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1. Ms.

Perdue has consistently failed to embrace her co-chair as of equal responsibility and she has
failed to work with her co-chair to share information and communications. She has, in point of
fact, held meetings with selected officers of the Party and made decisions without the
knowledge and/or participation of her co-chair. The unprecedented nature of this SCGOP-
approved co-chair system absolutely requires that Ms. Perdue understands her co-chair’s equal
states and that together, they must work to define the nature and responsibilities of the
HCGOP’s co-chairs.

2. Ms. Perdue has steadfastly refused to respond to repeated formal and informal requests for
what must be universally considered the most basic, fundamental materials necessary and
required by law and by tradition to operate the HCGOP or any a legitimate organization.

3. Ms. Perdue resisted turning over the HCGOP’s books and other financial information to the
newly appointed Party Treasurer, Eric Santorelli. On May 24, 2019, when she finally presented
the HCGOP bank checkbook to Mr. Santorelli, those checking account records only went back as
far as late December 2018. Critically, there was no back-up documentation for what amounts to
tens of thousands of dollars’ worth of checks written and deposits made – no invoices, no
receipts and, importantly, no “books:” in short, it appears the Horry County Republican Party,
throughout Ms. Perdue’s tenure, kept little or no financial records of any kind. Were it not that
the bank maintains copies of checks written, Mr. Santorelli would have no idea what monies
were expended on what products and/or services.

4. Also on May 24, 2019 the checkbook included a carbon of check #2257 that had been made
payable very day to “Cash” in the amount of $1,500.00. Although no invoice accompanied the
check that covered a $1,500 cash dispursement by Ms. Perdue, a note in the memo portion
denoted “”Cash for Website Coding”. No records exist of any authorization approvals for a
check of $1,500 (to cash or any individual) by fellow HCGOP officers, by the Ways & Means
Committee, or by the Executive Committee. Shockingly, only one signature appears on that
check … that of Dreama Perdue. Her unilateral decision to write a check to cash and to spend
$1,500 on “Website Coding” without the express approval of other officers and/or the Ways &
Means Committee is in direct violation of the Party Bylaws.

5. Upon further examination of 160 checks dating back to 11/3/15 (presented to Mr. Santorelli by
Ms. Perdue – as well other checks that Mr. Santorelli was able to acquire from the bank
directly, it became painfully evident that Ms. Perdue has not only consistently failed to follow
financial procedures established in the HCGOP Bylaws, but has also consistently failed to follow
standard acceptable business procedure for expenditures and record-keeping.

• Out of a total of 160 checks reviewed written by Ms. Perdue over the last (45+) months,
a total of only eleven (11) checks contain the two signatures required in the Bylaws for
check of ANY amount. Of those 160 checks, 76 checks were written by Ms. Perdue in
amounts in excess of $250; including 13 written in amounts in excess of $1,000. Of the
13 in excess of $1,000, only 4 had the required 2 signatures. It is unknown whether the
checks over $1,000 were approved by the Ways and Means committee.

• A total of 6 checks were made payable to “cash” for “change” and or a variety of
sometimes unspecified purposes, for which no corresponding deposit has been
identified as received.
• A total of 39 transactions (28 checks plus 11 automatic debit) totaling $13,314.87 were
made payable to “Cardmember Services” for credit card payments, yet the HCGOP has
no credit card issued in its name. As of this writing, there are no corresponding receipts
identifying the nature and purpose of these credit card charges – to say nothing of an
explanation as to whose name appears on the credit card in question.
• Despite being said that Dream Perdue possesses a HCGOP cell phone, there are no
records of funds being dispersed directly for any phone services. It is thought that the
payments to the “Cardmember services “credit card include phone service charges ,
among other unknown expenses. It has been stated that Dream Perdue has a HCGOP
phone (number (843) 998-1271). This phone number is NOT registered to the Horry
County Republican Party and is, according to Ms. Perdue herself, her personal cell

6. HCGOP Insurance Policy

Ms. Perdue has repeatedly failed to respond to requests by her co-chair to provide him with a
copy of the HCGOP Insurance Policy (for which bank records show we are spending in excess of
$1,200 annually). After almost 3 months of refusals and concerned about the nature and scope
of the coverage we are receiving, Mr. Carey contact the appropriate insurance company shown
on the checking account and was able to obtain a copy of the policy. Critically, it appears that
the policy does NOT include ANY insurance for Directors and Officers – meaning that every
officer and every EC may be liable for damages in a lawsuit. In addition, the liability policy
denotes coverage at 2 addresses (one owned by Winyah Road LLC , the other the property of
past HCGOP chairman Robert Rabon) This situation is untenable and completely indefensible.

7. Website & Social Media.

Ms. Perdue has repeatedly failed to direct those responsible for building and/or maintaining the
official HCGOP website and/or Social Media pages to prohibit the use of these important Party
communications vehicles for individual promotion, including that of specific candidates and/or
political organizations. In addition to failing to share “administrative” tasks with her duly-
elected co-chair, she has taken it upon herself to determine what organizations qualify to be
listed as “approved” by the HCGOP – even though there IS NO SUCH approval procedure.

8. Membership Database.
Ms. Perdue has repeatedly failed to provide copies of the HCGOP membership database,
including records of who has paid due and when; contact information for both phone, snail mail
and Email and other information absolutely vital to the execution of her duties as co-chair of the
Party – and critical to the successful execution of the duties and responsibilities of the various
Standing Committees. Accurate membership data is the lifeblood of any membership
organization, especially one involved in politics and elections.

9. Public contact/responsiveness. Numerous test calls to (843) 998-1271 have been answered
simply “Hello” rather than a formal greeting such as “Thank you for calling the Horry County
Republican Party.” Still another phone number appears on some Facebook Pages (843-488-
4445) … a number that has been disconnected for several years. Standing Committee chairs and
members, along with Ms. Perdue’s co-chair, insist that prompt and accurate response to public
or member inquiries by ANY communications means is absolutely vital to the successful
operation, maintenance and growth of the HCGOP.