VII. CHALLENGE OF CLINTON DELEGATES — CAMPAIGNING BEFORE SANCTIONED PRIMARY
63. Prior to the enactment of 2007 PA 52, all of the major candidates for the Democratic nomination signed a pledge not to “campaign or participate” in any state which schedules a presidential election primary or caucus before February 5, 2008, except for the pre-window states of Iowa, Nevada, New Hampshire and South Carolina.
64. As a result of the enactment of 2007 PA 52, four of the Democratic candidates, Sen. Joe Biden, former Sen. John Edwards, Sen. Barack Obama, and New Mexico Gov. Bill Richardson withdrew from Michigan’s presidential primary process.
65. The Clinton campaign participated in Michigan’s sanctioned primary, by choice, via inclusion on the Michigan ballot.
66. Prior to the sanctioned primary, and continuing as of this date, the Clinton campaign sent emails and established a website specific to Michigan .
67. As of this date, the official co-chairs of the Clinton campaign in Michigan are James Blanchard and Joel Ferguson.
68. On or before Q1 2007, James Blanchard gave $2,300 to the Clinton campaign.
69. On or before January 15, 2008, James Blanchard paid for widely distributed campaign materials and mailings, urging a vote for Clinton in Michigan’s sanctioned primary. [Exhibit E]
70. While the DNC is not responsible for prosecuting alleged criminal violations of campaign finance laws, activities of officials representing the campaign are within the scope of sanctions.
Non-Binding Primary
71. If the Michigan Democratic Party makes the Section III adjustments at its May 17, 2008, meeting for selection of at-large delegates, Clinton delegate votes from Michigan should not be counted during the convention, pursuant to Rule 20.C(1)(b).
District Convention Participants
72. Should the Michigan Democratic Party fail to make needed adjustments at its May 17, 2008, meeting for selection of at-large delegates, the entire delegation must be recalculated to reflect district-level participation.
73. Clinton pledged delegates should be removed, pursuant to Rule 20.C(1)(b).
74. This would be the most efficacious method of achieving the fifty (50%) percent delegate reduction of Rule 20.C(1)(a).
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