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APP TRO Cv2013-008731 Conformed 14jun2013

APP TRO Cv2013-008731 Conformed 14jun2013

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02/15/2014

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Law Office of Chris Ford125 East Coronado RoadPhoenix, AZ, 85004602-688-5571
 APPLICATION FOR TEMPORARY RESTRAININGORDER; PETITION FOR PRELIMINARY INJUNCTIONPage 2 of 7
F
ACTS
 
Consistent with the facts articulated in plaintiffs’ Verified Complaint, in summary:The League of United Latin American Citizens, Arizona Chapter (“LULAC AZ”) held itsannual convention, located at Pima Community College, Desert Vista Campus, Tucson, Arizona,on June 8, 2013.A primary purpose of this convention was for delegates from local Councils to vote for delegates who will represent Arizona in voting at LULAC’s annual national convention for 2013,which is scheduled to take place in Las Vegas, Nevada from June 17-22, 2013.Defendants and Does managed and controlled the aforementioned LULAC AZconvention on June 8, 2013, including and especially the election of delegates and voting process.LULAC AZ’s 2013 annual state convention agenda advertised that registration for thatevent would take place from 8 a.m. to 10 a.m. on the morning of June 8, 2013. Exhibit A toDeclaration of Chris Ford (“Ford Dec.”) at 1-2.Plaintiff Soto arrived prior to 10 a.m., and defendants registered him to participate in theconvention, including qualifying him to vote in LULAC AZ’s elections that day as a delegatefrom his Council.Plaintiffs Salazar and Miranda arrived at approximately 10:45 a.m., but defendantsnonetheless registered them to participate in the convention, including qualifying them to vote inLULAC AZ’s elections that day as a delegates from their Councils.Because defendants registered plaintiffs, provided plaintiffs with delegate badges andtold them they were qualified to vote, plaintiffs believed they were duly registered for theconvention and eligible to vote.However, when the election started during the afternoon session of the convention,defendants did not call plaintiffs’ names or council numbers, did not seat plaintiffs to vote, and infact denied and prevented plaintiffs from any participation in the voting.Despite their having been led plaintiffs to believe that they were validly registered andqualified to vote, defendants, immediately prior to the election, told plaintiffs told they were
 
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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..
Exhibit A,
to Verified ComplaintThe Receipt specifies that the council’s 11 members, four delegates and four alternateswere in “good” standing.
Exhibit A
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
.
Exhibit B
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.
 
To vote
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).//

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