of Defendants, or any of them,
such references shall be deemed to mean that such individuals at all relevant times acted on
behalf of the Defendants.
FACTUAL ALLEGATIONS
13.
On June 4, 2016, the KDP held its quadrennial Democratic State Convention in
Louisville, Kentucky. It lasted all day, approximately 1,500 Democrats attended, several votes
were taken, and several Democrats made speeches. The presiding officer was Defendant Sannie
Overly, who claimed to be and presented herself all day as the Chair of the SCEC, also known as
the Chair of the KDP. Although one or more subcommittees had planned and set up the event,
Ms. Overly had established and given direction to the subcommittees and had the overall
responsibility for running the show. Many of the attendees had never attended a state convention
before, including the Plaintiff. There were no written agendas to hand out to the attendees, so
almost no one had any real knowledge of what would occur or when it would occur. All we
knew was that delegates supporting Hillary Clinton for President and delegates supporting
Bernie Sanders for President would be elected somehow to attend the July 25-28 Democratic
National Convention in Philadelphia; and that the KDP would somehow be reorganized,
whatever that might mean. The Democrats checking people in from 8:00 to 10:00 am were able
to answer virtually none of the questions Plaintiff and his colleagues had about the day's agenda.
Attendees were told at the end of each activity what activity would occur next, when, and in
which room.
14.
From 10:00 am to about 2:00 pm, the attendees' attention was directed toward
choosing delegates to the National Convention in Philadelphia on July 25 to 28, 2016. At 2:08
pm, substantially all of the 1,500 attendees gathered in a large auditorium. Defendant Overly,
standing on the platform at the front of the room, said, Welcome to the Democratic State
Convention. We're here to reorganize the party and select our delegation to the National
Convention. She introduced the newly-elected Vice-Chair of the KDP, Neville Blakemore,
without mentioning when, where, how, or by whom he had been elected. Several weeks earlier,
Plaintiff had learned that the Vice-Chair position had become open. He had submitted a written
application and resume but is unaware of whether Mr. Blakemore or anyone else had submitted
an application in writing. A couple of weeks before the Convention, Plaintiff had received an
email from Defendant Overly to the effect that the SCEC needed more time to fill the Vice-Chair
position. The announcement not the election of Mr. Blakemore as the new Vice-Chair took
Plaintiff completely by surprise. Mr. Blakemore, who will be called as a witness, talked about
how much wealthier the Republican Party of Kentucky was at that moment; stated, We're
Democrats... we're disorganized; said, We are the underdog; talked about Social Security,
Medicare, civil rights, voting rights, and Sannie's leadership; and declared that his Number 1
job is to Do what Sannie tells me.
15.
Mayor Greg Fischer welcomed the attendees to Louisville, and Congressman
John Yarmuth, representing Kentucky's 3rd Congressional District, talked about the importance
of boosting turnout among Kentucky's registered Democrats. Defendant Andy Beshear,
Kenucky's new Attorney General, talked about how his office was protecting children and
praised the many accomplishments of his father, former Governor Steve Beshear, who was the
next speaker.
16.
At 3:02 pm, Steve Beshear, who will be called as a witness, began describing how
his administration had handled extremely tight state budgets over his eight years in office; why
the Affordable Care Act needed to be defended against the new governor, Matt Bevin; and how
important voter turnout will be in November. He then asked Sannie and Neville to come back
up here to the stage. I want to ask this body to confirm them by acclamation, Steve Beshear
said. There were some cheers. I'm not even going to ask for nays, he concluded. Plaintiff stood
up to nominate himself for the position of Chair of the KDP but was not recognized, and the
room was too noisy for him to be heard. Defendant Sannie Overly immediately began giving a
four-minute acceptance speech. At 3:18, someone else took the podium to lead the attendees
through a series of votes on amendments to some KDP document or other. All seven proposed
amendments were approved by acclamation, even though Plaintiff stood up when the fifth
proposal was presented, voted No, and proposed an amendment to that amendment. He was
told that the proposals could not be amended, only approved. Robert's Rules of Order were
clearly violated in a manner that makes all the Defendants liable to suit under 42 U.S.C. 1983.
17.
Jim Gray of Lexington, who is running for US Senate against Rand Paul (R), gave
a stump speech from 3:28 to 3:43 pm. Sannie Overly then announced the results of the morning's
and afternoon's voting for members of the State Central Executive Committee (SCEC). Without
any transition or warning, Defendant Overly opened nominations for the DNC Committee
Woman, without telling anyone what that is. Defendant Alison L. Grimes, who was standing in
front of a microphone on the floor, screamed that she wanted to nominate her mother, Charlotte
Lundergan. Defendant Overly immediately asked for a motion to close nominations and said,
Nominations are closed approximately two seconds later. Charlotte Lundergan was
immediately elected by acclamation, having no opponents. Steve Beshear, who was standing in
front of another microphone, immediately nominated someone named Nathan Smith to be the
DNC Committee Man. Defendant Overly asked for a motion to close nominations. Plaintiff
stood up to nominate himself but was not near a microphone and was not recognized. About one
second later, Defendant Overly announced, Nominations are closed, and Mr. Smith was
immediately elected by acclamation, in malicious violation of Robert's Rules of Order.
Nominations were opened for at-large members of the SCEC. About 30 Democrats were
nominated by various people. No nominee was given an opportunity to make a campaign speech.
Plaintiff nominated himself but found out later that he had not been elected.
18.
State Representative Leslie Combs, who had announced her retirement from the
General Assembly but not from politics, spoke from 4:03 to 4:20 pm in order to get everyone
fired up. After an 18-minute break, Defendant Overly announced that there would be two
meetings after the close of the Convention, one of which would be a meeting of the new
members of the SCEC. Defendant Overly announced that nominations were open for the
superdelegates pledged to support Bernie Sanders for President. After those nominations closed,
nominations were opened for superdelegates pledged to support Hillary Clinton for President.
After those nominations closed, Defendant Grimes came forward to talk about famous Kentucky
Democrats who had died during the last four years. First, however, she talked about some of
Donald Trump's (R) positions on a few issues, asking, Do you want a wall? The crowd
shouted, No! Do you agree that more countries should have nuclear weapons? No!
Defendant Grimes continued, We want a Democrat in the White House, and I hope and pray it's
a woman! No supporter of Bernie Sanders for President was ever given an opportunity to make
a speech to the Convention. A slide show pictured 25 Democrats who had died, and a break was
called at 5:08 pm. More minor posts were filled, the winners were announced, and the State
Democratic Convention ended at 6:04 pm. Plaintiff stayed at the first post-Convention meeting
of the new SCEC until 6:55 pm, but nothing of note occurred.
19.
It took Plaintiff a day or two to realize that when the results of a given election
during the Convention had few if any important implications for the future of the KDP, voting
procedures that faintly resembled democratic procedures had been used. When the results were
important to the Defendants and their co-conspirators, however, democratic procedures were
totally dispensed with. In the case of the most important decision of the day, the naming of the
Chairperson and Vice-Chair of the KDP to four-year terms, no election was conducted at all.
Nominations were never open, candidacy statements were never asked for or distributed to
attendees, no nominee other than Defendant Overly was allowed to speak to the decision-making
body, no warning was given of the upcoming vote, no actual vote was allowed, and no one but
co-conspirator Steve Beshear was allowed to nominate and recommend anyone. A sham election
had occurred, and Defendant Overly and (future witness) Neville Blakemore had been rammed
down the throats of the KDP's highest authority the Convention attendees assembled using a
type of procedure that could have been used in any dictatorship in the world. By custom, for
many years the Chair of the KDP has wielded vast, sweeping powers.
20.
When a political party organizes and conducts a sham election for important
offices and positions that is reminiscent of any dictatorship, it has violated a sacred public trust
and 42 U.S.C 1983, fostered cynicism throughtout the entire society, and violated an actual
contract with the public. The Charter of the Democratic Party of the United States contains the
following sentence in its Preamble: Bound by the United States Constitution, aware that a party
must be responsive to be worthy of responsibility, we pledge ourselves to open, honest endeavor
and to the conduct of public affairs in a manner worthy of a society of free people. That is a
solemn commitment, in the nature of a contract, to the country's Democrats and all other
Americans as well. If the Defendants are honest, however, they would propose that the following
sentence be added: In states such as Kentucky, however, the current Party leaders should
dispense with every known democratic procedure and install their favored nominees in powerful
positions after holdling closed meetings in smoke-filled rooms, rigging Party elections,
preventing voters from obtaining any pertinent information about the choices they will be asked
to vote on, and behaving in an irresponsible manner worthy of any dictatorship in the world.
21.
On January 30, 2016, the SCEC held a meeting in its Headquarters on Democrat
Drive in Frankfort. Plaintiff attended the first part of the meeting, even though the meeting had
never been publicized on the KDP's web site. Plaintiff had found out about the meeting only by
stopping in at the Headquarters building a couple of days earlier and asking the receptionist if
any SCEC meetings had been scheduled for the year 2016. Having heard at the previous SCEC
meeting, which hadn't been publicized on the KDP web site either, that the Chair, Patrick
Hughes, was either planning to resign or had already resigned, Plaintiff had submitted a formal
application on 1/13/16 to the SCEC to be elected to the vacant or soon-to-be vacant position. He
had also requested an interview by an ad-hoc subcommittee that had been formed to accept
applications and interview candidates. As is the norm in voluntary and quasi-governmental
organizations, any member of the organization was eligible to apply. The subcommittee never
contacted Plaintiff about his application or request. Plaintiff was never informed whether anyone
else had submitted an application or whether the subcommittee had ever met or interviewed
anyone. A legitimate organization publicizes all of its upcoming board meetings to its members.
If it has a web site, a legitimate organization never fails to post notices of important upcoming
meetings on its web site. In the Plaintiff's experience between November, 2013 and the present
date, however, the KDP has never publicized any upcoming meeting of the SCEC, which is
equivalent to the board of directors of any voluntary organization, public or quasi-governmental
commission, or corporation that has a board. By failing to inform its members of upcoming
vacancies, meetings, and important votes, the KDP has been operating ultra vires for at least the
last 31 months. None of the decisions or other actions the SCEC has taken during that time were
legally binding or valid; any or all of them may be challenged by Plaintiff as contractual
violations and overturned by this Court for having been made in a facially unlawful and
antidemocratic manner; and all of them must be done over in a lawful manner. These demands
can and should be implemented by injunctions and declaratory Orders.
22.
About halfway through the meeting on 1/30/16, the acting Chairperson (a
Democrat other than Defendant Overly and unknown to Plaintiff) announced that the SCEC
would be going into a closed session to deal with a personnel matter and that all guests must
leave the room. Appellant immediately raised a point of order and said, more or less, This
meeting was not properly publicized, so any decisions made here today would be illegal. After
a minute or so, the acting Chairperson replied to the group more or less as follows: In response
to the point of order, this meeting was properly publicized. Plaintiff replied in support of his
point of order, effectively appealing the ruling of the acting Chair, but about half the guests
were already on their way out the door. Plaintiff followed them under protest. The governing
body never debated or voted on his point of order, which constituted a willful and blatant
violation of Robert's Rules of Order.
23.
Closed sessions of the SCEC where important decisions are made are illegal per
se. Any voluntary, mass-based political organization that claims to operate in a democratic
manner would ensure that all public meetings at all levels of the organization would be open to
all members of the organization and to the media. In the real world, secrecy and corruption go
together. So do secrecy and criminality. The SCEC is the highest deliberative and decisionmaking body of the KDP except when a statewide party convention is in session, which occurs
for a few hours only once every four years. There is no valid justification for the SCEC's
deliberations and votes ever to be secret from the Commonwealth's 1.6 million Democrats or the
general public. Secret meetings or secret sessions of public meetings can quickly lead to the
abandonment of democracy and violation of rights, which is what has occurred in the case at bar.
24.
The election of a new State Party Chairperson is not a personnel matter that
may be kept secret in a democratic republic. The notion is literally absurd; it is like conspiring to
prevent the voters from playing any role in selecting the next governor or president because
those are private personnel matters. By custom, the Chairperson of the SCEC exercises vast,
sweeping powers, and to keep secret the process by which the Chair is elected inevitably brings
public suspicion upon the KDP and all of its other decisions and activities. What are they trying
to hide? How ironic for them to call their party 'Democratic.' The Congress of the United
States hardly ever uses closed sessions, even though some of its deliberations and decisions have
implications for national security. The United States Senate has been called into closed session
only 54 times since 1929, and the U.S. House of Representatives has met in closed session only
six times since 1825. The SCEC has never had a legitimate reason to expel any Kentucky
Democrat or any reporter from any part of any of its meetings.
25.
On Saturday, 1/30/16, Plaintiff was prepared to nominate himself to the position
of Chair of the KDP, but he was never given any opportunity to do so. On that day, the unlawful
use of a closed executive session of the SCEC was maliciously used to prevent Plaintiff from
exercising his constitutional right, guaranteed by 42 U.S.C. 1983, to nominate himself to a
position for which he was otherwise legally and technically qualified. Plaintiff would have
requested an open debate to include himself and any nominees put forward by the SCEC's adhoc subcommittee. A reporter who witnessed at least the first part of the meeting mentioned in a
news report that Sannie Overly was elected by unanimous vote. The reporter did not mention,
nor does Plaintiff yet know, whether the SCEC ever considered any nominees other than
Defendant Overly on 1/30/16 during its secret session. Unanimous, secret votes for the next
General Secretary of the ruling Communist Party were the norm in the old Soviet Union before it
collapsed. Such votes usually followed the elimination of competing candidates by any means
necessary, leaving only one nominee for the Soviet Politburo to elect.
26.
Defendants are sued under 42 U.S.C. 1983 for conducting a sham election for
the extremely important position of Chair of the KDP in the days up to and including 1/30/16.
Any voluntary organization that was democratically controlled would have filled its highest
executive position by fully publicizing a full description of the legal and practical procedures for
selection of the new Chairperson. Notice would have been given to all interested Democrats and
the media. Publication of said procedures would have been done in such a fashion that all current
and prospective members of the KDP were fully and adequately informed of the pertinent
procedures in time to participate in the process of vetting and electing the new Chair and Vice
Chair, or in time to compete for the offices themselves. Moreover, any truly democratic
organization would have timely published a complete description of the legal and practical
qualifications for the Chair position. A genuine, democratic election would have included the
review of a number of applicants' qualifications, interviews with the most qualified candidates,
the submittal of candidacy statements to the SCEC or its subcommittee, speeches by the
candidates to the full SCEC on 1/30/16, questions to several candidates from the members of the
SCEC, an open debate among the members of the SCEC, and an open, public vote. Virtually
none of that was done on or before 1/30/16. The secret, closed election or selection of Defendant
Overly on that date obviously constituted a sham election, which violated 42 U.S.C. 1983
because the KDP is a quasi-governmental institution. The real decision was not made by the full
SCEC on that date but by the Defendants and perhaps a few other co-conspirators such as former
Governor Steve Beshear at some time, unknown to the Plaintiff, before the SCEC meeting. The
SCEC acted as a mere rubber stamp on 1/30/16, and Plaintiff was unlawfully deprived of the
right to compete for the position of Chair of the KDP.
27.
Two days after the sham election, on 2/1/16 the Plaintiff appealed certain of the
SCEC's actions to the SCEC, including the undemocratic, allegedly unlawful procedure it had
just used to select Defendant Overly as the new Chairperson to replace Patrick Hughes, whose
term in that position had lasted only one year. Plaintiff complained about the illegality of both
the unpublicized public portion of the meeting on 1/30/16 and the even more secret part of the
meeting during which Defendant Overly had apparently been selected. Plaintiff requested a
hearing of the SCEC to hear his written appeal and resolve the disputes. A few weeks later,
Plaintiff received a letter from Sannie Overly stating that the SCEC would hear the appeal on
4/30/16 at the KDP Headquarters building in Frankfort. The location of the hearing was later
changed to Morehead, Kentucky, but the date remained the same.
28.
On 4/14/16, Plaintiff mailed a note to Defendant Overly asking her to provide a
copy of his 7-page appeal to every member of the SCEC. In addition, Plaintiff asked her to
provide them with a copy of a motion for discretionary review that Plaintiff had filed with the
Kentucky Supreme Court on 4/6/16, and stated, It is an integral part of my appeal. Plaintiff
also asked Defendant Overly for a copy of all documents that might have been filed in response
to his appeal by every other party, which was in conformance with what any reasonable person
would consider to be due process. In a civil or criminal appeal, for example, all parties or their
attorneys are legally required to send copies of their pleadings, responses, motions, and
attachments to the judge and to all the other parties. Justice requires no less. There was no reply
from Defendant Overly, which suggested to the Plaintiff that no other parties had filed any
written responses to his appeal.

29.
On 4/20/16, ten days before the scheduled hearing, Plaintiff mailed another appeal
by certified mail to Defendant Overly, which appealed the election of Defendant Clint Morris as
Chair of the FCDP. Plaintiff had learned about an unpublicized, secret meeting that had occurred
in Lexington on 4/16/16 at which Defendant Morris had been elected, without any semblance
of a democratic vote, by a small minority of the members of the FCDP Executive Committee and
an even tinier minority of Fayette County Democrats. See Paragraphs 35 to 38 below. Plaintiff
asked Defendant Overly to include the appeal against Defendant Morris as part of the 4/30/16
hearing at which her own election as Chair of the KDP would be adjudicated by the SCEC.
Plaintiff did not receive any reply from Defendant Overly or any member of the SCEC until after
the 4/30/16 hearing had begun.
30.
On 4/30/16, Plaintiff arrived an hour early at the Morehead Conference Center for
the scheduled hearing of his appeal. The annual convention of the Kentucky Young Democrats
(YD) and College Democrats organizations was in progress. Plaintiff removed an antiwar sign
from his backpack and stood outside the room where about 25 or 30 YDs were listening to a
lecture by an older Democrat. Plaintiff never caused the slightest disturbance to the lecture and
never entered the lecture room. Liz Fossett, one of the Vice Presidents of the YDs, and Josh
Monroe, a former YD officer known to the Plaintiff, immediately threatened to call the police if
he didn't leave the entire building, not just the area outside the room the YDs were using. Several
police officers happened to be attending their own conference down the hall, and the YD
officials mentioned how easy it would be to call them over to arrest him. Plaintiff said, What
about freedom of speech? but did leave the building for an hour. In Plaintiff's experience with
Kentucky police officers since 1982, they sometimes use grossly excessive force and even
violence when arresting a nonviolent suspect, and the trend is worsening. Plaintiff considers the
threat made by the two YD officials to have been an unjustified, unlawful threat of force in order
to violate his constitutional rights to freedom of speech and peaceable assembly. Their action
constituted another violation of 42 U.S.C. 1983, although Plaintiff did not know it at the time.
31.
4/30/16 was not the first or last time Plaintiff has been threatened with physical
force by a Democratic Party official for exercising his First Amendment rights of free speech,
free association, and freedom of movement. On 3/13/14, Plaintiff attempted to attend the regular
meeting of the Executive Committee of the FCDP. As Plaintiff was coming in the back door, he
saw Bob Layton, who had recently been rammed through as the new Chair of the FCDP, coming
in the front door. They met in the hallway outside the meeting room. "Stand right here," Layton
ordered. Plaintiff did so. Layton got two or three other large, scowling men to stand next to him
and loudly delivered what Plaintiff felt was a rehearsed address approximately as follows: "You
have been disruptive. We operate by Robert's Rules of Order, and you violated them. You are not
a member of the Executive Committee. If you try to go in tonight I will call the police and have
you arrested." Layton then handed Plaintiff a four-page document. Since it was clear that
Layton's threat was serious, Plaintiff left the premises. The document included the sentences,
"You will be trespassing if you refuse to leave." Also, "Your disorders interfere with the business
of the FCDP. This letter is to inform you that the above steps are effective immediately upon
your receipt of this letter, and that the police are being called now to respond to your refusal to
leave." Layton had written his threatening statement under the assumption that Plaintiff would
enter the FCDP meeting and would refuse to leave, neither of which occurred. Plaintiff was an
active, Democratic (primary) candidate for the U.S. House of Representatives, i.e., a federal
candidate, when Layton threatened him with force on 3/13/14, violating 42 U.S.C. 1983.
32.
When the meeting of the SCEC began on 4/30/16, Defendant Overly was chairing
it. Plaintiff noticed someone else, unknown to him, sitting next to her at a table at the front of the
room. The dialogues in this paragraph and Paragraph 33 are reconstructed from memory and are
therefore approximate. Defendant Overly began by congratulating Defendant Clint Morris on his
election as Chair of the FCDP. She then announced that the first item of business would be an
appeal by Geoff Young and invited Plaintiff to come up to the front of the room to state his
appeal. Plaintiff was amazed to see that Defendant Overly was clearly planning to preside over
the hearing at which she herself was one of the appellees. Plaintiff began by stating that one of
the decisions he was appealing was the undemocratic election of Defendant Morris as Chair of
the FCDP on 4/16/16. Defendant Overly, acting like a judge, interrupted him to say that that
appeal would not be heard that day but at a later date.
33.
Plaintiff then said to the members of the SCEC, I assume you've all received a
copy of my 7-page appeal. Defendant/Judge Overly interrupted again and said, You are to ask
questions of the Chair, not the members of this Committee. Plaintiff: You didn't even distribute
copies of my appeal to the members of the State Central Executive Committee? Defendant/
Judge Overly: Please just go on and state your appeal. Plaintiff: Okay, I'll read it aloud.
Plaintiff began to talk about his allegation that grossly inadequate notice had been given to
Kentucky's Democrats about the 1/30/16 SCEC meeting at which Defendant/Judge Overly had
been selected as Chair. He managed to state that in his personal experience between December
2013 and the present date, notices of upcoming meetings of the SCEC were never posted on the
KDP's web site. Plaintiff said that the failure to inform Kentucky's Democrats made the meetings
unlawful and should invalidate every decision made by the KDP during the last two and a half
years. Members of the SCEC began interrupting Plaintiff, and Defendant/Judge Overly
encouraged them to do so by recognizing each member. One asked in a hostile manner, What
are you demanding that we vote on? Plaintiff answered, For one thing, the entire process of
searching for, interviewing, and voting for a KDP Chairperson must be done over and done
right. When Plaintiff said, No closed sessions of meetings are allowed in an organization that
claims to be democratic. In the real world, (reading from page 4 of his appeal) secrecy and
corruption go together. So do secrecy and criminality. Another member of the SCEC interrupted
to say, You just used the word 'corruption.' I want to know what you meant by that. Plaintiff:
We'll get to that. A member from Fayette County said, Mr. Young would be ineliglible to hold
any office in the KDP because he didn't support Jack Conway, the Party's nominee for Governor,
last year. He also attended a meeting of the Women's Network and held a sign that said, 'Clinton
is a war criminal.' Another member said, How can you say you didn't receive notice about
upcoming meetings when you attended the meeting in January and you're here right now? You
found out about them, so how could they have been secret? A new member of the SCEC said, I
make every effort to inform members of the Northern Kentucky county parties about upcoming
meetings of the SCEC. We're doing our best to operate in a proper manner. Defendant Overly
stated that Plaintiff would be given one more opportunity to speak, and that a time limit of five
more minutes had been set for this agenda item. Plaintiff replied to the new member, saying that
while his personal intentions might have been the best, the committee as a whole had been
operating unlawfully, undemocratically, and ultra vires at least since December, 2013, and
possibly for years before that. Plaintiff was never able to say anything about his most serious
allegations, because when he tried to start talking about the fifth element of his appeal, a longtime member, Joe Graviss, interrupted him to say, This hearing isn't about that. You just said
you were appealing the election of Sannie Overly as Chair. I'm getting tired of all this grandstanding. The hearing ended with a unanimous vote against Plaintiff's appeal, the bulk of
which the SCEC had never even heard or read. Plaintiff left the meeting immediately thereafter.
34.
The entire hearing on 4/30/16 was a farce, a sham, and a fraud that violated 42
U.S.C. 1983 because it violated his due process rights to a fair hearing. The procedure that
would be followed on 4/30/16 was never made clear to the Plaintiff, even after the hearing
began. The judge was one of the defendants and had every motive to run a kangaroo court.
The jury had never been given a copy of the Plaintiff's appeal, even though Defendant/Judge
Overly had had three months to convey it to them electronically or by mail. Various members of
the SCEC interrupted Plaintiff so many times with hostile questions that they never heard his
most serious accusations at all. It is possible that Defendant/Judge Overly had conspired ex
parte with some of the SCEC members who interrupted Plaintiff that day in order to help them
prepare their rude and disruptive remarks. Several of the most important defendants (or
witnesses) had not been invited by Defendant/Judge Overly and were not there to defend their
actions and omissions. That was of little consequence, however, because the Plaintiff was not
allowed to present his appeal or question any witnesses anyway. The person sitting next to
Defendant/Judge Overly turned out to be her attorney. Absolutely no due process was afforded
the Plaintiff. The incident proved conclusively that the KDP has no legitimate process in place to
resolve high-level disputes between Democrats, nor does the SCEC presently have the slightest
interest in developing a fair process to resolve disputes or hear appeals from members. Plaintiff
demands that they do so. As matters stand today, any Kentucky Democrat needing to appeal a
decision of the SCEC might as well forget about obtaining anything resembling justice, fair
treatment, or due process. The SCEC is being sued for allowing, helping, and encouraging the
other Defendants to turn the KDP into a dictatorship and the SCEC into a junta for all intents and
purposes, which constitutes a violation of 42 U.S.C. 1983.
35.
On 4/16/16, the Fayette County Democratic Party (FCDP) held its Legislative
District Convention, also known as its County Convention, which occurs only once every four
years. The event was tightly scripted and moved along for two hours as planned and previously
announced. Then almost everyone, including the Plaintiff, left. Then another meeting occurred
which simply hadn't been announced. No notice had been given to the large majority of the
attendees that this second meeting would occur after the convention. Apparently, as Plaintiff
heard on the evening of 4/19/16 for the first time, Defendant Clint Morris had been elected
Chair and Andrea Ewen elected Vice-Chair of the FCDP. As is the norm in voluntary
organizations, any Democrat registered in Fayette County was eligible to apply. If Plaintiff had
known there was going to be a meeting after the FCDP quadrennial convention to elect the next
Chair and Vice-Chair, he would surely have attended and nominated himself for the Chair
position. Some other strong supporters of Bernie Sanders for President would also have stayed
around on 4/30/16 and either nominated themselves or watched and listened to the proceedings.
36.
Exactly as in the Statewide Democratic Convention that would be held on 6/4/16,
when the results of a given election during the Fayette County Democratic Convention had few
if any important implications for the future of the FCDP, voting procedures that were almost
democratic had been used. When the results were important to the Defendants and their coconspirators, however, democratic procedures were entirely absent. In the case of the most
important decision of the day, the naming of the Chairperson and Vice-Chair of the FCDP to
four-year terms, no open, democratic election was conducted at all. Nominations were never
open to the Democrats attending the County Convention, candidacy statements were never asked
for or distributed to attendees, no nominees at all were allowed to speak to the County
Convention, which should have been the body voting to elect the County Chairperson, no
warning was given of the upcoming, unpublicized meeting, and only a tiny percentage of the
Democrats who attended the Convention made the momentous decision. The full FCDP
Executive Committee had not even been elected yet. A secret, illegal election occurred on
4/16/16, and Defendant Morris and (future witness) Andrea Ewen were rammed down the
throats of the county's Democrats using a type of procedure that could have been used in any
dictatorship in the world. Defendant Clint Morris and the Executive Committee of the FCDP
clearly violated 42 U.S.C. 1983. By custom, for many years the Chair of the FCDP has
wielded vast, sweeping powers in the county.
37.
Exactly as in the unlawful, secret election of Defendant Overly as Chair of the
KDP on 1/30/16 and in her unlawful, facially undemocratic confirmation on 6/4/16,

Defendants are sued for conducting an illegal election for the extremely important position of
Chair of the FCDP in the days up to and including 4/16/16, . Any voluntary organization that
was democratically controlled would have publicized the upcoming election and the
qualifications of the position fully. Plaintiff would have applied, and had applied for the position
of FCDP Chairperson a little over a year before when the position had become vacant. Such
publication would have been done in a timely fashion so that all prospective candidates for the
Chair position would have had full and adequate opportunity to compete for the office. A
genuine, democratic election would have included the review of a number of applicants'
qualifications, interviews with the best candidates, the submittal of candidacy statements to
every Democrat attending the Fayette County Convention or to the FCDP's full Executive
Committee, speeches by the candidates to the full County Convention on 4/16/16 or to the full
FCDP Executive Committee after all of its members had been seated, questions to several
candidates from the registered Democrats attending the County Convention, an open debate, and
an open, public vote. Virtually none of that was done on or before 4/16/16. The secret, closed
election or selection of Defendant Morris on that date was blatantly illegal because it violated 42
U.S.C. 1983. The real decision was not made by the Fayette County Convention on 4/16/16
but by the Defendants and perhaps a few other co-conspirators at some time, unknown to the
Plaintiff, before the County Convention. Defendants had unlawfully prevented both the County
Convention and the full Executive Committee of the FCDP from voting at all for their future
Chairperson. Plaintiff was presented with a fait accompli at a meeting of a different organization,
The Women's Network, three days after the illegal, secret election had occurred. Plaintiff was
unlawfully deprived of his right to compete for the position of FCDP Chairperson, thereby
harming his political career.
38.
Defendant Morris has refused to bring the Plaintiff's appeal of the 4/16/16
election (or any other fraudulent election) before the FCDP, even for purposes of discussion,
has forwarded all pertinent documents to the KDP in Frankfort, and has refused to talk with
Plaintiff about resolving the controversy at any level other than the SCEC of the KDP, where, as
Plaintiff has described in Paragraphs 27 through 34 above, no functioning mechanism exists to

resolve serious disagreements among Democrats. The SCEC of the KDP could have chosen to
hear the Plaintiff's appeal against Defendant Morris on 4/30/16, but Defendant/Judge Overly
decided unilaterally to postpone that item until September 17, 2016. The farcical hearing on
4/30/16 was only slightly more violative of Plaintiff's due process rights than the one that took
place on 9/17/16. Once again, Defendant Overly had failed and refused to provide a copy of
Plaintiff's two-page accusation to each member of the SCEC. Once again, an open discussion
was prevented, and once again, justice was denied, violating Plaintiff's due process rights and 42
U.S.C. 1983. Defendant Morris has threatened Plaintiff with force (arrest for trespassing) on
three more occasions since August 19, 2016, in the presence of many FCDP members.
39.
On 2/7/15, the SCEC held an unpublicized meeting at which the Chairperson of
the KDP, Dan Logsdon, was replaced by Patrick Hughes, a close associate of then-Attorney
General Jack Conway (D), who was running for Governor. Plaintiff was unaware of the meeting
because no notice of it had been posted on the KDP's web site. Plaintiff had been expressing
great interest, publicly and repeatedly, in replacing Logsdon as the KDP Chairperson since
November 2014, when Kentucky's Democrats did very poorly against Mitch McConnell and
other Republican candidates. The SCEC demonstrated gross negligence and actual malice
between November 2014 and February 2015 because it failed to publicize the fact that Dan
Logsdon was about to resign and a new Chair would be needed. If Plaintiff had known that there
was a possible opening and that the SCEC might fill it on 2/7/15, he would have applied in
writing for the position of KDP Chair, somehow found out about the SCEC meeting, attended it,
nominated himself, made a speech to the SCEC, and answered questions about his qualifications.
40.
In January, 2015, Plaintiff had filed to run for the Democratic nomination for
Governor (along with Johnathan Masters for Lieutenant Governor). Defendant Jack Conway was
the only other candidate, and Defendant Sannie Overly was his running mate for Lieutenant
Governor. On Monday, 2/9/15, the SCEC held a "Unity Press Conference" at the KDP
Headquarters building in Frankfort, where then-Governor Steve Beshear, Defendant Jack
Conway, Defendant Alison Lundergan Grimes, and several other prominent Democrats
expressed their unity with and support for each other. Before the speeches began, Plaintiff asked
the brand-new Chairperson of the KDP, Patrick Hughes, for permission to speak and was denied.
Shortly after the Unity Press Conference ended, Mr. Hughes said to a reporter, 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. To name candidates is to nominate them; thus, the SCEC and
the brand-new KDP Chair officially nominated Defendants Conway and Grimes on 2/9/15,
despite the fact that the primary election was still more than three months away, on 5/19/15. For
a political party to nominate its candidates three months ahead of the vote is to turn the entire
primary election into an empty, undemocratic exercise, a sham that violates 42 U.S.C. 1983.
41.
Defendants and Chairman Hughes violated Kentucky law when they nominated
Defendant Conway on 2/9/15, announced their decision to the public, and then made sure that
the KDP promoted, supported, and allocated resources to Conway and not his opponent (the
Plaintiff) from 2/9/15 until 5/19/15. KRS 118.105 (1) reads as follows:
Nominations by political parties -- Vacancy in candidacy -- Replacement
candidates -- Exceptions -- Ineligibility of Senior Status Special Judge.
(1) Except as provided in subsections (3) and (4) of this section and in KRS
118.115, every political party shall nominate all of its candidates for elective
offices to be voted for at any regular election at a primary held as provided in this
chapter, and the governing authority of any political party shall have no power to
nominate any candidate for any elective office or to provide any method of
nominating candidates for any elective office other than by a primary as provided
in this chapter.
This is the Kentucky statute that specifies clearly and emphatically that no method of
choosing Democratic (or Republican) nominees is lawful other than a "free and equal" primary.
[See Section 6 of the Kentucky Constitution] Most enabling statutes do not repeat themselves by
stating that no other method to accomplish the specified goal is allowed, but free and equal
elections are so important to the life of a democratic republic that the General Assembly felt that
the inclusion of a slightly redundant clause the last four lines was necessary. The Defendants
and their co-conspirators developed an antithetical, facially unlawful process to nominate Jack
Conway for Governor more than three months before the primary election and sideline the
Plaintiff, in complete contempt for the law and the freedom of Kentucky's 1.6 million registered
Democrats to enjoy an election untainted by any type of fraud, intimidation, bribery, or any
other corrupt practice. [Kentucky Constitution Section 151] The Defendants and their coconspirators committed the worst election fraud in Kentucky history to date: stealing an entire
primary election by turning it into a sham election, thereby also violating 42 U.S.C. 1983.
42.
Between 2/10/15 and 2/12/15, Plaintiff contacted Patrick Hughes and then-
Governor Steve Beshear and demanded, in writing, that the SCEC hold a hearing as soon as
possible to review and overturn its own actions in connection to the bogus Unity Press
Conference on 2/9/15, at which Defendant Jack Conway had been illegally nominated for
Governor and Defendant Alison L. Grimes had been illegally nominated for Secretary of State.
Neither Democrat ever replied to Plaintiff in any way, and Chairman/Dictator Hughes never
scheduled a hearing of the SCEC, proving that the KDP was not a democratic organization but a
petty dictatorship or an ongoing criminal enterprise during the entire period between 2/9/15 and
Hughes' resignation one year later. A quasi-governmental institution that has no functioning
mechanism to resolve appeals or disputes does not meet the definition of a legitimate or
democratic organization. The Kentucky Democratic Party is not democratic at this time.
43.
During 2015, Plantiff initiated three civil actions to bring the lawbreaking
Defendants to heel. None of his complaints was ever heard or adjudicated on its merits. No
responsive pleading was ever filed by Defendant Alison L. Grimes, Defendant Jack Conway,
Steve Beshear, Patrick Hughes, or Dan Logsdon. They and their two attorneys filed only CR
12.02 motions to dismiss. Each such motion was poorly reasoned, unsupported by facts, logic, or
any Kentucky statute; each was shown to be wholly lacking in merit, even frivolous; and each
motion to dismiss was sustained by a series of Kentucky judges, most or all of whom happened
to be Democrats. Every appeal Plaintiff made to the Kentucky Court of Appeals was dismissed,
and all three of the motions for discretionary review Plaintiff made to the Kentucky Supreme
Court were denied without explanation. The third was denied in a one-sentence Order dated
8/17/16. Plaintiff is including these facts in this Complaint because they bear on obstruction of
justice, a federal violation.
44.
Many of the arguments Defendants Conway and Grimes and the other defendants
made in 2015, by counsel, in support of their three Kentucky Civil Rule 12.02 motions to
dismiss were frivolous, impudent, and astonishing, and include the following:
- No court may ever review actions and omissions by leaders of the Democratic or
Republican Parties, no matter what violations they are alleged to have committed. A state court
case, Rosenberg v. Republican Party of Louisville, 270 S.W.2d 171 (Ky. Ct. App. 1954) may
overrule and negate the decision in Smith v. Allright, 321 U.S. 649 (1944). (3/24/15)
- Although the landmark decision in Smith v. Allwright, 321 U.S. 649 (1944) established
that courts may review and overturn practices of a state Democratic Party (Texas) that turned its
primary elections there into unfair, undemocratic, sham elections, no court in America may even
review any allegedly unfair, undemocratic KDP practices unless they involve racial
discrimination. No other corrupt practices by Party leaders may ever be reviewed by any court.
- Even if the leaders of the KDP violate one or more statutes or sections of the
Constitution, the courts may not even hear a civil complaint because the question is one
essentially political, and not judicial, in its character. (3/24/15)
- Parties themselves are the arbiters of their own rules, even if the KDP has no written
rules that it follows and has no functioning mechanism to adjudicate procedural disputes or
provide even basic due process. The KDP makes up its own rules as it goes along. (3/24/15)
- Intra-party disputes are non-justiciable, even if constitutional and civil rights of a
Party member (as enumerated in 42 U.S.C. 1983) are being maliciously, systematically and
chronically violated. (3/24/15)
- A primary election is not an election, so it does not have to be free and equal, no matter
what Section 6 of the Kentucky Constitution might say.
- Plaintiff's written letters and emails to Patrick Hughes (2/10/15) and Steve Beshear
(2/12/15) do not count as going through administrative channels because neither powerful
Democrat ever chose to respond to the letters and emails. Plaintiff therefore may never take them
to court. (3/24/15) Plaintiff has demonstrated above that if the KDP has any administrative
channels to resolve disputes or appeals, they simply do not function. They are sham procedures
and a bad joke. Violating Plaintiff's due process rights violates 42 U.S.C. 1983.
- A motion to dismiss that responds to none of the specific allegations in a complaint is
actually a responsive pleading. (4/27/15)
- The only grounds upon which a Democrat may challenge the good faith and bona fides
of a Democratic candidate under KRS 118.176 are the age and residency requirements. (5/11/15)
- Even if a challenger can make a prima facie case that a candidate has been acting in bad
faith for months and/or has committed election fraud on a massive scale, the challenger may not
file a civil lawsuit (i.e., a pre-election challenge under KRS 118.176) if the candidate has met the
age and residency requirements. Note: The title of KRS 118.176 is, Challenging good faith of
candidate. (5/11/15)
- Plaintiff did not accuse the five powerful Democrats of violating any Kentucky statutes
or sections of the Kentucky Constitution until after the Franklin Circuit Court had thrown out his
civil complaint on 5/1/15. [Brief of Appellees, 9/11/15] In fact, Plaintiff had accused them of
violating KRS 118.105 (1) and two sections (6 and 151) of the Kentucky Constitution a full
month before, in Plaintiff's 4/1/15 Answer to Both Motions to Dismiss. In other words, the
five Democrats (by counsel) attempted to lie to and thereby defraud the Kentucky Court of
Appeals. The five powerful Democrats never asked any court to excuse their false statement(s).
- Despite the plain language of Section 115 of the Kentucky Constitution, a challenger
who believes a circuit court wrongly threw out his or her challenge may not appeal to any higher
court; only the challenged candidate may appeal an unfavorable circuit court decision to the
Kentucky Court of Appeals.
- A circuit court judge may delay ruling on a challenge made under KRS 118.176 for nine
weeks or longer, even though the statute states that The motion [i.e., challenge to a candidate]
shall be tried summarily and without delay. In other words, Kentucky circuit court judges may
violate the plain language of governing statutes at will.
- Contrary to all controlling case law, the doctrine of res judicata (claim preclusion)
prohibited Plaintiff from filing a second lawsuit against Defendant Jack Conway that was totally
different from his previous lawsuit. Specifically, the cause of action was completely different,
two different elections were involved, and the first lawsuit was never resolved on its merits.
Only the two parties were the same. (11/9/15) No lawsuit filed by Plaintiff in 2015 has ever been
heard or adjudicated on the merits.
- A 64-page criminal complaint, signed by the Plaintiff on 12/28/15 and stamped by a
notary public, was only two pages long and was never signed or dated. This transparent, easily
checked falsehood was submitted to the Kentucky Supreme Court on 1/4/16 by Defendant
Conway and his attorney. Their motive to defraud Kentucky's highest Court could not have
been more plain.
45.
Despite these and other falsehoods and frivolous pleadings filed in various
Kentucky courts by Defendants Conway and Grimes and three other KDP co-conspirators during
2015-16, Jefferson County Circuit Court Judge, the Hon. Angela Bisig, awarded CR 11 sanctions
to Defendant Conway's lawyer to be paid by Plaintiff. The Order, dated 11/30/15, was based on
the court's false conclusion that the doctrine of res judicata applied to two of Plaintiff's lawsuits,
as discussed in Paragraph 44 above. The Kentucky Court of Appeals refused to reverse that
Order, without giving any cogent reason for its refusal. Plaintiff filed a motion for discretionary
review before the Kentucky Supreme Court, which was denied on 8/17/16. To date, the answer
of Kentucky's Judicial Branch to all of these frivolous, bad-faith arguments by Defendants

Conway and Grimes and their powerful co-conspirators has been, in effect, We agree with the
proposition that powerful Democrats are and must remain above the law and Constitution.
46.
Defendants Conway's and Grimes' and their co-conspirators' attitude toward
Plaintiff's civil actions during 2015-2016 can be summed up concisely: If the defendants are
influential enough members of the KDP, none of their actions and omissions may ever be
reviewed by any court. The Party's leaders may violate any rule, law, section of Kentucky's
Constitution, civil rule, or local court rule without risk. If any Democrat appeals their actions to
the SCEC, that governing body of the KDP shall either ignore him or her for at least a year or
summarily deny the appeal without even reading it and without any semblance of due process. If
any Democrat tries to sue them, the complaint must immediately be thrown out of court and the
plaintiff fined for his or her effrontery. The KDP is not now and must never be a democratic
organization. It does not now and must never in the future operate in a democratic manner.
47.
As mentioned in Paragraph 42 above, Plaintiff mailed out a 64-page criminal
complaint, signed before a notary public, on 12/28/15. It was mailed to the following agencies
and individuals:
Attorney General Loretta Lynch, U.S. Department of Justice, 950 Pennsylvania Avenue,
NW, Washington, DC 20530-0001
John E. Kuhn, Jr., U.S. Attorney for Western Kentucky, 717 West Broadway, Louisville,
KY 40202
Kerry B. Harvey, U.S. Attorney for the Eastern District of Kentucky, 260 W. Vine Street,
Suite 300, Lexington, KY 40507-1612
Jim Huggins, FBI Duty Agent, 125 Lisle Industrial Ave, Tate Building, Suite 120,
Lexington, KY 40511
Kentucky Attorney General's Office of Criminal Investigations, 1024 Capital Center

Drive, Suite 200, Frankfort, Kentucky 40601
Kentucky Secretary of State's Office, 700 Capital Ave #152, Frankfort, KY 40601
Emily Dennis, General Counsel, Kentucky Registry of Election Finance, 140 Walnut
Street, Frankfort, Kentucky 40601-3240
Kathryn H. Gabhart, Executive Director, Executive Branch Ethics Commission, #3
Fountain Place, Frankfort KY 40601
Mr. M. Stephen Pitt, Esq., General Counsel for the Office of Governor Matt Bevin, 700
Capital Avenue, Bay #100, Frankfort, KY 40601
Mark Guilfoyle, Esq., Dressman Benzinger LaVelle, PSC, 207 Thomas More Parkway,
Crestview Hills, KY 41017
Jon Salomon, Esq., 3600 National City Tower, 101 South Fifth Street, Louisville, KY
40202
Susan Stokley Clary, Clerk, Kentucky Supreme Court, Room 209, State Capitol, 700
Capitol Ave., Frankfort, KY 40601-3488
Samuel Givens, Jr., Clerk, Kentucky Court of Appeals, 360 Democrat Drive, Frankfort,
KY 40601
Hon. Judge Thomas D. Wingate, c/o Sally Jump, Clerk, Franklin County Circuit Court,
222 St. Clair Street, Frankfort, KY 40601
David L. Nicholson, Clerk, Jefferson County Circuit Court, Divisions 8 and 10, 700 W.
Jefferson St., Louisville, KY 40202
48.
Attorney Mark Guilfoyle was Counsel for Steve Beshear, Defendant Jack
Conway, Patrick Hughes, and Dan Logsdon. Attorney Jon Salomon was and is Counsel for
Defendant Alison L. Grimes. The Clerk of the Kentucky Supreme Court returned the document a
couple of days later because Plaintiff had not attached it to a pleading. He soon did so, and it
became part of the case record in his third motion for that court's discretionary review.
49.
In his criminal complaint, the Plaintiff documented the intentional, systematic,

and malicious violation of certain Kentucky election laws and regulations including, but not
limited to: KRS 11A.005, KRS 11A.020; KRS 118.105 (1); KRS 118.176; KRS 119.245; KRS
119.265; KRS 119.275; KRS 121.120 (5); Kentucky Constitution Sections 6, 15, 115 and 151;
and 32 KAR 2:170.
50.
Former Kentucky Attorney General, Defendant Jack Conway, never responded to
the 12/28/15 criminal complaint in any way. He should have appointed a special prosecutor.
51.
On 2/4/16, Defendant Grimes' lawyer, Jon Salomon, mailed a 2-page response
(not counting one attachment) to the Executive Director of the Executive Branch Ethics
Commission, Kathryn H. Gabhart. Grimes and her lawyer (Grimes/Salomon) called Plaintiff's
allegations baseless and stated that Plaintiff's 64-page criminal complaint did not allege that
Defendant Grimes ever violated any law or ethics regulation. They wrote, But Mr. Young has
failed similarly to allege any conduct by Secretary (of State) Grimes that could conceivably
constitute a violation of the Executive Branch Code of Ethics. Even a cursory review of
Plaintiff's criminal complaint, however, proves that Grimes/Salomon's argument was false on its
face. Their argument reduces to the frivolous assertion that violating KRS 118.105 (1) and
participating in a conspiracy to commit the worst election fraud in Kentucky history cannot
conceivably have also violated any provision of the Executive Branch Code of Ethics. In other
words, conspiring to steal the contested 2015 primary election at which Secretary of State
Grimes herself was nominated for reelection cannot conceivably have constituted a use of her
public office to obtain private benefits. [KRS 11A.005 and 11A.020]
52.
On 2/8/16, Steve Beshear and his new attorney, Mark Overstreet, mailed a 21-
page response to Ms. Gabhart, making essentially the same frivolous argument. The
allegations..., even if true, fail to identify acts or omissions that violate the provisions of Chapter
11A of the Kentucky Revised Statutes, including 11A.020(1) and KRS 11A020(3)...
[Confidential Response and Motion to Dismiss for Lack of Probable Cause; 2/8/16, at 1] In other
words, even if Steve Beshear did conspire to steal the entire 2015 Democratic primary election
on behalf of Jack Conway, that conspiracy must have been totally ethical and lawful.
53.
On May 2, 2016, the Executive Branch Ethics Commission mailed a letter to
Plaintiff, Defendants Conway and Grimes, and other parties saying that Preliminary
Investigation 16-PI-009, 16-PI-010, and 16-PI-011 developed insufficient evidence to support a
finding that these individuals violated the Executive Branch Code of Ethics. In other words,
even if Steve Beshear, Defendant Jack Conway, and Defendant Grimes actively conspired with
others to violate KRS 118.105 (1) and thereby commit the worst election fraud in Kentucky
history, the conspiracy to defraud must have been carried out in a totally ethical and lawful way.
54.
Plaintiff's phone calls to the Kentucky Registry of Election Finance about his
criminal complaint have yielded essentially nothing to date. The agency's General Counsel said
the Registry has no jurisdiction over criminal complaints regarding wholesale election fraud.
55.
Plaintiff's experience with the Kentucky Attorney General's (AG's) Office was
at least as bad. Former AG Jack Conway was a defendant in all three of Plaintiff's 2015 civil
lawsuits. It almost goes without saying that he refused to investigate himself, Defendant Grimes,
and former Governor Steve Beshear. Defendant Conway also refused to discuss the issue, or any
other issue, with Plaintiff for the entire calendar year. His second term ended on 1/4/16 when
Defendant Andy Beshear was sworn in as the new AG. Plaintiff immediately started asking for a
meeting with the new AG to discuss his 64-page criminal complaint. Defendant A. Beshear
refused, but had two staffers meet with him. They told him flatly on 1/12/16 in Frankfort that no
Democrat had violated KRS 118.105 (1) during 2015 and that no prosecutor would be able to
convince any jury otherwise.
56.
Plaintiff's experience with the Kentucky Board of Elections (BoE) was at least
as bad. The Board's first duties, listed on its web site, are to ensure Kentuckys compliance with
federal and state election laws. Plaintiff attended one session of the public meeting the BoE held
on Primary Election Day, May 17, 2016. Earlier that morning, he had called in to report a ballot
irregularity at his own precinct polling place. At the public meeting, the official chairing the
meeting, Defendant Alison L. Grimes, told him his concern was being handled. Plaintiff asked to
bring up another issue at the end of the session. About half an hour later, Defendant Grimes tried
to adjourn the session without allowing Plaintiff to speak to the BoE. Plaintiff had to make a
point of order, was recognized, and then asked the four BoE members present whether they had
been given copies of his 12/28/15 criminal complaint. Defendant Grimes interrupted and refused
to allow the BoE members to answer. She said, in effect, that because Mr. Young had a motion
for discretionary review pending before the Kentucky Supreme Court, the Board of Elections
could not legally consider the matter. Plaintiff disagreed, announced, This is a coverup, and
left the room. Plaintiff believes that Defendant Grimes and the BoE's Executive Director,
Maryellen Allen, never provided copies of Plaintiff's criminal complaint to the six BoE
members. Defendant Grimes was one of the five Democrats Plaintiff had accused of election
fraud in 2015. Exactly as Defendant Overly did on 4/30/16, Defendant Grimes insisted on
presiding over and dominating the 5/17/16 hearing about her own actions and omissions as
Kentucky's highest election officer in 2015-16, thereby acting simultanelously as the defendant,
defense attorney, and judge.

57.
On August 16, 2016, Plaintiff attended the regular meeting of the BoE in
Frankfort. Unlike the meeting on 5/17/16, all of the BoE members were present. Plaintiff was
unaware that the BoE only had Room 110 in the State Capitol building for 60 minutes. He
waited patiently from 10:00 to 11:00 am while Defendant Grimes ran out the clock by leading
the BoE through a number of items of business, some of which seemed trivial and time-wasting.
At 11:00 am, as Defendant/Chairperson/Judge Grimes was preparing to adjourn the meeting,
Plaintiff stood up and asked the BoE for some time on the agenda that day. It was at that time
that Defendant/Chairperson/Judge Grimes told Plaintiff that another meeting was scheduled for
11:00 in that room. Plaintiff repeated his request. Defendant/Chairperson/Judge Grimes did not
even ask the Plaintiff what topic he wanted to bring up. Plaintiff later informed a staff member in
the Secretary of State's Office that he would have brought up his 12/28/15 criminal complaint,
and that he was planning to ask the BoE to schedule a special meeting before its next scheduled
meeting date, 9/20/16, to discuss that issue. Plaintiff emailed his request to the Executive
Director of the BoE, Ms. Allen, later that day (8/16/16).
///
[CLAIMS FOR RELIEF]
FIRST CLAIM FOR RELIEF
VIOLATION OF PLAINTIFF'S CONSTITUTIONAL RIGHT TO RUN FOR
CHAIRPERSON OR VICE-CHAIR OF THE KDP ON 6/4/16
58.
Plaintiff realleges and incorporates by reference the allegations contained in
paragraphs 1 through 57 above.

59.
A preponderance of evidence will prove that Defendants conspired to violate 42
U.S.C. 1983 and 18 U.S.C. 241, Conspiracy Against Rights, when they conducted a sham
election to install Defendant Overly and (witness) Neville Blakemore at the Democratic
Statewide Convention in Lousville on 6/4/16. In short, no election was ever held, so Plaintiff
was deprived of the right to run for an office in a quasi-governmental organization, the KDP, for
which he was otherwise qualified. Kentucky provides public funds to the KDP to help it conduct
free and equal elections. The conspiracy to defraud has been described with particularity in
Paragraphs 13 to 20 above. This intentional violation of Plaintiff's rights harmed his political
career and entitles him to recover punitive damages in amounts to be proven at trial.
60.
Defendants committed the acts alleged herein maliciously, fraudulently and
oppressively with the wrongful intention of injuring Plaintiff from an improper and evil motive
amounting to malice, and in conscious disregard of Plaintiffs rights. Plaintiff is thus entitled to
recover exemplary and punitive damages from Defendants in amounts to be proven at trial.
SECOND CLAIM FOR RELIEF
VIOLATION OF PLAINTIFF'S CONSTITUTIONAL RIGHT TO
COMPETE FOR POSITION OF CHAIR OF THE KDP ON 1/30/16
AND CHAIR OF THE FCDP ON 4/16/16
61.
A preponderance of evidence will prove that Defendants conspired to violate 42
U.S.C. 1983 and 18 U.S.C. 241, Conspiracy Against Rights, when they conducted, in secret,
a sham procedure to install Defendant Overly as the new Chairperson of the KDP during the
period leading up to and including 1/30/16. Plaintiff was unlawfully barred from attending the
part of the SCEC meeting at which he would have nominated himself, given a speech, and
answered questions, and was thereby deprived of the right to compete in any meaningful sense
for an office in a quasi-governmental organization, the KDP, for which he was otherwise
qualified. The conspiracy to defraud, which turned what would have been a contested election in
any legitimate, democratic organization into an uncontested, unanimous coronation, has been
described with particularity in Paragraphs 21 to 26 above.
62.
Defendants violated the same Federal statute when they conspired to confirm or
coronate Defendant Clint Morris as Chair of the FCDP on 4/16/16 in an unpublicized meeting of
a small subset of the FCDP's Executive Committee. That violation of law was described with
particularity in Paragraphs 35 to 38 above.
63.
THIRD CLAIM FOR RELIEF
DENIAL OF DUE PROCESS
64.
Paragraphs 27-34 above make a prima facie case that Defendants operated a
kangaroo court on 4/30/16 and have no genuine process whatsoever to resolve serious disagreements between Kentucky Democrats, thereby violating 42 U.S.C. 1983 and Plaintiff's due
process rights. No quasi-governmental institution, which is what the KDP and FCDP are,
operates without any functional method to resolve disputes or hear appeals brought by its
members. Only a criminal enterprise or a dictatorship allows the boss to dominate a proceeding
in which the boss is one of the accused; denies its members all universally recognized due
process rights; and insists that whatever the boss says goes.
65.
Defendant Grimes blatantly violated Plaintiff's due process rights on 5/17/16,
8/16/16, and every day in between when she refused to allow the BoE to hear Plaintiff's criminal
complaint and refused to ask Governor Matt Bevin (R) to appoint a special prosecutor to
investigate large-scale election fraud and other offenses that had not been prosecuted in 2015.
66.
recover punitive and exemplary damages from Defendants in amounts to be proven at trial.
FOURTH CLAIM FOR RELIEF
INTIMIDATING A CANDIDATE THROUGH THE THREAT OF FORCE
67.
Plaintiff was a very active (primary election) candidate for a Federal office, the
U.S. House of Representatives from Kentucky's 6th District, when he showed up in Morehead
on 4/30/16 to participate in the hearing that Defendants had scheduled.
18 U.S. Code 245 (b), Federally protected activities, provides as follows:
...(b) Whoever, whether or not acting under color of law, by force or threat of
force willfully injures, intimidates or interferes with, or attempts to injure,
intimidate or interfere with
(1) any person because he is or has been, or in order to intimidate such person or
any other person or any class of persons from
(A) voting or qualifying to vote, qualifying or campaigning as a candidate for
elective office, or qualifying or acting as a poll watcher, or any legally authorized
election official, in any primary, special, or general election;
shall be fined under this title, or imprisoned not more than one year, or both...
When Young Democrats Liz Fossett and Josh Monroe threatened to have the Plaintiff arrested
and thrown in jail on 4/30/16 for silently standing in a public space (the hallway outside the
meeting rooms of the Morehead Conference Center) holding his antiwar sign, they violated this
federal statute and 42 U.S.C. 1983 on behalf of and for the benefit of the Defendants. [see
Paragraph 30 above] They were following the example set by former FCDP Chairperson Bob
Layton on 3/13/14. [see Paragraph 31 above] Josh Monroe is or was an influential Fayette
County Young Democrat, and he was probably in the FCDP building when Bob Layton
threatened Plaintiff with arrest and jail. Plaintiff's arrest, even though it would have been false
arrest, would have significantly damaged his chosen career as a Democratic candidate for offices
in Kentucky. Conversely, being elected to an important position within the KDP or FCDP would
have enhanced Plaintiff's experience, reputation and credibility with regard to future runs for the
U.S. House of Representatives. When Defendant Morris threatened Plaintiff three times during
2016 in similar circumstances, he violated this federal statute and 42 U.S.C. 1983.
68.
Defendants and their co-conspirators committed the acts alleged herein
maliciously, fraudulently and oppressively with the wrongful intention of injuring Plaintiff from
an improper and evil motive amounting to malice, and in conscious disregard of Plaintiffs
rights. Plaintiff is thus entitled to recover exemplary and punitive damages from Defendants in
amounts to be proven at trial.
FIFTH CLAIM FOR RELIEF
DEPRIVATION OF PLAINTIFF'S RIGHTS UNDER COLOR OF LAW
69.
18 U.S.C. 242, Deprivation of Rights Under Color of Law, reads, in pertinent
part, as follows:
Whoever, under color of any law, statute, ordinance, regulation, or custom,

willfully subjects any person in any State, Territory, Commonwealth, Possession,
or District to the deprivation of any rights, privileges, or immunities secured or
protected by the Constitution or laws of the United States... shall be fined under
this title or imprisoned not more than one year, or both...
The Constitution protects every citizen's rights to due process, to vote in fair, uncorrupted
elections, and to run for office. [See also Sections 2 and 6 of the Kentucky Constitution] A
preponderance of evidence will prove that all of the Defendants conspired willfully to violate
this Federal statute and 42 U.S.C. 1983. Because the KDP and FCDP are quasi-governmental
institutions, Party chairpeople and executive committee members were, by definition, acting
under color of law when they violated the constitutional and due process rights of the Plaintiff, a
Kentucky Democrat, during the period from March, 2014 up to and including the present date.
Even if this Court finds that the KDP and FCDP are not quasi-governmental institutions, all of
the Defendants were acting under color of law when they violated Plaintiff's civil rights. Steve
Beshear and Defendants Grimes, Conway, and Andy Beshear, moreover, actually held powerful
positions in Kentucky's government when they participated in the conspiracy to commit the
violations described herein. Every unlawful act and omission they committed was done under
color of law.
70.
SIXTH CLAIM FOR RELIEF
DEPRIVATION OF PLAINTIFF'S RIGHT OF HONEST SERVICES
71.
18 U.S.C. 1346, Deprivation of Right of Honest Services, makes it a federal
offense for Kentucky's Attorney General and/or Secretary of State to refuse to facilitate or even
allow the investigation of his or her own wrongdoing or that of a close relative or close
associate, if a plaintiff or complainant has made a prima facie case that election fraud has
occurred. 42 U.S.C. 1983 explicitly allows Plaintiff to sue all of the Defendants for damages
for violating these state and federal laws. Plaintiff first accused Defendant Conway, Defendant
Grimes, and three other powerful Democrats of having conspired to commit the worst election
fraud in Kentucky history rigging an entire primary election on 4/1/15 in his Answer to Two
Motions to Dismiss his 3/2/15 civil complaint in Franklin County Circuit Court, Division 2. At
the hearing before the Honorable Judge Thomas Wingate on 4/6/15, Plaintiff repeated that
accusation in open court. It was based on Defendants' alleged shredding of KRS 118.105 (1), the
foundational enabling statute governing primary elections. Plaintiff included additional evidence
and accusations about massive election fraud in his signed and notarized criminal complaint,
made under penalty of perjury, on 12/28/15, and in numerous court documents from 4/1/15 to
the present date.
72.
The Chairperson of the KDP from 2/9/15 to approximately 1/30/16 was Patrick
Hughes. He did nothing to cause or enable the SCEC to hold a hearing on the Plaintiff's
accusations of serious election law violations. His refusal to act constitutes evidence that the
SCEC has no functioning process to adjudicate serious disputes between Kentucky Democrats.
Defendant Overly's sham hearing on 4/30/16 constitutes evidence that the SCEC maliciously
violated virtually all of the Plaintiff's due process rights and that no legitimate appeal procedure
exists within the KDP. The Defendants have repeatedly obstructed Plaintiff's efforts to bring
these accusations before any of the following state agencies for investigation, adjudication or
prosecution: the Kentucky Governor's Office (during the term of Steve Beshear), the Kentucky
Office of the Attorney General, the Kentucky Secretary of State's Office, the Kentucky Board of
Elections, the Executive Branch Ethics Commission, and the Kentucky Registry of Election
Finance. In so doing, those Defendants who were or are Executive Branch officials have
repeatedly, maliciously, and chronically violated KRS 522.020, which reads as follows:
Official misconduct in the first degree.
(1) A public servant is guilty of official misconduct in the first degree when, with
intent to obtain or confer a benefit or to injure another person or to deprive
another person of a benefit, he knowingly: (a) Commits an act relating to his
office which constitutes an unauthorized exercise of his official functions; or (b)
Refrains from performing a duty imposed upon him by law or clearly inherent in
the nature of his office; or (c) Violates any statute or lawfully adopted rule or
regulation relating to his office.
(2) Official misconduct in the first degree is a Class A misdemeanor.
73.
Defendants Conway and Grimes, by counsel, have insisted since 3/24/15 that
powerful Democrats are above the law and may never be taken to court for any reason that might
be (accurately or falsely) labeled political. Faced with well-documented evidence that they had
conspired to violate Kentucky's election laws, they should have assigned a special prosecutor to
investigate the facts and proceed with a criminal or civil case if appropriate. Defendant Andy
Beshear should have appointed a special prosecutor upon taking office. Instead, he had two staff
members tell Plaintiff that no powerful Democrat could possibly have violated any state election
statute in 2015, specifically including KRS 118.105. And Defendant Morris refused for at least
18 months to bring the controversy, or any part of it, before the Executive Committee of the
FCDP for debate and possible resolution. Morris, in his capacity as a voting member of the
SCEC, a quasi-governmental agency, also attended the sham hearing on 4/30/16 and failed or
refused to question or object to any aspect of Defendant/Judge Overly's egregious misconduct.

Nothing could be a clearer example of self-dealing than an Attorney General who categorically
refuses to investigate and prosecute criminal actions committed by himself (Conway) or AG
Andy Beshear's father (Steve Beshear). Defendant Grimes' refusal to allow the Kentucky Board
of Elections to enforce Kentucky's election laws during the period from 1/2/16 through 8/16/16
is also blatant self-dealing. The BoE deserves to be criticized for allowing an alleged, unindicted,
election-rigging, election-stealing felon to dominate its agenda so completely between 1/2/16
and the present date that the BoE has never actually heard or read the entire set of accusations
Plaintiff has made against Kentucky's highest election official, Defendant Grimes.
74.
SEVENTH CLAIM FOR RELIEF
NULLIFYING VALID STATUTES
75.
In the process of trying to place their powerful clients permanently beyond the
reach of any law or court, attorneys Mark Guilfoyle and Jon Salomon felt compelled to make
arguments, in writing, to the effect that certain Kentucky statutes and sections of the Kentucky
Constitution may never be applied to their clients. If enough judges agree with the proposition
that a certain law may be violated and ignored if the defendants are powerful Democrats, then
those laws have effectively been nullified. For example, the cause of action of Plaintiff's third
civil lawsuit against Jack Conway on 10/30/15 was that Conway, his lawyer, a Jefferson County
Circuit Court judge, and the Kentucky Court of Appeals had violated and nullified KRS 118.176,
Challenging Good Faith of Candidate. Nullifying valid statutes violates Section 15 of the
Kentucky Constitution. 42 U.S.C. 1983 allows Plaintiff to sue all of the Defendants for
damages and injunctive relief for violating this Kentucky statute and Constitution section.
76.
Defendants Conway, Andy Beshear, and Grimes, aided by certain Kentucky
judges, have completely nullified KRS 118.105 (1), which prohibits the Democratic (and
Republican) Party from nominating any of its candidates except through a state-supported, stateregulated, and state-supervised primary election. 42 U.S.C. 1983 allows Plaintiff to sue all of
the Defendants for damages for violating this Kentucky statute. Defendant Andy Beshear's
Office made it clear in a meeting with Plaintiff on 1/12/16 that there is no way for any Democrat
even to be accused of violating this statute as long as a primary election actually occurs.
Beshear's staffers explicitly told Plaintiff that sham primary elections are perfectly lawful and
acceptable. During the same meeting in Frankfort, they told Plaintiff that while the Federal Code
might have laws against obstruction of justice, Kentucky has none. If that is the case, Defendants
should have referred Plaintiff's criminal complaint to the appropriate Federal prosecutor(s). They
failed and refused to do so. If that is not the case, Defendants were intentionally making a false
representation about the law in an effort to get the Plaintiff to drop all of his legitimate legal
actions to defend his constitutional rights.
77.
EIGHTH CLAIM FOR RELIEF

INTIMIDATING PLAINTIFF BY THREATENING CR 11 SANCTIONS
78.
Soon after Plaintiff filed his second challenge to the good faith and bona fides of
Defendant Conway on 10/30/15 in Jefferson County Circuit Court, Division 10, pursuant to KRS
118.176, Conway's attorney, Mark Guilfoyle, called the Plaintiff to say that the challenge was
barred by the doctrine of res judicata. Conway/Guilfoyle then followed up with an email that
contained the paragraph: Please dismiss your case with prejudice at once. If you refuse to
dismiss your complaint, I will ask the Court to award my costs in having to respond to and
appear in court on such a frivolous lawsuit. [Email, 11/6/15] Plaintiff had researched res
judicata, however, and learned that the doctrine could not legally be applied because: (1) the
cause of action of that challenge was totally different than the cause of action in Division 8
earlier that year; and (2) the first challenge was never heard or adjudicated on its merits. Plaintiff
included these facts in his timely, written response to Conway/Guilfoyle's motion to dismiss.
Judge Angela Bisig of Division 10, however, committed reversible error by granting Conway/
Guilfoyle's meritless demand for sanctions under CR 11. The Judge wrote in her Order dated
11/30/15, Young has previously filed this same action in another division of Jefferson Circuit
Court. That statement was false, and Defendants knew it was false. Plaintiff hereby accuses
Defendant Conway and his attorney of threatening sanctions in order to intimidate Plaintiff into
dropping his legally valid challenge of 10/30/15. Intimidation to prevent Plaintiff from
exercising his legal right to seek redress in a Kentucky circuit court violates 42 U.S.C. 1983.
79.
Defendants committed the acts and omissions alleged herein maliciously,
fraudulently and oppressively with the wrongful intention of injuring Plaintiff from an improper
and evil motive amounting to malice, and in conscious disregard of Plaintiffs rights. Plaintiff is
thus entitled to recover exemplary and punitive damages from Defendants in amounts to be
proven at trial.
[PRAYER FOR RELIEF]
WHEREFORE, Plaintiff respectfully asks this Court to enter judgment against the
Defendants, and each of them, for: 1) General, compensatory, and special damages, according to
proof; 2) punitive and exemplary damages according to proof; 3) an emergency, temporary
injunction to be issued by this Court after it has heard arguments pro and con; 4) permanent
prospective injuctions to prevent future violations; and 5) such other and further relief as the
Court deems just and proper.
Because Defendants have maintained since 3/24/15, despite overwhelming evidence to
the contrary, that the KDP and FCDP are purely voluntary organizations, all of whose activities
and customary practices are legally beyond the reach of any court to investigate, prohibit, or
alter, Plaintiff will ask this Court, via a separate motion, to:
(A) ORDER the Defendants to attend at least one settlement conference, pursuant to
Local Rule 16.2, to be held in lieu of the hearing which Defendants have scheduled for 1:00
pm at the KDP Headquarters building in Frankfort, Kentucky, on September 17, 2016, or on a
later date to be determined by the Court.
(B) freeze all of the assets of the KDP and FCDP and prohibit the expenditure of any of
their assets for any purpose, unless the Court, upon a motion, answer, and Order, makes one or
more exceptions; or until the case at bar has been finally adjudicated or settled;
(C) ORDER that no public funds shall be distributed to the KDP or FCDP for any
purpose, and that any public funds that would have been allocated to them pursuant to Kentucky
statutes shall be deposited instead into an escrow account under the sole control of this Court;
and
(D) ORDER the KDP and FCDP not to destroy or hide any of their books and records,
and to make all of their books and records available to Plaintiff for examination and/or copying,
upon reasonable notice, during regular business hours.
(E) Violations of this temporary injunction, if granted by this Court, by Defendants and
their co-conspirators should be punishable by a fine or any other lawful penalties as determined
by this Court.
DATED: October ___28____, 2016
By ________________________________
GEOFFREY M. YOUNG, pro se,
454 Kimberly Place
Lexington, KY 40503
Phone: (859) 278-4966
JURY TRIAL DEMAND
Plaintiff hereby demands a jury trial on all issues so triable.
DATED: October ___28____, 2016
By ________________________________
Certificate of Service of Amended Civil Complaint Case No. 3:16-CV-62-GFVT

I, Geoffrey M. Young, pro se, hereby certify that I have mailed a copy of the enclosed
amended civil complaint, first-class postage prepaid, to the following parties on October 28,
2016.
BY: ___________________________________________
Geoffrey M. Young
454 Kimberly Place
Lexington, KY 40503
Phone: (859) 278-4966
Jennifer A. Moore and Abigale Rhodes Green
Counsel for Sannie Overly, Clint Morris, Jack Conway, KDP and FCDP
Grossman & Moore, PLLC
One Riverfront Plaza
401 West Main St., Suite 1810
Louisville, KY 40202
Jon Salomon, Esq.
Counsel for Alison Lundergan Grimes
Tachau Meek, PLC
3600 National City Tower
101 South 5th Street
Louisville, KY 40202-3120
Matt James, Assistant Attorney General
Counsel for Andy Beshear
Office of the Attorney General
70 Capitol Ave., Suite 118
Frankfort, KY 40601
Page 1 of 1

Kentucky Democratic Party Federal Denial Due Process Complaint 10.28.16

Încărcat de

Informații document

Drepturi de autor

Formate disponibile

Partajați acest document

Partajați sau inserați document

Opțiuni de partajare

Vi se pare util acest document?

Este necorespunzător acest conținut?

Drepturi de autor:

Formate disponibile

Kentucky Democratic Party Federal Denial Due Process Complaint 10.28.16

Încărcat de

Drepturi de autor:

Formate disponibile

UNITED STATES DISTRICT COURT

EASTERN DISTRICT OF KENTUCKY

42 U.S.C. 1983 CIVIL RIGHTS

Plaintiff alleges as follows:

of a conspiracy by powerful Democrats, both in and out of Kentucky government, which

Plaintiff is a registered Democrat living in Lexington, Fayette County, Kentucky,

The individual Defendants are highly influential, well-known members of the

The organizational Defendants are not purely private or voluntary organizations

may be called as witnesses.

Whenever and wherever this Complaint refers to any act or omission by a

Whenever and wherever reference is made in this Complaint to any act by a

Mayor Greg Fischer welcomed the attendees to Louisville, and Congressman

About halfway through the meeting on 1/30/16, the acting Chairperson (a

On Saturday, 1/30/16, Plaintiff was prepared to nominate himself to the position

On 4/14/16, Plaintiff mailed a note to Defendant Overly asking her to provide a

written responses to his appeal.

Exactly as in the Statewide Democratic Convention that would be held on 6/4/16,

Exactly as in the unlawful, secret election of Defendant Overly as Chair of the

KDP on 1/30/16 and in her unlawful, facially undemocratic confirmation on 6/4/16,

Plaintiff has described in Paragraphs 27 through 34 above, no functioning mechanism exists to

On 2/7/15, the SCEC held an unpublicized meeting at which the Chairperson of

of Kentucky's Judicial Branch to all of these frivolous, bad-faith arguments by Defendants

Defendants Conway's and Grimes' and their co-conspirators' attitude toward

As mentioned in Paragraph 42 above, Plaintiff mailed out a 64-page criminal

Kentucky Attorney General's Office of Criminal Investigations, 1024 Capital Center

In his criminal complaint, the Plaintiff documented the intentional, systematic,

Former Kentucky Attorney General, Defendant Jack Conway, never responded to

On 2/4/16, Defendant Grimes' lawyer, Jon Salomon, mailed a 2-page response

On May 2, 2016, the Executive Branch Ethics Commission mailed a letter to

defense attorney, and judge.

Plaintiff realleges and incorporates by reference the allegations contained in

paragraphs 1 through 57 above.

A preponderance of evidence will prove that Defendants conspired to violate 42

Defendants committed the acts alleged herein maliciously, fraudulently and

A preponderance of evidence will prove that Defendants conspired to violate 42

Defendants committed the acts alleged herein maliciously, fraudulently and

Defendant Grimes blatantly violated Plaintiff's due process rights on 5/17/16,

Defendants committed the acts alleged herein maliciously, fraudulently and

Defendants and their co-conspirators committed the acts alleged herein

18 U.S.C. 242, Deprivation of Rights Under Color of Law, reads, in pertinent

Whoever, under color of any law, statute, ordinance, regulation, or custom,

Defendants committed the acts alleged herein maliciously, fraudulently and

18 U.S.C. 1346, Deprivation of Right of Honest Services, makes it a federal

refused to question or object to any aspect of Defendant/Judge Overly's egregious misconduct.

Defendants committed the acts alleged herein maliciously, fraudulently and

Defendants Conway, Andy Beshear, and Grimes, aided by certain Kentucky

Defendants committed the acts alleged herein maliciously, fraudulently and

EIGHTH CLAIM FOR RELIEF

Defendants committed the acts and omissions alleged herein maliciously,

COMPLAINT FOR DAMAGES & INJUNCTIONS Page 48 of 48

Certificate of Service of Amended Civil Complaint Case No. 3:16-CV-62-GFVT

S-ar putea să vă placă și