Clinton Camp Counsel Complains About Texas Caucus

TO: Interested Parties
FROM: Lyn Utrecht Campaign Counsel
RE: Caucus Irregularities
The campaign legal hotline has been flooded with calls containing specific accusations of irregularities and voter intimidation against the Obama campaign. This activity is undemocratic, probably illegal, and reflects a wanton disregard for the caucus process.
The three most egregious categories are:
1) Irregularities: Prematurely Taking Precinct Convention Packets by Obama Campaign
Numerous calls have shown that Obama supporters prematurely removed convention packets from polling places. Packets may not legally given out until 7:15 PM or when the last voter has cast a ballot in the primary. The Texas State Party warned the Obama campaign in writing that they may not take these packets early or remove them from the polling locations. The Party directed that these irregularities be reported to law enforcement “since they amount to criminal violations.” The Party stated “removing convention packets … will not be tolerated.”
A sampling of the precincts where this occurred are:
659 – Tarrant
709 – Houston
2316 – Tarrant
1205 – Dallas
3127 – Bexar
3082 – Fort Bend
18/224 – Harris
3221 – Dallas
87 – El Paso
851 – Houston
115 – Harris
470 – Galveston
388 – Harris
3000 – Dallas
1214 – Dallas
20 – Medina
205 – Walker
2) Voter Intimidation: Lock-out of Clinton caucus goers by Obama Campaign
Numerous calls have been received that the Obama campaign has taken over caucus sites and locked the doors, excluding Clinton campaign supporters from participating in the caucus. The Clinton supporters have been unable to enter the premises to caucus. In at least one instance, law enforcement was called and forcibly opened the caucus site.
A sampling of the precincts where this occurred are:
4401 – Dallas
2052 – Tarrant
4402 – Dallas
75 – Harris
18 – Hardin
259 – Harris
124 – Nueces
4050 – Tarrant
115 – Harris
6 – Roma County
78 – Jefferson
117 – Denton

  1. There are numerous instances of Obama supporters filing out precinct convention sign-in sheets during the day and submitting them as completed vote totals at caucus. This is expressly against the rules. The sign-in sheets were copied by the Obama campaign from the Texas Democratic Party website and taken by supporters to various polling places to sign-up caucus goers prior to the start of the caucuses


  1. I do not release sources. This was an internal memo that is sent tome from a insider close the the Clinton Campaign. Believe me,I am not the only one who got this memo. I

    Phone: (202) 293 1177
    Lyn Utrecht is a Partner at Ryan, Phillips, Utrecht & MacKinnon. She practices in the areas of federal and state election, campaign finance, ethics and lobbying laws. Her practice includes representation of Members of Congress, presidential candidates, campaign committees, trade associations, membership organizations, labor organizations and corporations before the Federal Election Commission, Senate and House Ethics Committees and state election commissions. Ms. Utrecht holds an undergraduate degree from Yale University (B.A. 1974) and a Juris Doctor from Georgetown University Law Center, cum laude (1979).
    Ms. Utrecht was Counsel to four of the 2004 presidential primary campaigns (Edwards, Dean, Graham, Moseley Braun), Gore/Lieberman 2000, Clinton/Gore ’96 and ’92, the 1992 Harkin for President campaign, and the 1984 Mondale campaign. She has represented numerous Senate campaigns including the Hillary Rodham Clinton for US Senate Committee.
    Prior to joining the firm, from 1976 through 1983 she was in the General Counsel’s office at the Federal Election Commission, from 1980 to 1983 as Special Assistant General Counsel. While at the Commission, Ms. Utrecht specialized in litigation, representing the Commission in numerous cases in federal district and appellate courts. Ms. Utrecht is also a member of the Election Law Section of the American Bar Association Administrative Law Division, and recently completed a three year term on the American Bar Association’s Standing Committee on Election Law and now serves on its Advisory Commission. She is a regular faculty member for the Practicing Law Institute’s program on corporate election law.
    Ms. Utrecht is admitted to practice in the District of Columbia and Maryland.

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