Law Office of Chris Ford125 East Coronado RoadPhoenix, AZ, 85004602-688-5571
APPLICATION FOR TEMPORARY RESTRAININGORDER; PETITION FOR PRELIMINARY INJUNCTIONPage 3 of 7
unqualified to vote.LULAC officers failed to follow Robert’s Rules of Order when conducting the election.Prior to the June 8, 2013 LULAC AZ convention, plaintiff Salazar received a certificatefrom LULAC stating that her council #1135 was in good standing and a “LULAC Receipt of Payment” dated May 28, 2013 showing that LULAC Council #1135 had paid $306 to thenational office on April 29, 2013..
to Verified ComplaintThe Receipt specifies that the council’s 11 members, four delegates and four alternateswere in “good” standing.
to Verified Complaint.Plaintiff Miranda herewith submits to the Court a list of approximately 29 duly registereddelegates to the LULAC AZ convention on June 8, 2013,
all of whom defendants denied theright to vote
to Verified Complaint.Members of LULAC enjoy the following rights:a.
“To participate in all meetings and other activities of their respective councils.”Constitution of the League of United Latin American Citizens (“LULAC Const.”), art. 4, §1b.(2); b.
“To propose, discuss and vote on matters of interest to and for the welfare of theCouncil or League.” LULAC Const., art. 4, § 1b.(3);c.
and be candidates for an office in their Council, District, State or NationalConventions, provided that in the case of offices at levels higher than their Council, they arecertified as delegates to the convention, have the support of respective Council and otherwisefulfill all requirements of the office sought.” LULAC Const., art. 4, § 1b.(4) (emphasis added);d.
At conventions, “[o]nly accredited delegates registered at the Convention will beallowed to vote.” Bylaws of the League of United Latin American Citizens (“LULAC Bylaws”),art. II, § 3h;e.
“Each Council in good standing
shall have the right to send as many delegates and alternates as it is entitled to
,” according to a chart in the bylaws. LULAC Bylaws, art. II, §4(emphasis added).//