Complaint in Fannie Young v. Keith Bulen, Marion County Republican Central Committee, Richard Lugar, Lee Eads, Noble Pearcy, and Winston Churchill, U.S. District Court, Southern District of Indiana, Indianapolis Division, filed November 4, 1968

Fannie Young, the lead plaintiff in a class action against the Marion County Republican Central Committee and the individuals listed, accuses the defendants of having conspired to intimidate African American voters in the city and keep them from voting in the 1966 election. Young charges the central committee with sending deputy prosecutors and other agents to polling places to serve as challengers to deny African Americans the right to vote as well as with sneind police and dogs to polling places in the African American wards of the city to intimidate voters. This is a complaint for an emergency restraining order to ensure the tactics are not repeated in the upcoming 1968 election.