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Plaintiffs Amended Petition and Appendix 2.0
Plaintiffs Amended Petition and Appendix 2.0
DC-18-00821
__________________________________________________________________________
__________________________________________________________________________
COME NOW, the Dallas County Republican Party (the “DCRP”) and Missy Shorey
(“Shorey”), as Chairwoman of the DCRP, and file this, their First Amended Petition Challenging
the Certification of a 128 (one hundred and twenty-eight) Democratic Candidates’ Applications
For a Place on the Democratic Primary Ballot, & Application for Temporary Injunction
CAUSE NO.
DCRP v. DCDP – Plaintiffs’ First Amended Petition & Application for TRO / Temporary Injunction Page 1
complaining of and against the Dallas County Democratic Party (the “DCDP”), Carol Donovan
(“Donovan”) as Chairwoman thereof, and for cause of action would respectfully show unto the
Court as follows:
1. This lawsuit arises out of the certification of compliance for and submission to the Secretary
of State by the DCDP of 128 candidates for places on the Democratic Primary Ballot, whose
applications were not accepted by the DCDP’s Chairwoman Donovan, the only individual
2. The Plaintiffs seek injunctive relief to prevent Donovan and the DCDP from including: (a) any
of these candidates, whose applications are attached in Plaintiffs’ Appendix to this Petition on
the March 2018 Democratic Primary ballot; and (b) any of these candidates on the November
2018 General Election Ballot as a result of any such candidates’ participation in the March
3. The Plaintiffs also seek injunctive relief to prevent Donovan and the DCDP from declaring
any of these candidates administratively ineligible and replacing them, where statute permits,
with a candidate of Donovan’s choice so as to avoid a ruling in the Plaintiffs’ favor on the
merits.
4. This matter is subject to Discovery Level 2 in accordance with the Texas Rule of Civil
Procedure 190.3.
5. The DCRP is a political party organized in accordance with the Texas Election Code, with its
principal place of business located at 11617 N. Central Expressway, Suite 240, Dallas, Texas,
75243.
6. Shorey, as the Dallas County Republican Party Chairwoman, is an individual who resides in
7. The DCDP is a political party organized in accordance with the Texas Election Code with its
principal place of business located at 4209 Parry Avenue, Dallas, Texas 75223. The Dallas
County Democratic Party may be served with process by serving its Chairwoman, Carol
Donovan, at its principal place of business, or its General Counsel, Sarah Duncan, at 3500
Maple Ave, Dallas, TX 75219, or wherever else either two may be found.
8. Donovan, as the Dallas County Democratic Party Chairwoman, is an individual who resides in
Dallas County. Donovan may be served with process at her principal place of business, or by
serving Sarah Duncan, the General Counsel of the Dallas County Democratic Party (whom the
Plaintiffs understand to also represent Donovan in this matter), at 3500 Maple Ave, Dallas, TX
8. Jurisdiction is proper in this Court in accordance with Texas Election Code §§ 145.035 and
172.117 and the Plaintiffs seek an injunction against the Defendants in accordance with
CAUSE NO.
DCRP v. DCDP – Plaintiffs’ First Amended Petition & Application for TRO / Temporary Injunction Page 3
9. Venue is proper in Dallas County, Texas, because the events giving rise to Plaintiffs’ causes
of action occurred in Dallas County, Texas and because all parties are residents of (or have
their principal place of business in) Dallas County for venue purposes.
V. FACTS
A. Background
10. The deadline to submit applications for placement on the March 2018 Primary Ballot for
11. After the filing deadline, a candidate may not file and the county Chair may not accept, an
12. The candidates whose petitions are the subject of this challenge submitted their applications
and/or applications and petitions, along with a fee, to the DCDP for offices sought wholly
within Dallas County, before the December 11, 2017 deadline, in accordance with The Texas
purporting to be Donovan, so certifying the candidates for inclusion on the primary ballot, in
15. The Primary Election is scheduled to be held on March 6, 2018, and early voting ballots were
16. The Texas Election Code states that a candidate’s application for a place on the ballot, must
17. The Election Code also makes clear that for any office that is wholly within one county, a
candidate’s application for a place on a party’s primary ballot must be filed with that political
party, specifically with the County Chair or the County Party Secretary.3
18. The Election Code gives the Secretary of State the authority to create and prescribe different
19. The application form (Form 2-2), contains a further admonition within the form warning that
failing to provide required information could result in rejection of the application: “All fields
MUST be completed unless marked optional. Failure to provide required information may
20. The Election Code requires that, once those applications are received by the appropriate
authority (for placement on the March 2018 Dallas Democratic Primary Ballot, the DCDP),
that “authority with whom the application is filed shall review the application to determine
CAUSE NO.
DCRP v. DCDP – Plaintiffs’ First Amended Petition & Application for TRO / Temporary Injunction Page 5
whether it complies with the requirements as to form, content, and procedure that the
application and petition must satisfy for the candidate’s name to be placed on the ballot.”6
21. After the relevant authority makes that determination, the Election Code requires it to certify
the names of all candidates who comply, as the names are written on the application, for
22. The County Chair, alone, is the presiding officer of a county party, under the Election Code.8
23. The Election Code designates the County Chair, alone, as the sole person responsible for
certifying and the sole person authorized to submit the names of complying candidates to the
Secretary of State.9, 10
24. Though the Secretary of State may prescribe deadlines by which these submissions must be
delivered, the Code makes very clear that those candidate submissions are to be made by the
Chair.11
25. The form also indicates, at the bottom, that the certification for submission to the Secretary
26. This authority may not be delegated except in very limited circumstances. In fact, the Code
only makes provision for a State Party Chair to perform a County Chairs’ job, and then only
makes this provision if: (a) there is an absence of County Party leadership; or (b) the County
make special notice to the County Chair or the County Executive Committee if he or she is
going to or has performed one of the Chair’s duties for him or her, including the submission
27. If a County Party Chair has a reasonable impediment to being able to perform those tasks
which the Election Code requires of them with regard to Primary Elections, the County Chair
may request, in advance, that the State Chair or the State Chair’s Designee perform the duty
28. But there is no provision in the Election Code that makes it possible or permissible for
29. On information and belief, Donovan made no such request to the Texas Democratic Party’s
Chair, nor is there any indication that the Texas Democratic Party Chair notified Donovan or
the DCDP of a determination that Donovan was not performing her duties in a timely
30. Political Parties are expressly prohibited by the Code from making nominations to public
31. In the attached Appendix, Plaintiffs submit all 151 Applications submitted to the DCDP by
candidates (and submitted by the DCDP to the Secretary of State) for inclusion on the March
CAUSE NO.
DCRP v. DCDP – Plaintiffs’ First Amended Petition & Application for TRO / Temporary Injunction Page 7
32. Donovan signed only 22 of these 151 Applications (plus her own). The remaining 128
applications bear someone else’s forgery of Donovan’s name – the forgeries do not
resemble Carol Donovan’s signature as it appears on her own application for inclusion on
33. Only a county party Chair may accept applications for ballot access (or, in the narrow
exceptions provided by the Code, the State Chair or Designee) or submit complying
34. The following applications for the following candidates in the following districts were indeed
accepted and signed by the County Chair, with a signature that matches Defendant
Donovan’s signature on her own application for inclusion on the party primary ballot for
Party Chair:
35. The following applications for the following candidates in the following districts were not
accepted and signed by the County Chair, and are instead signed by a John Doe #1 with a
signature that does not match Defendant Donovan’s signature on her own application for
CAUSE NO.
DCRP v. DCDP – Plaintiffs’ First Amended Petition & Application for TRO / Temporary Injunction Page 9
26. Julia Hayes, County Criminal Court-at-Law No. 2
27. Audrey Faye Moorehead, County Criminal Court-at-Law No. 3
28. Remeko Tranisha Edwards, County Criminal Court-at-Law No. 7
29. Carmen White, County Criminal Court-at-Law No. 8
30. Peggy Hoffman, County Criminal Court-at-Law No. 9
31. Wini Cannon, County Commissioner Pct. 2
32. Thomas G. Jones, Justice of the Peace, Pct. 1, Place 1
33. Valencia Nash, Justice of the Peace, Pct. 1, Place 2
34. Norris “Stretch” Rideaux, Justice of the Peace Pct. 4, Place 1
35. Fred “Action” Jackson, Justice of the Peace Pct. 4 Place 2
36. Sara Martinez, Justice of the Peace, Pct. 5, Place 1
37. Juan Jasso, Justice of the Peace, Pct. 5 Place 2
38. Tracey Gulley, Constable Pct. 1
39. Rolando Garcia, Constable Pct. 5
40. Susan E. Lopez-Craig
36. The following applications for the following candidates in the following districts are not
accepted and signed by the County Chair, and are instead signed by a John Doe #2 with a
signature that does not match Defendant Donovan’s signature on her own application for
CAUSE NO.
DCRP v. DCDP – Plaintiffs’ First Amended Petition & Application for TRO / Temporary Injunction Page 11
54. Pamela Luther, Judge, County Criminal Court of Appeals, No. 2
55. Bruce Kaye, County Criminal Court of Appeals, No. 2
56. Marilynn Mayse, County Criminal Court of Appeals, No. 2
57. Roberto Canas, County Criminal Court-at-Law, No. 10
58. Etta J. Mullin, County Criminal Court-at-Law, No. 10
59. Shequitta Kelly, County Criminal Court-at-Law, No. 11
60. Symone Redwine, County Criminal Court-at-Law, No. 3
61. Nancy C. Mulder, County Criminal Court-at-Law, No. 4
62. Lisa Green, County Criminal Court-at-Law, No. 5
63. Angela M. King, County Criminal Court-at-Law, No. 6
64. Felicia Pitre, District Clerk
65. Marian Brown, Sheriff
66. Roy Williams, Jr., Sheriff
67. Pauline Medrano, County Treasurer
68. Elba Garcia, County Commissioner, Pct. 4
69. Anthony Elland, Justice of the Peace, Pct. 2, Place 1
70. Margaret O’Brien, Justice of the Peace, Pct. 2, Place 1
71. Katina Whitfield, Justice of the Peace, Pct. 2, Place 2
72. Shannon Bradford, Justice of the Peace, Pct. 3, Place 1
73. Mauri Long, Justice of the Peace, Pct. 3, Place 2
74. Mike Jones, Justice of the Peace, Pct. 4, Place 1
75. Sasha Moreno, Justice of the Peace, Pct. 4, Place 2
76. Katy Hubener, Justice of the Peace, Pct. 4, Place 2
77. Andrew “Bundy” Goldsmith, Justice of the Peace, Pct. 5, Place 2
78. Alvin “AJ” Johnson, Constable Pct. 1
79. Bill Gipson, Constable Pct. 2
80. Curtis “Traylor” Harris, Constable Pct. 3
81. Kevin Solomon, Constable Pct. 4
82. Bryan D. Woodard, Constable Pct. 4
83. Edward Wright, Constable Pct. 4
84. Donald G. Artis, Constable Pct. 4
85. Sha Steger Knight, Constable Pct. 4
86. Ron E. Bivins, Constable Pct. 4
87. Beth Villarreal, Constable Pct. 5
88. Henry Brown, Justice of the Peace Pct. 2, Place 2
whose applications were accepted in violation of the Election Code. No candidate wrongly
accepted by an unauthorized individual can legally be included on a ballot for the March
38. The Election Code authorizes challenges to the form, content, and procedure of an
application until the end of the day before any ballot to be voted on via early mail voting has
been mailed out.16 Early voting ballots for voting by mail were initially scheduled to be
mailed out by the Dallas County Elections Department on Saturday January 20, 2018.
39. The Original Petition in this matter initiated a challenge, well within this time limit, to the
form of, content of, and procedure related to the acceptance of the applications of the 128
candidates’ whose applications were not accepted and submitted by the DCDP Chair.
VI.CAUSES OF ACTION
40. The Plaintiffs re-allege and incorporate-by-reference the facts and allegations set forth above.
41. A justiciable controversy has arisen between the Plaintiffs and the Defendants. The Plaintiffs
ask the Court to declare that the 128 Candidates whose applications were not accepted by
Donovan before their wrongful submission to the Secretary of State are not eligible for
inclusion on either the March 2018 Democratic Primary Ballot or the November 2018
CAUSE NO.
DCRP v. DCDP – Plaintiffs’ First Amended Petition & Application for TRO / Temporary Injunction Page 13
42. It was necessary for the Plaintiffs to employ counsel to prosecute this action. In accordance
with § 37.001 et seq. of the Texas Civil Practice & Remedies Code, the Plaintiffs are entitled
to recover their reasonable and necessary attorneys’ fees and costs herein, for which they now
sue.
43. All conditions precedent to recovery have been performed, have occurred, or have been
waived.
Injunction
44. The Plaintiffs re-allege and incorporate-by-reference the facts and allegations set forth above.
45. One of the principal purposes behind the Texas Election Code is the prevention of election
fraud and electoral misconduct, and to protect the integrity of the electoral process. Tex. Elec.
Code §1.003(a); In re Bell, 91 S.W.3d 784, 787 (Tex. 2002). “A person who is being harmed
to appropriate injunctive relief to prevent the violation from continuing or occurring.” Tex.
46. The DCDP has submitted to the Secretary of State, in violation of the provisions of the Texas
Election Code in Section 172.029(a), 128 different candidates for inclusion in the March
2018 Democratic Primary Ballot, who were not accepted by the DCDP Chair Donovan. It is
past the statutory deadline set by the Secretary of State for any additional Applications to be
47. Many of the 128 identified candidates seek offices for which the DCRP was unable to timely
certify to the Secretary of State its receipt of a statutorily compliant candidate application.
the proper authority as having met the application requirements established by the Election
Code for inclusion on a primary ballot, the Election Code authorizes the parties to
subsequently nominate a designated candidate for office. Accordingly, the Plaintiffs are in
danger of being denied their statutory right to designate nominees for the many offices for
which Donovan, the only individual with the statutory authority to certify candidates’
compliance and submit them to the Secretary of State, did not do so.
48. Others of the 128 identified candidates seek offices for which the DCRP did timely certify to
the Secretary of State its receipt of one or more statutorily compliant candidate applications.
In these instances, the Plaintiffs are in danger of being harmed by having to face an
opponent in the November 2018 General Election, who the Texas Election Code bars from
inclusion as a candidate. Risner v. Harris County Republican Party, 444 S.W.3d 327, 345
(Tex. App.—Houston [1st Dist] 2014, writ of mandamus denied, 2014 Tex. LEXIS 801 (Tex.
September 8, 2014)).
49. The DCRP, and Shorey, have complied with their statutory obligations. They, and their
candidates, would suffer harm from upholding the stringencies of the Election Code, when
their counterparts have not done the same. Additionally, the Plaintiffs, like all Dallasites,
would suffer harm in the form of the damages to the integrity of the elections process that
would result from an unequal application of the law allowing 128 candidates onto the ballot,
despite the DCDP’s flagrant, willful, systematic submission of candidates to the Secretary of
CAUSE NO.
DCRP v. DCDP – Plaintiffs’ First Amended Petition & Application for TRO / Temporary Injunction Page 15
50. The injunctive relief sought herein is necessary to adequately protect the interests of the
Plaintiffs, and the voting public, from election fraud, misconduct, and manipulation of the
election process. The Plaintiffs do not have an alternative, after-the-fact, adequate remedy at
likelihood that the Defendants will allow the 128 identified candidates to be placed on March
2018 Democratic Primary Ballot, and, thereafter, on the November 2018 General Election
51. The Plaintiffs will suffer immediate and irreparable harm unless the Defendants, their agents,
knowledge of this injunction are immediately restrained from, directly or indirectly, engaging
(a) Certifying any of the identified candidates for inclusion on the March 2018
(b) Certifying any of the identified candidates as DCDP nominees on the November
Primary;
(c) Verifying or certifying the printing of ballots including any of the identified
candidates’ names as candidates for office in the March 2018 Democratic Primary or
(d) Conducting any Primary Election, or authorizing anyone else to conduct on their
behalf a Primary Election, in which any of the identified candidates are listed as
General Election, or authorizing anyone else to conduct on their behalf the November
2018 General Election, to the extent that any of the identified candidates is listed as
the DCDP’s primary winner for any office or as the DCDP’s nominee for any office;
and/or
(f) Declaring each and every any identified candidate ineligible under Tex. Elec. Code
§145.003(f);
52. The Plaintiffs have a substantial likelihood of prevailing on the merits. Given the high
likelihood that the Plaintiffs will prove that the Defendants did not comply with the Election
Code and prevail on the merits, no legitimate harm or prejudice will result to the Defendants
from the Court granting the requested injunctive relief before trial. On the other hand, the
Plaintiffs will suffer immediate and irreparable harm from a denial of such injunctive relief.
53. There is no remedy at law for Plaintiffs’ additional statutory rights if the TRO is not granted.
The Texas Election Code provides that when there has not been a Primary Election in either
party, the County Party Committees may so appoint a representative to represent them on the
ballot. If the TRO is granted, wherever there is no Republican candidate yet identified for an
office effected by the TRO, no primary race would held for that office in either party, leaving
both Parties the statutory right to appoint a nominee for the November election. However, if
the TRO is not granted, and the Plaintiffs were to prevail between the Primary and the
General Election, because the Democratic Party held a primary, the Plaintiffs could not
VII.CONDITIONS PRECEDENT
CAUSE NO.
DCRP v. DCDP – Plaintiffs’ First Amended Petition & Application for TRO / Temporary Injunction Page 17
54. All conditions precedent necessary for Plaintiffs to have and recover in this action have been
respectfully requests that: (a) citation issue and process be served on the DCDP and Carol
Donovan, its Chairwoman; (b) the Court grant both a Temporary Restraining Order, and, after a
hearing, both a Temporary Injunction and a Permanent Injunction against Defendants; and (c) the
Court grant the Plaintiffs a declaratory judgment as requested, including in its relief the
Plaintiffs’ reasonable and necessary attorney’s fees incurred prosecuting this action, costs and
expenses of suit herein, and both pre- and post-judgment interest on all monetary relief sought
herein at the highest rates allowed by law. Finally, the Plaintiffs ask for any other and further
relief to which the Court determines the Plaintiffs may be justly entitled.
/s/Elizabeth D.Alvarez
Elizabeth D. Alvarez
Texas Bar No. 24071942
CAUSE NO.
DCRP v. DCDP – Plaintiffs’ First Amended Petition & Application for TRO / Temporary Injunction Page 19
LOCAL RULE CERTIFICATION
In accordance with Local Rule 2.02, the undersigned hereby certifies that at least two hours
before presenting this application to the Court, the undersigned notified the Defendants of this
application. The undersigned sent a copy of the application and proposed order to Defendants via
email to those Defendants whose e-mail address the undersigned was aware of notifying them of
Plaintiffs’ intention to present this application to the Court ex parte as follows:
In the e-mail, the undersigned provided his cell phone number so that Defendants could contact
her. At least two hours before presenting this application to the Court, the undersigned notified
the following Defendants of the application by telephone and sent the Defendants who provided
her with their e-mail addresses a copy of the application and proposed order as follows:
/s/Elizabeth D. Alvarez
Elizabeth Alvarez
STATE OF TEXAS §
COUNTY OF DALLAS §
I, Davin Bernstein, state and declare that I am over 21 years of age and fully competent to make
this declaration. The facts set forth herein are true and correct and are within my personal
knowledge. I have read the foregoing Plaintiffs’ First Amended Petition Challenging the
Certification of the Improperly Certified Democratic Candidates Application for a Place on the
Democratic Primary Ballot, Application for Temporary Restraining Order, & Application for
Temporary Injunction, and that the facts stated in paragraphs 4-7, 3-32, 37-43, and 45-47, are
within my personal knowledge and are true and correct, unless otherwise qualified therein.
My name is Davin Bernstein, my date of birth is 08/24/1965, and my address is 228 Hollywood
Drive, Coppell, Tx, 75019. I declare under penalty of perjury that the foregoing is true and
correct.
________________________________
Davin Bernstein
Administrator, Dallas County Elections Department
CAUSE NO.
DCRP v. DCDP – Plaintiffs’ First Amended Petition & Application for TRO / Temporary Injunction Page 21
CERTIFICATE OF SERVICE
I certify that on January 22, 2018, I served a copy of this Petition on all counsel of record in
accordance with the Texas Rules of Civil Procedure via email, and through service of process.
DEFENDANTS
__________________________________________________________________________
__________________________________________________________________________
CAUSE NO.
DCRP v. DCDP, et al,
PLAINTFFS’ APPENDIX TO THEIR ORIGINAL PETITION, APPLICATION
FOR A TEMPORARY RESTRAINING ORDER, & APPLICATION FOR TEMPORARY INJUNCTION
TABLE OF CONTENTS
CERTIFICATE OF SERVICE..........................................................................................................158
CAUSE NO.
DCRP v. DCDP, et al,
PLAINTFFS’ APPENDIX TO THEIR ORIGINAL PETITION, APPLICATION
FOR A TEMPORARY RESTRAINING ORDER, & APPLICATION FOR TEMPORARY INJUNCTION
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RESPECTFULLY SUBMITTED this 19th day of January, 2018.
s/Elizabeth D. Alvarez
Elizabeth D. Alvarez
Texas Bar No. 24071942
CAUSE NO.
DCRP v. DCDP, et al,
PLAINTFFS’ APPENDIX TO THEIR ORIGINAL PETITION, APPLICATION
FOR A TEMPORARY RESTRAINING ORDER, & APPLICATION FOR TEMPORARY INJUNCTION
APPENDIX PAGE 157
CERTIFICATE OF SERVICE
I certify that on January 18th, 2018, I served a copy of this Petition on all counsel of record in
accordance with the Texas Rules of Civil Procedure via email, and/or through service of process.
DEFENDANTS
CAUSE NO.
DCRP v. DCDP, et al,
PLAINTFFS’ APPENDIX TO THEIR ORIGINAL PETITION, APPLICATION
FOR A TEMPORARY RESTRAINING ORDER, & APPLICATION FOR TEMPORARY INJUNCTION
APPENDIX PAGE 158