STATE OF

STATE OF MICHIGAN
MICHIGAN
IN THE COURT
IN THE COURT OF
OF APPEALS
APPEALS

MALINDA
MALINDA PEGO, ALI HOSSEIN,
PEGO, ALI HOSSEIN, HASSAN,
HASSAN, Court of
Court of Appeals
Appeals No.
No.
NEHME, ANN DELISLE,
NEHME, ANN JESSICA
DELISLE, JESSICA
BAREFIELD, NORM SCHINKLE
BAREFIELD, NORM SCHINKLE and
and
WARREN CARPENTER
WARREN CARPENTER Kent Circuit
Kent Circuit No: 24-00658-CZ
No: 24-00658-CZ
Hon. J.
Hon. J. Joseph
Joseph Rossi
Rossi
Plaintiffs-Appellees,
Plaintiffs-Appellees,

vs.
vs.

KRISTINA KARAMO,
KRISTINA KARAMO,

Defendant-Appellant.
Defendant-Appellant.

Defendant-Appellant’s
Defendant-Appellant's Motion to Stay
Motion to Stay

** ** ** Decision
Decision Needed
Needed By
By Friday, March 1,
Friday, March 1, 2024
2024 ** ** **
__________________________________________________________________

W ARNER N
WARNER ORCROSS &
NORCROSS & JUDD,
JUDD, LLP
LLP L OFFICE OF D
AW OFFICE
LAW J. H
ANIEL J.
DANIEL ARTMAN
HARTMAN
Johnathon Lauderbach
Johnathon Lauderbach (P51313)
(P51313) Daniel J.
Daniel J. Hartman
Hartman (P512632)
(P512632)
150 Ottawa
150 Ottawa Avenue,
Avenue, NW NW Suite
Suite 1500
1500 P.O. Box 307
P.O. Box 307
Grand Rapids,
Grand Rapids, MIMI 49503
49503 Petosky
Petosky MI 49770
MI 49770

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(616)
(616) 752-2000
752-2000 (231) 348-5100
(231) 348-5100
Counsel for Plaintiffs
Counsel for Plaintiffs Counsel for Defendant
Counsel for Defendant

C OLLINS E
COLLINS FARRELL PC
INHORN FARRELL
EINHORN PC
Donald D. Campbell (P43088)
Donald D. Campbell (P43088)
Kellie Howard-Goudy
Kellie Howard-Goudy (P69009)
(P69009)
4000 Town
4000 Town Center,
Center, 99th Floor
th Floor
Southfield, MI
Southfield, MI 48075
48075
(248) 355-4141
(248) 355-4141
[email protected]
[email protected]
Kellie.Howard-
Kellie.Howard-
[email protected]
[email protected]
Co-Counsel for Defendant
Co-Counsel for Defendant

Defendant-appellant Kristina
Defendant-appellant Kristina Karamo asks this
Karamo asks this Court
Court to stay lower-court
to stay lower-court

proceedings,
proceedings, including enforcement of
including enforcement of the February 27,
the February 27, 2024
2024 Order
Order Granting
Granting Plaintiffs’
Plaintiffs'
Motion for
Motion for Preliminary Injunction while
Preliminary Injunction while its
its application
application is
is pending and, if
pending and, if it
it grants
grants leave
leave

to appeal, while
to appeal, while the appeal is
the appeal is pending.
pending. In support of
In support of this
this motion,
motion, Karamo relies on
Karamo relies on MCR
MCR

7.209(A)(1) and (H)(2)

7.209(A)(1) and and states:
(H)(2) and states:

1.
1. Plaintiffs-appellees
Plaintiffs-appellees are among the 107 members of the Michigan

Republican State Committee who voted to replace defendant-appellant Kristina Karamo

with Peter Hoekstra on January 6, 2024.

2.
2. Plaintiffs-appellees filed a two-count complaint to challenge Karamo’s
Karamo's title

as chair under Committee's

Committee’s bylaws. Among other things, the complaint sought

declaratory relief that Karamo was properly removed as Chair of the Committee, and that

all actions Karamo took after allegedly being removed as Chair on January 6, 2024 are

void and have no force or effect.

3.
3. Plaintiffs-appellees filed aa motion
Plaintiffs-appellees filed for aa preliminary
motion for preliminary injunction on January
injunction on January

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24, 2024
24, 2024 incorporating
incorporating the complaint and
the complaint and seeking,
seeking, substantively,
substantively, identical
identical relief.
relief. The
The

circuit court
circuit court heard
heard that
that motion February 21,
motion February 21, 22,
22, and
and 27,
27, 2024.
2024. It
It entered
entered an
an order
order granting
granting

the
the motion on February
motion on February 27,
27, 2024.
2024. (Attachment 1).
(Attachment 1).

4.
4. Defendant-appellant
Defendant-appellant is
is contemporaneously
contemporaneously filing
filing an
an emergency
emergency

application for
application for leave
leave to appeal and
to appeal and aa motion for immediate
motion for consideration.
immediate consideration.

5.
5. This Court
This may stay
Court may stay any
any order
order from
from aa lower-court
lower-court under
under MCR
MCR 7.209(H)(2)
7.209(H)(2)

on "just
on “just terms.”
terms."

6.
6. The issues
The issues raised
raised in
in defendant-appellant’s application are
defendant-appellant's application are central
central to
to the
the

validity of
validity of the order granting
the order granting the
the preliminary injunction. Critically,
preliminary injunction. Critically, the order granting
the order granting

2
the
the preliminary injunction effectively
preliminary injunction effectively grants
grants the full relief
the full requested in
relief requested in plaintiffs’
plaintiffs'

complaint before
complaint before aa trial
trial on
on the merits, and
the merits, and the impact of
the impact of the order cannot
the order cannot be
be undone, even
undone, even

if defendant
if defendant prevails at trial.
prevails at trial.

7.
7. Further, the
Further, the order,
order, as
as it stands, voids
it stands, voids aa previously noticed MiGOP
previously noticed MiGOP

convention of
convention of delegates in Detroit
delegates in Detroit scheduled
scheduled for
for March
March 2,
2, 2024.
2024.

Accordingly, defendant-appellant
Accordingly, defendant-appellant Kristina Karamo asks
Kristina Karamo asks this
this Court
Court to enter an
to enter an

order staying
order staying lower-court
lower-court proceedings
proceedings until the conclusion
until the conclusion of
of this appeal.
this appeal.

Collins Einhorn
Collins Farrell PC
Einhorn Farrell PC

BY:
BY: /s/ Donald
/s/ Donald D.
D. Campbell
Campbell
Donald D.
Donald D. Campbell
Campbell (P43088)
(P43088)
Kellie Howard-Goudy
Kellie Howard-Goudy (P69009)
(P69009)
4000 Town
4000 Town Center,
Center, 99th Floor
th Floor
Southfield, MI
Southfield, MI 48075
48075
(248) 355-4141
(248) 355-4141
[email protected]
[email protected]
Dated: February
Dated: February 28,
28, 2024
2024

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3
RECEIVED by MCOA 2/28/2024 4:47:48 PM
ATTACHMENT 11
ATTACHMENT
 STATE OF MICHIGAN

IN THE 17TH CIRCUIT COURT FOR THE COUNTY OF KENT

MALINDA PEGO, ALI HOSSEIN, HASSAN CASE NO. 24-00658-CZ

NEHME, ANN DeLISLE, JESSICA BAREFIELD
NORM SCHINKLE and WARREN CARPENTER, HON. J. JOSEPH ROSSI

Plaintiffs,

v.

KRISTINA KARAMO,

Defendant.

Jonathan E. Lauderbach (P51313) Daniel J. Hartman (P52632)

Troy M. Cumings (P63278) Law Office of Daniel J. Hartman
Katherine G. Boothroyd (P85881) Attorneys for Defendant
Warner Norcross & Judd, LLP PO Box 307
Attorneys for Plaintiffs Petoskey, MI 49770
150 Ottawa Ave NW, Suite 1500 (231) 348-5100
Grand Rapids, MI 49503 [email protected]
(616) 752-2000 [email protected]

RECEIVED by MCOA 2/28/2024 4:47:48 PM

[email protected]
[email protected] Donald D. Campbell (P43088)
[email protected] Kellie Howard (P69009)
Collins Einhorn Farrell PC
Co-Counselfor Defendant
4000 Town Center, 9th Floor
Southfield, MI 48075
(248) 351-7170
[email protected]
[email protected]

ORDER GRANTING PLAINTIFFS' MOTION FOR PRELIMINARY INJUNCTION

This matter comes before the Court on Plaintiffs' Motion for Preliminary Injunction. After

reviewing the motions and briefs filed by the parties, hearing oral arguments, and otherwise being

fully informed, this Court hereby GRANTS Plaintiffs' Motion for the reasons stated on the record.

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 Therefore, this Court finds, that as of January 6, 2024, Ms. Karamo was removed as Chair

of the Michigan Republican State Committee and that Malinda Pego became the Acting Chair of

the Michigan Republican State Committee, and that any actions of Ms. Kamaro since January 6,

2024 purporting to be taken on behalf of the Michigan Republican State Committee are void and

have no effect.

This Order prohibits Ms. Karamo, or any other person acting for or on her behalf, from:

(1) holding herself out as Chair of the Michigan Republican State Committee, in person, to the

media, or on social media; (2) calling any meeting of the Michigan Republican State Committee;

(3) conducting, or attempting to conduct, any business in the name of the Michigan Republican

State Committee or the Michigan Republican Party; (4) accessing any postal boxes held in the

name of the Michigan Republican State Committee or the Michigan Republican Party; (5)

accessing any bank accounts held in the name of the Michigan Republican State Committee or the

Michigan Republican Party; (6) filing or causing to be filed any report or any other documentation

required by state or federal campaign finance or election law; and (7) engaging in any

RECEIVED by MCOA 2/28/2024 4:47:48 PM

communication, including on social media, that purports to be issued on behalf of the Michigan

Republican State Committee or the Michigan Republican Party.

This Order is effective immediately, and has retroactive application to any actions after

January 6, 2024 by Ms. Karamo purporting to act as chair.

The Trial date of June 10, 2024 remains.

IT IS SO ORDERED.

THIS IS THE NOT FINAL ORDER AND DOES NOT CLOSE THE CASE.

Date: c2 - 7 ca arttri - P/
HON. J. JOSEPH ROSSI
Circuit Court Judge

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