STATE OF SOUTH DAKOTA COUNTY OF _ Yankton Eist___ JUDICIAL CIRCUIT Yankton County GOP Committee _ PLAINTIFF'S STATEMENT OF BMALL CLAIMS. Plaintiff Names or Business Name “ suc casee: LLL) SUC AD-| 51 Roger Meyer Greg Adamson Duane Becker FILED Defendant Names or Business Namo MAR 27 2023 Describe the basis for your cialm: (use additions! sheat i See Attached Sheet $112,000.00 (exclude Interest and filing fees) Interest ‘Subtotal Filing Fees Plaintiffs Total $12,050.28 (21 Sheriff Service only — no certified mall TB sherityPersonal Service requested if cortified mall retuned undelivered “Additional fees charged for service options listed above. It's the plaintiff's responsibility to as oF process server for fea amounts and to file the Return of Service. wile Ufitis‘There was an unauthorized transfer of $12,000 from the Yankton County Republican GOP Committee on December 7, 2022 by Defendant Duane Becker. ‘The Defendant's were members of the former Yankton County Republican Committee and transferred the $12000 to their newly formed District 18 Republican Political Action Committee without any authorization from local Committee members, the Yankton County GOP Committee, or the Republican State Board. There are no minutes of @ meeting authorizing the action of the Defendants. ‘The Yankton County Republicans have not and do not presently have by-laws separate and apart from the State Republican By-Laws. The county organization is governed by the state by-laws asis the situation with most if not all other South Dakota counties that have organized Republican Committees. ‘The lack of minutes or documented approval by the State Executive Board as required by the state by- laws evidences their lack of authority to withdraw the funds. A request for the return of funds has been denied. Because this action was taken without the required authorization, it was wrong for the Defendant's to take this action. The Plaintiff seeks the return of the $12,000 to the Yankton County Republican GOP Committee. The fact that Defendant's used this money to create a new PAC is irrelevant. since they are the only three persons who have any control over how the funds are spent. This is contrary to how the funds are used under the control of the Yankton County Republican GOP Committee where all of the membership votes on how funds are spent. | pray that the court grant this relief,Facts regarding the $12000 transfer. |, Steve Rokahr, am the current Chairperson of the Yankton County GOP and have been authorized by a vote of its members to bring this matter before the court. The timeline for the activities which brings me before this court are the actions of the Defendants are as. follows. Since the Yankton County Republicans have not and do not presently have Bylaws, consequently the county organization is governed by the State Republican bylaws as is the situation is for most if not all other SD county Republican Committees. The state Republican Bylaws include several sections governing the County's duties and responsibilities: Sections 3-5 and the financial rules in Section 8. Note specifically the $2500 limit of expenditure without approval. Exhibit__1__. At the October meeting there was a motion made to have elections that evening. That motion was tabled by the Chairperson, Deb Bodenstedt, as she indicated that the elections would be held at a November 8" or sooner meeting. See the meeting minutes Exhibit _2 On November 5 Deb Bodenstedt the Chairman sent out an email canceling the November 8" meeting and rescheduling it for November 21” and the email indicated that the elections would be held at that meeting. See Exhibit_3 ‘The November Meeting was later cancelled, claiming (falsely) that the location, JoDean’s where numerous ‘meetings and the Lincoin Day dinners had been held was not ADA compliant so the meeting had to be cancelled. We have been meeting at JoDean’s for all the meetings that | have attended since May 2022. See Exhibit__4_. On November 29" a form creating a PAC was filed with the State, with its Directors being named as Roger Meyer, Chair, Greg Adamson, Co-Chair, and Duane Becker, Treasurer. See Exhibit_5__. ‘There was no meeting of the Yankton County Republicans in December 2022 ‘A Check for $12,000 was written by Duane Becker to the PAC on 12/7/22. It was deposited the same day into the PAC account. See Exhibit_6__. On December 29, 2022 the Yankton county precinct men and women called a special meeting for January 5, 2023 and notice was sent as required by the bylaws. Deb Bodenstedt sent an email notice to Yankton County Republicans on 12/31/22 scheduling a meeting for Jan 16% and indicated the county elections would be held at this meeting. This was in response to the meeting that had been called by the Yankton County Committee Precinct Men and Women which was sent ‘out on the 29% of December. ‘The meeting scheduled by Deb Bodenstedt was planned to occur AFTER the State Meeting. This was so the old board could attend the State Meeting in Pierre, which was scheduled for Jan 14 By delaying the elections, the existing board would retain the authority to vote at the state meeting. This included matters, such as voting for the Party Chair and other matters. Historically, the elections have been held early enough 0 the new board could attend and vote at the state meeting.The Precinct members sent out a Notice on 12/29/22 calling a meeting on 1/5/23. This notice was compliant with the requirements of the Bylaws for a special meeting. The goal was to have the election of officers before the State Republican meeting in Pierre on January 14. The Membership was informed by an email from Deb Bodenstedt on January 3” that the current board would ot attend the January 5® meeting called by the Precinct Men and women. See Exhibit__7__. There were 35 Precinct people at the meeting on January 5 but no elected officials. The bylaws are vague ‘about what to do when the elected officers do not attend a meeting properly called by the Precinct Men and ‘Women according to the bylaws, so at the Jan 5! meeting elections were held despite the deliberate absence of any elected officers and a new slate of officers were voted in. See meeting minutes as Exhibit__8__ Documents reflecting the election results from the S™ were taken to the Auditor and Certified and Notarized on January 8", Chris Patton and | went to Pierre for the State meeting on 1/14/23 with our paperwork and showed it to David ‘Wheeler, the Chairman of the Bylaws Committee. He refused to recognize our paperwork even when | showed him the email that the current board said they wouldn't attend our meeting. When Wheeler was asked what to do about officers who refuse to attend a properly called meeting the reply was “that's your problem”. At the meeting called by the old board on 1/16/23 there were 36 Precinct people in attendance and several members totaling 54 in all. The meeting was called to order by the vice president, Roger Meyer, and the agenda was followed. To summarize the elections. The old board members were all replaced. See Certification form as Exhibit 9. |, Steve Rokahr, was voted in as Chairman. After the meeting and for the following couple days, | tried to get some cooperation from the old board regarding the transfer all of the bank accounts, courity membership lists, previous meeting minutes, information on Lincoln Day Dinners, post office box, the Facebook account and other storage and misc. accounts. ‘On the 17" of January, Duane Becker assisted the new board to change the signature cards and have access to the Bank Account at First Dakota, When Stacey Nickels (the new Treasurer) started to go through the bank account records, one check immediately stood out. tt was the check for $12,000 to a PAC. emailed the former board on January 18" asking what authority the board had for the withdrawal of the funds. See Exhibit__10_. Duane Becker emailed a reply. | quote from his email See Exhibit_11__ “We believe the funds in question were properly transferred to the District 18 Republican Political Action ‘Committee (PAC) per the authority and unanimous vote of the Yankton County Republican Executive Committee”. Sincerely, DG Butch Beckerthen responded asking him for the documentation that would prove that the funds were “property transferred”. Ihave not been provided with any minutes or other documentation to prove that there was an executive ‘meeting of the Yankton GOP prior to the transfer of the funds. Lack of minutes means there was no meeting or other action to validate any decision to transfer this money. There is also no evidence that the outgoing board had State Executive Board approval. This is an alternative requirement for a large transfer, under Section Vill of the bylaws. received no response. | reached out to Daisy Kamback, (Secretary of the old board). | sat down at our church and discussed it with her. She said she wouldn’t give me any of the prior minutes. She would not comment on the check situation. On 1/28/31, \reached out to Roger Meyer, the new chairman of the GOP PAC. Ext This is his response | quote: “While we appreciate your referencing Section Vill Financial Regulations of the ByLaws of the South Dakota Republican Party, your interpretation is incorrect. This section of the “ByLaws” pertains only to the State (South Dakota) Party. They do not govern county party funding. We have contacted David Wheeler, Chairman ByLaws Committee of the South Dakota Republican Party, who confirms our interpretation of Section Vill Financial Regulations. Please submit future threats to the former Yankton County GOP executive committee as a group. Thank you Former Yankton County Republican Executive Committee" After | reached out to him, | talked to him at our Church the next Sunday. He claimed that he was very upset that we would question him regarding the money. | explained that | still needed the dacumentation for the check. He told me that | was never to talk to him or contact him again! ‘Yankton County Republicans have not and do not presently have by-laws apart from the State Republican By- Laws, consequently the county organization is governed by the state by-laws, as is the situation with most if not all other South Dakota county Republican Committees. The lack of minutes and documented approval by the State Executive Board that is required by the state by-laws demonstrates the previous Yankton county board members violation of the bylaws as recounted and documented above, Because this action was taken improperly, the proper remedy is the return of the $12,000 used to establish the separate PAC. ‘On behalf of the Yankton County GOP membership | petition the court to grant this relief. Thank You