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23evSboul FOR THE SUPERIOR COURT, 18" JUDICIAL DISTRICT GUILFORD COUNTY ~ NORTH CAROLINA AMY ©. (“CRISSY”) PRATT, in her official ‘capacity a8 Second School District Member, ww GUILFORD COUNTY SCHOOL BOARD Prati, pro se ‘AND. KKATHARINA("LINDA”) WELBORN, in her official Capacity as Fourth School District Member, GUILFORD COUNTY SCHOOL BOARD Plaintif, pro se ‘AND, MICHAEL LOGAN, Plaintiff, pro se DEENA HAYES-GREENE, In her oftici DISTRICT 8 REPRESENTATIVE ‘PUBLIC BODY, Defendant AND WILLIAM GOEBEL, in his official capacity as DISTRICT 3 REPRESENTATIVE GUILFORD COUNTY SCHOOL BOARD Defendant ‘AND DIANNE BELLAMY SMALL, in her official capacity as DISTRICT 4 REPRESENTATIVE GUILFORD COUNTY SCHOOL BOARD Defendant capacity as CHAIR, GUILFORD SCHOOL BOARD AND DEBORAH NAPPER, in her official capacity as DISTRICT § REPRESENTATIVE. GUILFORD COUNTY SCHOOL BOARD Defendant AND KHEM IRBY, in her official capacity as DISTRICT 6 REPRESENTATIVE GUILFORD COUNTY SCHOOL BOARD Defendant AND BETTYE JENKINS, in her official capacity as DISTRICT 7 REPRESENTATIVE GUILFORD COUNTY SCHOOL BOARD Detendent ‘AND ALAN SHEROUSE, in his offical capacity as AT-LARGE REPRESENTATIVE. GUILFORD COUNTY SCHOOL BOARD Defendant COMPLAINT #1 Plaintiffs allege that Defendant Board Chair Deena Hayes-Greene, in concert with the other Democrat members Guilford County (GC) Board of Education (BOE), violated the Nonth Carolina Open Meetings statute, specifically, N.C. General Section 143-318-10, an official meeting occurs whenever a majority of the members of a public body gather together to take action, hold a hearing, deliberate, or otherwise transact the business of the body. The meeting held by Defendant Hayes-Greene with Defendant Goebel to offer him the Distict3 seat and obtain his acceptance averted board and public input into the public business of candidate selection. Section 143-318- 10, by holding a series of unauthorized, serial, and secret telephone calls. The intent of these secret telephone calls was to brief the Democratic members of the BOE of a plan to appoint Defendant Wiliam Goebel to represent District 3 in lieu of appointing Plaintit Logan to the BOE. For several months—from December 2022 through March 2023— the BOE and the GC GOP argued over which entity had the right—the authority under the law—lo nominate and/or approve and appoint an individual from GCS District 3, For background purposes, Guilford County, North Carolina, is divided into eight schoo!

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