Raghib for Connecticut

Raghib Allie-Brennan
203.794.4486
rab@raghibforct.com

May 31, 2016

TO:

Members of the Connecticut Democratic State Central Committee

24th District:
Alice Hutchinson
Ted Feng

byrd002@yahoo.com
tfeng@uaw.net

26th District
Barbara A. Reynolds
Ted Hoffstatter

barbaraareynolds@gmail.com
tedhoffstatter@hotmail.com

28th District
Susan Barrett
William Burke

ladybugsbarrett@snet.net
liam06824@yahoo.com

Dear All:
On May 17, 2016, the Democratic Party in the 2nd State Assembly District held a convention to
nominate a candidate for that seat for the November, 2016 election. Eleven delegates attended that
convention, and selected the undersigned, Raghib Allie-Brennan, as the party-endorsed candidate for
the 2nd District, by an 8-3 margin. I have duly filed a certificate with the Secretary of State as the
party-endorsed candidate.
The other declared candidate, Thomas C. Burke, Jr., received the support of 3 delegates, which was
more than 15% of the total delegates at the convention. Last night, May 30, 2016, the chair of the
convention, Nicholas J. Vitti, Jr., signed a certificate of candidacy for Mr. Burke as having received
15% of the vote at the convention. It is my understanding that Mr. Burke intends to file this certificate
with the Secretary of State today, thereby claiming eligibility for a primary.
Mr. Burke is not eligible to file this certificate, and his signature thereon violates the provisions of the
General Statutes governing election law. Under Section 9-400 of the General Statutes,
A candidacy for nomination by a political party to a district office may be filed by or
on behalf of any person whose name appears upon the last-completed enrollment list of such
party within the district the person seeks to represent that is in the office of the
Secretary of the State at the end of the last day prior to the convention for the party from
which the person seeks nomination .
Mr. Burkes name did not appear on the enrollment list of the Democratic Party prior to the
convention. Attached to this letter please find copies of all of Mr. Burkes voter registration cards.

7 Monarch Drive
Danbury, CT 06811
Paid for by Raghib for Connecticut, Starr L. Unwin, Treasurer

Raghib for Connecticut

As can be seen, Mr. Burke was a member of the Republican Party from the first day he registered to
vote in March 2007 at the age of 18.
On March 29, 2016, Mr. Burke submitted a change of registration card to become a member of the
Democratic Party. This change of registration was processed by the Bethel Registrar of Voters on
March 31, 2016.
General Statutes 9-59 provides that
Any elector whose name has been transferred from one enrollment list to another or
who has applied for erasure or transfer of his name from an enrollment list shall not
be entitled to participate or vote in a caucus or primary of any party, participate in the
appointment of members to any board or commission that is political in nature, be
appointed as a member of any board or commission that is political in nature or be
entitled to the privileges accompanying enrollment in any party for a period of three months
from the date of the filing of his application for transfer or for erasure
Under the statutes, therefore, Mr. Burke will not be entitled to full privileges in the
Democratic Party until June 29, 2016, and his name will not appear on the enrollment list until
then. The privilege of claiming the eligibility to run in a primary against the party-endorsed
candidate is not one which falls within the exceptions provided by the Statutes.
I hereby invoke the dispute resolution procedures set forth in Article V of the Rules of the
Connecticut Democratic Party. Under Article V, disputes must first be brought to the State
Central Committee members covering the district in question. In this case, three districts (the
24th, 26th and 28th) include a portion of the 2nd Assembly District.
I request that you confer and convene a meeting as soon as is possible, as this is a very time
sensitive issue. Article V suggests that you may request a legal opinion from counsel to State
Central. The ruling that we request is that the State Central Committee determine that Mr.
Burke is not eligible to submit a certificate of candidacy for a primary in the 2nd Assembly
District, and to direct the Secretary of State not to schedule a primary nor place his name on
the ballot. As this is a legal question, you may wish to consider simply deferring to the Dispute
Resolution Committee.

Raghib for Connecticut

Thank you in advance for your consideration.
/s/
Raghib Allie-Brennan
Copy to:

Theodore Bromley
Dominic Balletto, Jr.
Kevin Reynolds
Thomas C. Burke, Jr.

ted.bromley@ct.gov
nballetto@ctdems.org
kreynolds@rsgllc.com
thomas@thomasburkect.com