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To: The Democratic Party of Virginia
From: Gail Gordon Donegan
Re: Convention 2012 Complaint

I was a delegate from the 8th Congressional District to the DPVA State Convention on June 2. I observed numerous rule violations. I hereby challenge the legitimacy of the vote at the convention to elect Frank Leone and George Wallace to the DNC. The precise nature of the challenge and facts in support thereof are detailed in the body of this complaint.

According to the Democratic Party of Virginia Democratic Party Plan ("DPVA Plan"), the following regulations were violated:

1. Section 4.5 of the DPVA Plan states that "The State Convention held in the year of a presidential election shall elect the members of the Democratic National Committee allocated to Virginia, each member to serve a term of four (4) years." There was no legitimate election for DNC members. George Burke, Chair of the 11th District, certified delegates from any district but first made those delegates swear to vote his "Unity Team" slate, which is a violation of Section 14.5 of the DPVA Plan. He would not certify anyone who would not swear to support the "Unity Team" slate. Burke improperly credentialed delegates to vote in the 3rd district over the objections of the 3rd district chair, Linda Brooks, with whom I have spoken and who confirms these facts. There were insufficient paper ballots for the 1st district delegates for the paper vote, which further strains the legitimacy of the vote. Brian Moran allowed a departure from the rules with a confusing voice and standing vote, after someone made a motion for division, which further confused the issue. People sitting near me were unable to hear above the shouting and were not even sure what they were voting on or what "division" meant. As I observed the count, a protester was escorted out of the room by an armed guard, thus intimidating those of us who might otherwise have protested as well. This was all allowed by Craig Fifer, the DPVA Vice Chair of Technology, who was acting as Parliamentarian. I am not aware of any authorization of that change in role for Mr. Fifer. It is not his official role within DPVA.

2. According to Section 4.10, "The Central Committee shall remove from office and membership any member ...who shall be guilty of willful neglect of any duty imposed upon such member." Chairman Brian Moran and Vice Chair for Technology Craig Fifer willfully neglected their individual duties to hold a proper vote, and George Burke, Chair of the 11th District, committed fraud and violated convention rules.

The specific relief I request with respect to this challenge is that both Frank Leone and George Wallace be disqualified from the DNC and a proper vote be held at a date(s) and place(s) to be determined by the DPVA in the form of a new caucus or convention. I also request the Brian Moran, George Burke and Craig Fifer be removed from their offices with the DPVA. I respectfully request that I receive from you a signed copy of this complaint with an acknowledgement of your receipt of same.

Sincerely,

Gail Gordon Donegan
Delegate, 8th Congressional District

Received on behalf of DPVA by:

Name: ___________

Signature: __________
Date: _____________