SCV 20191127 3VerifiedComplaint OCR

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STATE OF NORTH CAROLINA IN THE GENERAL COURT OF JUSTICE

COUNTY OF ORANGE s u pe r io r c |)Iir 5i J.i Vis io n
File No. 19CVS IO / V

201^ NOV 21 A (h 10
NORTH CAROLINA DIVISION SONS OF )
CONFEDERATE VETERANS, INC., a North ) ORANGE CO., C.S.C.
Carolina corporation, ) ^€2-----'
)
BY.
Plaintiff, )
)
v. ) VERIFIED COMPLAINT
)
THE UNIVERSITY OF NORTH )
CAROLINA and THE UNIVERSITY OF )
NORTH CAROLINA BOARD OF )
GOVERNORS, )
)
Defendants. )
Plaintiff North Carolina Division Sons of Confederate Veterans, Inc., a North Carolina
corporation, respectfully alleges and states as follows:
PARTIES
1. Plaintiff North Carolina Division Sons of Confederate Veterans, Inc. (“SCV” or
“Plaintiff’) is a North Carolina registered nonprofit corporation organized under the laws of North
Carolina with headquarters in Sanford, Lee County, North Carolina.
2. SCV’s Articles of Incorporation filed with the North Carolina Secretary of State
provide that SCV was organized for the following purposes:
To associate in one united, compact body men of Confederate ancestry, and to

cultivate perpetuate and sanctify the ties of fraternity and friendship entailed
thereby; to aid and encourage the history and achievement from Jamestown to this
present era, constantly endeavoring to see that the events of the War Between The
States and the heroic contributions of the Confederate soldiers of Indian Territory
are authentically and clearly written, and that all documents, relics and momentoes
[sic] produced and handed down by those active participants therein are properly
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treasured and preserved for posterity; to aid and assist in the erection of suitable
and enduring monuments and memorials to all Southern valor, civil and military,
wherever done and wherever found; to instill into our descendants a devotion to
and reverence for the principles represented by the Confederate States of America,
to the honor, glory and memory of our fathers who fought in that cause ....
Said corporation is organized exclusively for charitable, religious, educational, and

scientific purposes .... [T]he corporation shall not carry on any other activities not
permitted to be carried on ... by a corporation exempt from Federal income tax
under section 501(c)(3) of the Internal Revenue Code ....
See Exhibit A (Articles of Incorporation, North Carolina Division Sons of Confederate Veterans,
Inc. (filed Jul. 11, 1988)).
3. As a registered nonprofit corporation under North Carolina law, Plaintiff has the
capacity to bring this action and is authorized to bring this action pursuant to the provisions of its
charter and rules of internal governance, and the signatory to this Verified Complaint has the
authority to institute this action on behalf of Plaintiff.
4. The University of North Carolina (“the UNC System”) is a public, multi-campus
university system authorized and governed by Article IX, Section 8, of the North Carolina
Constitution and Chapter 116 of the North Carolina General Statutes.
5. The University of North Carolina Board of Governors (“the UNC BOG”) is the
body politic and corporate organized and authorized under Section 116-3 of the North Carolina
General Statutes and is charged under Section 116-11 with (among other things) governing the
constituent institutions of the UNC System, including the University of North Carolina at Chapel
Hill (“UNC-CH” or “the University”), and with the general determination, control, supervision,
management, and governance of all affairs of the constituent institutions of the UNC System.
Under N.C. Gen. Stat. § 116-3, the UNC BOG is able to be sued in “all courts whatsoever.”
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6. UNC-CH is located on a parcel of land in Chapel Hill, North Carolina (“the
University campus”), part of which includes McCorkle Place in the 200 block of East Franklin
Street.
7. Because this action involves conduct and circumstances related to the realty of the
University campus and the affairs of the constituent institutions, the UNC System and the UNC
BOG (collectively, “Defendants”) are proper parties in their positions of authority, control,
governance, dominion, supervision, management, development, administration, direction, and
oversight of the realty of the University campus and the affairs of the constituent institutions and
all conduct and circumstances related to the realty of the University campus and the affairs of the
constituent institutions.
8. Any defense of sovereign immunity that Defendants may have is not applicable to
Plaintiffs monument law, contract, gift, and declaratory judgment actions in this Complaint, and
upon information and belief Defendants have waived sovereign immunity as to those claims.
9. Non-party The United Daughters of the Confederacy - North Carolina Division,
Inc. (“UDC”) is a North Carolina nonprofit corporation organized under the laws of North Carolina
with headquarters in Raleigh, Wake County, North Carolina.
10. UDC’s Articles of Incorporation filed with the North Carolina Secretary of State
provide that UDC was organized for among the following purposes:
[T]o achieve the objectives of the United Daughters of the Confederacy, which
include historical, benevolent, memorial, educational and patriotic programs, plans
events and scholarships by members who are lineal or collateral descendants of
men and women who served the cause of the Confederate States of America. . . .
[These purposes] are exclusively charitable, literary and educational within the
meaning of Section 501(c)(3) of the Internal Revenue Code of 1986 ....
See Exhibit B (Articles of Incorporation, The United Daughters of the Confederacy - North
Carolina Division, Inc. (filed Sept. 16, 1992)).
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JURISDICTION. VENUE. LIMITATIONS. AND STANDING
11. This Court has subject matter jurisdiction over Plaintiff and Defendants pursuant to
N.C. Gen. Stat. §§ 7A-240 and 1-253 et seq. and because the amount in controversy exceeds
$25,000.
12. This Court has personal jurisdiction over Plaintiff and Defendants pursuant to N.C.
Gen. Stat. § 1-75.4. Plaintiff is a North Carolina corporation and Defendants are all North Carolina
entities.
13. For the purposes of this Complaint, “the Confederate Monument” means the
combination of the statue, pedestal, and bronze tablets created and configured by artist John
Wilson in 1913.
14. This Court has in rem jurisdiction over the subject matter of this action, in particular
the Confederate Monument, under N.C. Gen. Stat. § 1-75.9.
15. Venue for this action is proper in Orange County under N.C. Gen. Stat. §§ 1-76(4),
1-79(a), and 1-82.
16. The causes of action pled in this Complaint accrued no earlier than on or about
January 14, 2019, when Defendants did not reannex the Confederate Monument to the realty of
the University campus as described below. As such, all claims are within any relevant statute of
limitations within the North Carolina General Statutes.
17. As described in detail below, on June 2,1913, UDC presented UNC-CH (then “The
University of North Carolina”) with a monument (“the Confederate Monument”) honoring
University students and graduates who served in the Confederate armed forces.
18. Prior to the filing of this Complaint, UDC assigned any and all of its existing legal
and equitable rights, title, and interests in the Confederate Monument, including any and all choses
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in action related to the Confederate Monument, to Plaintiff. See Exhibit C (Memorandum of
Assignment).
19. Because Plaintiff is the current owner of any and all existing legal and equitable
rights, title, and interests in the Confederate Monument, including any and all choses in action
related to the Confederate Monument, Plaintiff has standing to bring this lawsuit.
20. Because Plaintiff is the current owner of any and all existing legal and equitable
rights, title, and interests in the Confederate Monument, including any and all choses in action
related to the Confederate Monument, Plaintiff is a real party in interest in this lawsuit.
FACTUAL BACKGROUND
21. UDC was organized and adopted a Constitution and By-Laws on April 28, 1897.
See Exhibit D (Minutes of Organization, United Daughters of the Confederacy, North Carolina
Division).
22. Upon information and belief, one of UDC’s early aims was to preserve the history
of the Confederate effort in the Civil War, including the accomplishments of women who
supported the Confederate armed forces and the families of Confederate soldiers during the War.
As part of this undertaking, UDC raised money to finance the creation and erection of monuments
throughout North Carolina to honor various Confederate heroes and ideals.
23. At the Eleventh Annual Convention of UDC in October 1907, a resolution was
introduced “that the next work undertaken by [UDC] be the erection, on the campus at the State
University, of a monument to the students and faculty, who went out from its walls in 1861 to fight
and die for the South.” This resolution passed the Convention. See Exhibit E (United Daughters of
the Confederacy, North Carolina Division, Minutes of the Eleventh Annual Convention at 71
(1907)).
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24. In early 1908, a UDC representative wrote to University of North Carolina
President Francis P. Venable on behalf of UDC to suggest that UDC raise funds to erect a
monument for the University campus in Chapel Hill that would honor UNC-CH students who had
served in the Confederate armed forces. In this letter, the UDC representative asked Venable for
permission to place such a monument on the University campus.
25. UDC’s request was presented during the June 1, 1908, meeting of the University of
North Carolina Board of Trustees. The Board of Trustees approved UDC’s request for permission
to erect a monument on the University campus. See Exhibit F (University of North Carolina Board
of Trustees Minutes).
26. On June 9,1908, Venable responded to UDC to offer cooperation with UDC’s plans
to erect a monument on the University campus and to propose a meeting with UDC representatives
to discuss the kind of monument that would be erected. See Exhibit G (letter)
27. UDC named a Chapel Hill Monument Committee to work on the plans for creating
and erecting a monument on the University campus. See Exhibit H (United Daughters of the
Confederacy, North Carolina Division, Minutes of the Twelfth Annual Convention at 73-75
(1908)).
28. On or about March 20, 1909, a UDC representative wrote Venable the following
about plans for the monument: “I hope it will not be many years before it will stand silent & alone,
on our beautiful University grounds, reminding future generations of the sacrifice of those men,
nothing can dim ....” See Exhibit I (letter)
29. Over the next several months, Venable and UDC representatives corresponded
about the plans for the monument. They eventually decided that (1) the Confederate Monument
would be a statue and would be placed on a central location on the University campus, (2) UDC
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would raise the money for the creation and purchase of the monument, and (3) any additional funds
necessary to complete the project would come from private donors. See, e.g., Exhibit J (letter).
30. In an October 5,1909, letter to Venable, a UDC representative wrote the following
about plans for Venable to speak at UDC’s Convention: “I think the Daughters are much pleased
at the idea of your talking to them & I hope you will place before them many reasons why we
should build a handsome monument at our State University to perpetuate our Southern history.”
See Exhibit K (letter).
31. On or about October 14, 1909, Venable spoke at UDC’s Thirteenth Annual
Convention in support of the effort to erect the monument on the University campus. A motion
was made to unveil the monument in 1911, the fiftieth anniversary of when the students and faculty
left the University to join the Confederate armed forces. This motion passed the Convention. See
Exhibit L (United Daughters of the Confederacy, North Carolina Division, Minutes of the
Thirteenth Annual Convention at 65-67 (1909)).
32. Venable and representatives of UDC settled on John Wilson, a renowned sculptor
from Massachusetts who taught art at the Copley Society of Boston and at Harvard University, to
create the monument. See Exhibit M (letter); Exhibit N (Wikipedia biography of John Wilson).
33. UDC members worked to raise funds for the monument into 1910, but it appeared
that they would not be able to raise sufficient funding in time for the monument to be erected in
1911. In August 26, 1910, and September 5, 1910, letters to John Wilson about the work on the
monument, Venable noted that he was acting as the “agent” of the UDC committee and that he
was helping to raise funds from private donors. See Exhibit O (August 26, 1910, letter); Exhibit P
(September 5, 1910, letter).
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34. In August 1910, a UDC representative wrote the following to Venable: “I asked
[John Wilson, the artist] who was to sign the contract. He did not know. I told him none of us
women could do it of course.” See Exhibit Q (letter).
35. On June 19, 1911, Venable wrote the following in response to the August 1910
letter he received:
I have assumed that you would prefer the business end of this to be handled by me,
but it is entirely satisfactory to me if you wish to sign this contract and to have the
payments made by the Treasurer of the U.D.C.... Of course, Mr. Wilson [the
artist] understands that my signing this does not bind the University nor myself
personally.
See Exhibit R (letter).
36. On June 21, 1911, a UDC representative wrote back the following to Venable:
Your letter with the contract for the monument was received last night. Of course I
do not wish to sign it. You are the proper one to do so. . . . [The UDC
representative’s husband] says he prefers for the business end of it to be handled by
you - the money to be collected and turned over to you ....
See Exhibit S (letter).
37. During much of the period of negotiations between UDC and Venable about who
would be responsible for signing the contract, North Carolina law on the doctrine of coverture
provided that married women did not have the right to make contracts in their own name without
being adjudged a “free trader” and being subject to a privy examination. See, e.g., N.C. Revisal of
1905, § 2094 (attached as Exhibit T). This statute was repealed on March 6, 1911. See N.C. Laws
1911, c. 109 (attached as Exhibit U).
38. Over time, UDC and Venable also negotiated other terms related to the monument,
including the cost of the monument and its design. See Exhibit V (letter).
39. On June 29, 1911, the contract for the creation of the monument was signed
between “John Wilson, sculptor of Boston, Massachusetts, of the first part” and
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of the second part,” with a blank space for the name of the other
party to the contract. The contract was signed by John Wilson, Francis P. Venable, Frank S.
Richardson (upon information and belief a witness for John Wilson), and Thos. J. Wilson, Jr. (upon
information and belief Registrar for the University). See Exhibit W (contract).
40. The contract for the monument called for the sculpting of a bronze figure (“the
statue”), representative of a Confederate soldier, to be placed on top of a granite pedestal (“the
pedestal”) with bronze tablets that displayed information about the monument, the University
students who served in the Confederate armed forces, and UDC’s involvement in the creation of
the monument.
41. UDC members continued to raise money for the monument in 1912 and 1913 with
the aid of private donors solicited by Venable and others connected to UNC-CH. Plans were made
for the monument to be completed during the Spring of 1913. Venable and UDC agreed that the
monument would be unveiled during the commencement ceremonies in June 1913. See Exhibit X
(letter).
42. At the June 2, 1913, commencement ceremonies, Mrs. H.A. London, chair of
UDC’s Chapel Hill Monument Committee, presented the Confederate Monument to the University
and made the following remarks:
As Chairman of the Monument Committee of [UDC] I have the honor, and it gives me
much pleasure, to present in their name to the trustees of the University of North Carolina
this monument which is erected in memory of those students of this University who served
in the [Confederate armed forces]. . . . We have erected this monument not only in honor
of the dead but also of the living. ... Accept this monument and may it standforever as a
perpetual memorial to those sons of the University who suffered and sacrificed so much at
the call of duty.
See Exhibit Y (remarks) (emphasis added).
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43. In accepting the Confederate Monument on behalf of the University, Venable made
the following remarks:
[N]ow in commemoration of a great era and of a noble ideal there has been erected
on [the] campus this beautiful monument. ... It was to that patriotic organization,
[UDC], that the gracious thought first came of erecting this monument to the sons
of the University that entered the War. Four years ago [UDC] asked permission of
the Trustees to place the monument upon the campus, which was gladly granted
them.... In the name of the University and with an abiding gratitude I accept the
gracious gift of this monument, embodying as it does grateful memory for the past
and high hope for the future.
See Exhibit Z (emphasis added).
44. The Confederate Monument installed on the University campus included the statue
of the soldier, the granite pedestal, and the bronze tablets as described above. When installed, the
Confederate Monument was annexed to the realty of the University campus at McCorkle Place.
45. On or about October 9, 1913, Mrs. London provided a report to the Seventeenth
Annual Convention of UDC on behalf of the Chapel Hill Monument Committee about the
installation proceedings at the June 1913 University commencement. In her report, Mrs. London
made the following remarks:
The Chapel Hill Monument was unveiled during the last commencement at the
University. It is very beautiful. It is not only in memory of the boys who left the
University from 1861 to 1865, but also those who attended the University and
afterwards became Confederate soldiers. ... Dr. Venable and others have worked
unceasingly for it and now it stands there for all time and it will be an object lesson
to all future generations - and will impress upon the present day students their
obligation to respond to the call of duty.
See Exhibit AA (United Daughters of the Confederacy, North Carolina Division, Minutes of the
Seventeenth Annual Convention at 50-51 (1913)).
46. Upon information and belief, beginning no later than the 1960s, there were various
protests about the history of the Confederate Monument and its place on the University campus.
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These protests intensified in 2017 and 2018, with several large rallies against the Confederate
Monument and numerous incidents of vandalism. See, e.g.. Exhibit BB (article).
47. Upon information and belief, on or about the night of August 20, 2018, over 250
people protested at the site of the Confederate Monument. During this protest, a group of protestors
rigged ropes to the Confederate Monument and pulled the statue off of the Confederate
Monument’s pedestal. Upon information and belief, Defendants or their representatives, including
representatives of UNC-CH, were present at the time that people pulled the statue off of the
pedestal of the Confederate Monument. See Exhibit CC (article).
48. Upon information and belief, both the statue and the pedestal of the Confederate
Monument were damaged when protestors pulled the statue off of the Confederate Monument’s
pedestal.
49. Neither Defendants nor their representatives reinstalled the statue on the pedestal
of the Confederate Monument.
50. Upon information and belief, on or about August 20, 2018, Defendants or their
representatives, including representatives of UNC-CH, loaded the statue portion of the
Confederate Monument onto a truck and took it to an undisclosed location.
51. On or about January 14, 2019, then-UNC-CH Chancellor Carol Folt ordered that
the pedestal on which the statue portion of the Confederate Monument was mounted was to be
removed from the University campus. See Exhibit DD (article).
52. On or about the evening of January 14, 2019, Defendants or their representatives,
including representatives of UNC-CH, severed the pedestal of the Confederate Monument from
the realty of the University campus, removed the pedestal of the Confederate Monument from the
University campus, and took the pedestal of the Confederate Monument to an undisclosed location.
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53. Upon information and belief, Defendants or their representatives, including
representatives of UNC-CH, used drills, forklifts, and other industrial equipment to sever the
pedestal of the Confederate Monument from the realty of the University campus, thereby
damaging the Confederate Monument further in the process.
54. On or about August 22, 2018, then-UDC President Peggy W. Johnson wrote the
following email to Haywood Cochrane, then-Chair of the UNC-CH Board of Trustees, about the
Confederate Monument:
I, as a representative of the United Daughters of the Confederacy, request that the Boy
Soldier, [referred] to as Silent Sam, be returned to the United Daughters of the
Confederacy. We are willing to take possession of both the base and the sculpture. We have
been saddened that the message of this monument [has] been so misconstrued. He no longer
belongs on the campus of UNC Chapel Hill.
See Exhibit EE (email).
55. Defendants or their representatives have not returned the Confederate Monument
to UDC.
56. Upon information and belief, Defendants or their representatives are currently
storing the Confederate Monument on public property under the dominion or supervision of
Defendants or their representatives.
FIRST CLAIM FOR RELIEF

(Declaratory Judgment - Monument Law)
57. The allegations in each of the Paragraphs in this Complaint are realleged and
incorporated by reference as if fully set forth herein.
58. This action is brought pursuant to the North Carolina Declaratory Judgments Act,
N.C. Gen. Stat., Ch. 1, Art. 26.
59. An actual justiciable controversy exists between the parties.
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60. Chapter 100 of the North Carolina General Statutes governs all activities related to
“Monuments, Memorials, and Parks,” including any “object of remembrance,” which is defined
in N.C. Gen. Stat. § 100-2.1 as “a monument, memorial, plaque, statue, marker, or display of a
permanent character that commemorates an event, a person, or military service that is part of North
Carolina’s history.”
61. The Confederate Monument qualifies as an “object of remembrance” under N.C.
Gen. Stat. § 100-2.1.
62. Except as provided in Chapter 100, “a monument, memorial, or work of art owned
by the State may not be removed, relocated, or altered in any way without the approval of the
North Carolina Historical Commission.”
63. Under N.C. Gen. Stat. § 100-2.1, an “object of remembrance” located on “public
property” may not be permanently removed from that property and may only be relocated under
very limited conditions.
64. McCorkle Place on the University campus is property owned and controlled by
Defendants and as such is “public property” under North Carolina law.
65. An “object of remembrance” that is temporarily relocated must be returned to its
original location within ninety days of the completion of the project that required its temporary
removal.
66. An “object of remembrance” that is permanently relocated may only be relocated
to a site of “similar prominence, honor, visibility, availability, and access that are within the
boundaries of the jurisdiction from which it was relocated” and may not be relocated to a museum,
cemetery, or mausoleum unless it was originally placed at such a location.
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67. An “object of remembrance” may be relocated only in the following circumstances:
(a) when appropriate measures are required by the State or a political subdivision of the State to
preserve the object of remembrance, or (b) when necessary for construction and related efforts for
buildings, open spaces, parking, or transportation projects.
68. The Confederate Monument was not returned to its original location on McCorkle
Place on the UNC-CH campus within 90 days.
69. Upon information and belief, the Confederate Monument has not been relocated to
a site of “similar prominence, honor, visibility, availability, and access that are within the
boundaries of the jurisdiction from which it was relocated.”
70. The Confederate Monument was not relocated due to appropriate measures being
required by the State, a political subdivision of the State, or Defendants to preserve the Confederate
Monument.
71. The Confederate Monument was not relocated due to it being necessary for
Defendants to do so for construction, renovation, reconfiguration of buildings, open spaces,
parking, or transportation projects.
72. The North Carolina Historical Commission has not approved the removal,
relocation, or alteration of the Confederate Monument from the site of its annexation to McCorkle
Place on the University campus.
73. Based on the assignment agreement between UDC and Plaintiff, Plaintiff is the
current owner of any and all existing legal and equitable rights, title, and interests in the
Confederate Monument, including any and all choses in action related to the Confederate
Monument.
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74. Because Defendants’ actions with respect to the Confederate Monument after
Defendants did not reannex the Confederate Monument to the realty of the University campus on
or about January 14, 2019, have not complied with the provisions of Chapter 100 of the North
Carolina General Statutes, Plaintiff (as owner of any and all existing legal and equitable rights,
title, and interests in the Confederate Monument, including any and all choses in action related to
the Confederate Monument) is entitled an order of the Court declaring the rights and liabilities of
the parties, in particular that Chapter 100 of the North Carolina General Statutes mandates that the
Confederate Monument shall be returned its original location.
75. Based on N.C. Gen. Stat. § 100-2.1, this Court should enter an order requiring that
the Confederate Monument be returned to its original location and that Defendants reannex the
Confederate Monument to the realty at McCorkle Place on the University campus.
SECOND CLAIM FOR RELIEF

(Declaratory Judgment - Contract)
79. The writings back and forth between representatives of UDC and Venable in his
capacity as the President of UNC-CH constitute a meeting of the minds about (1) the conditions
under which UDC would raise funds for the erection of the Confederate Monument on the
University campus, (2) the conditions under which UNC-CH would allow UDC to annex the
Confederate Monument to the realty of the University campus, and (3) that the Confederate
Monument would remain annexed to the realty of the University campus forever.
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80. The consideration UNC-CH gave UDC in exchange for the Confederate Monument
was the use and enjoyment of a portion of the realty of the University campus on which to annex
the Confederate Monument.
81. The consideration UDC gave UNC-CH in exchange for the ability to annex the
Confederate Monument to the realty of the University campus was the money it raised, and
expended, to fund the creation and purchase of the Confederate Monument and the presentation of
the Confederate Monument to UNC-CH.
82. As such, the writings back and forth between representatives of UDC and Venable
in his capacity as'the President of UNC-CH constitute a binding contract under North Carolina
law.
Monument.
84. As owner of any and all existing legal and equitable rights, title, and interests in the
Monument, Plaintiff is entitled to an order of the Court declaring the rights and liabilities of the
parties, in particular that the writings back and forth between representatives of UDC and Venable
in his capacity as the President of UNC-CH constitute a valid and binding contract under North
Carolina law.
85. In the alternative, Mrs. London’s public statement at the June 1913 commencement
presenting the Confederate Monument to the University - “Accept this monument and may it stand
forever as a perpetual memorial” - and Venable’s public acceptance of the Confederate Monument
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after Mrs. London’s statement constituted a parol modification of the written contract entered into
between UDC and UNC-CH.
86. As owner of any and all existing legal and equitable rights, title, and interests in the
Monument, Plaintiff is entitled to an order of the Court declaring the rights and liabilities of the
parties, in particular that the writings back and forth between representatives of UDC and Venable
in his capacity as the President of UNC-CH constitute a valid and binding contract under North
Carolina law about the annexation of the Confederate Monument on the realty of the University
campus at McCorkle Place and that the public statements of Mrs. London and Venable about the
Confederate Monument at the June 1913 commencement were a parol modification of that written
agreement.
THIRD CLAIM FOR RELIEF

(Breach of Contract)
88. The writings back and forth between representatives of UDC and Venable in his
capacity as the President of UNC-CH constitute a binding contract under North Carolina law.
89. This contract between UDC and Venable on behalf of UNC-CH provided that
(1) UDC would raise money to fund a monument honoring University students who had served in
the Confederate armed forces, (2) Venable would act as UDC’s agent in raising funds for the
Confederate Monument from private donors, and (3) UNC-CH would annex the Confederate
Monument to the realty of the University campus to remain there “forever.”
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90. The consideration UNC-CH gave UDC in exchange for the Confederate Monument
was the use and enjoyment of a portion of the realty of the University campus on which to annex
the Confederate Monument.
91. The consideration UDC gave UNC-CH in exchange for the ability to annex the
Confederate Monument to the realty of the University campus was the money it raised, and
expended, to fund the creation and purchase of the Confederate Monument and the presentation of
the Confederate Monument to UNC-CH.
92. At the time that the Confederate Monument was annexed to the realty of the
University campus at McCorkle Place, it was the intent of both UDC and UNC-CH that the
Confederate Monument would remain annexed to the realty of the University campus in
perpetuity.
93. The annexation of the Confederate Monument on the realty of the University
campus on the UNC-CH campus and its remaining on the UNC-CH campus in perpetuity were
material terms of the contract between UDC and UNC-CH.
94. The statue portion of the Confederate Monument was removed from the UNC-CH
campus on August 20, 2018, and the pedestal portion of the Confederate Monument was removed
from the UNC-CH Campus on January 14, 2019.
95. The removal of the Confederate Monument from the UNC-CH campus was a
breach of a material term of the contract between UDC and UNC-CH.
96. Defendants’ breach of the contract is ongoing.
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Monument.
98. Plaintiff is entitled to enforce the terms of the contract between UDC and UNC-CH,
and to bring this action against Defendants for breach of the contract.
99. As a direct and proximate result of Defendants’ actions in breach of the contract,
Plaintiff has suffered certain damages, including monetary damages in excess of $25,000.
FOURTH CLAIM FOR RELIEF

(Specific Performance)
Monument.
102. Based on the valid and binding contract between UDC and UNC-CH, Plaintiff is
entitled to specific performance by Defendants of the contractual provision that the Confederate
Monument be annexed to the realty of the University campus.
103. Based on the material terms of the contract between UDC and UNC-CH, this Court
should enter an order requiring specific performance of Defendants to reannex the Confederate
Monument to the realty of the University campus.
FIFTH CLAIM FOR RELIEF

(Declaratory Judgment - Conditional Gift)
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107. When the Confederate Monument was annexed to the realty of the University
campus at McCorkle Place, it became a fixture, and thereby part of the realty, under North Carolina
law.
108. When UDC presented the Confederate Monument to UNC-CH, it intended to
present the Confederate Monument and did present the Confederate Monument under the
condition that the Confederate Monument be annexed to the University campus “forever.”
109. The condition that the Confederate Monument remain annexed to the realty of the
University campus “forever” was an express material condition subsequent of the gift.
110. UDC’s presentation of the Confederate Monument to UNC-CH was a conditional
gift under North Carolina law.
111. UNC-CH accepted the Confederate Monument as a gift from UDC subject to the
express material condition subsequent that the Confederate Monument remain annexed to the
realty of the University campus “forever.”
112. When UDC presented the Confederate Monument to UNC-CH as a conditional gift,
any and all legal and equitable rights, title, and interests in the Confederate Monument, including
any and all choses in action related to the Confederate Monument, transferred to UNC-CH subject
to the express material condition subsequent.
113. When Defendants did not reannex the Confederate Monument to the realty of the
University campus on or about January 14, 2019, Defendants intended that the Confederate
20
Monument be independent from the realty of the University campus permanently, and the
Confederate Monument then reverted to personal property under North Carolina law.
114. When Defendants did not reannex the Confederate Monument to the realty of the
University campus on or about January 14, 2019, the condition upon which UDC presented the
Confederate Monument to UNC-CH failed, and any and all legal and equitable rights, title, and
interests in the Confederate Monument, including any and all choses in action related to the
Confederate Monument, reverted to UDC.
115. UDC’s conditional gift of the Confederate Monument to UNC-CH and the
reversion of any and all legal and equitable rights, title, and interests in the Confederate Monument,
including any and all choses in action related to the Confederate Monument, to UDC did not violate
the common law rule against perpetuities. North Carolina law provides that reversionary interests,
as future interests retained by grantors, are considered vested at the time of the grant and are not
subject to the common law rule against perpetuities.
116. UDC’s conditional gift of the Confederate Monument to UNC-CH and the
reversion of any and all legal and equitable rights, title, and interests in the Confederate Monument,
including any and all choses in action related to the Confederate Monument, to UDC did not violate
the North Carolina uniform statutory rule against perpetuities. N.C. Gen. Stat. § 41-18 provides
that the uniform statutory rule does not apply to nonvested property interests held by a charity in
the event that the nonvested property interest is preceded by an interest held by a governmental
agency or subdivision of the government.
117. N.C. Gen. Stat. § 36C-4-405 also provides that no gift shall be invalidated by the
rule against perpetuities.
21
118. As Defendants have breached the express material condition subsequent of the gift,
Plaintiff (as owner of any and all legal and equitable rights, title, and interests in the Confederate
Monument, including any and all choses in action related to the Confederate Monument) is entitled
to have possession of the Confederate Monument awarded to it.
119. As the owner of any and all legal and equitable rights, title, and interests in the
Monument, Plaintiff can enforce the express and material condition subsequent of the gift.
120. Plaintiff is entitled an order of the Court declaring the rights and liabilities of the
parties, in particular that Plaintiff holds any and all legal and equitable rights, title, and interests in
the personal property of the Confederate Monument, including any and all choses in action related
to the Confederate Monument.
SIXTH CLAIM FOR RELIEF

(Quiet Title)
Monument.
123. Plaintiff is entitled to an order of the Court quieting title to the Confederate
Monument in favor of Plaintiff and against Defendants so as to free the property from the cloud
resting upon it and adjudging Plaintiff to be the owner of any and all legal or equitable rights, title,
and interests in the Confederate Monument, including any and all choses in action related to the
Confederate Monument.
22
SEVENTH CLAIM FOR RELIEF
(Trespass to Chattel)
125. On or about August 22, 2018, UDC asked Defendants to return the Confederate
Monument to it, but Defendants did not return the Confederate Monument to UDC.
126. At the time that Defendants did not reannex the Confederate Monument to the
realty of the University campus on or about January 14,2019, the Confederate Monument reverted
to personal property and was a chattel under the law of North Carolina.
127. At the time that Defendants did not reannex the Confederate Monument to the realty
of the University campus on or about January 14,2019, any and all legal and equitable rights, title,
of the University campus on or about January 14, 2019, UDC had the right to take possession of
the Confederate Monument whenever it desired, and therefore had constructive and virtual
possession of the Confederate Monument.
of the University campus on or about January 14, 2019, Defendants interfered with UDC’s
possession of the Confederate Monument without justification, authority, or lawful excuse.
130. Defendants continue to engage in the unauthorized and unlawful interference with
Plaintiffs possession of the Confederate Monument and the dispossession of the Confederate
Monument from Plaintiff (in Plaintiffs capacity as the owner of any and all rights, title, and
23
Confederate Monument) without justification, authority, or lawful excuse.
current owner of any and all existing legal and equitable rights, title, and interests in The
Monument.
132. As a direct and proximate result of Defendants’ actions in trespassing against
Plaintiffs legal and equitable rights, title, and interests in the Confederate Monument, Plaintiff has
suffered certain damages, including monetary damages in excess of $25,000.
EIGHTH CLAIM FOR RELIEF

(Conversion)
134. When Defendants or their representatives did not reannex the Confederate
Monument to the realty of the University campus on or about January 14, 2019, the Confederate
Monument reverted to personal property and any and all legal and equitable rights, title, and
135. Defendants or their representatives took possession of the Confederate Monument
after Defendants did not reannex the Confederate Monument to the realty of the University
campus.
136. On or about August 22, 2018, UDC asked Defendants or their representatives to
return the Confederate Monument to UDC.
24
137. Defendants or their representatives did not return the Confederate Monument to
UDC.
138. The actions of Defendants or their representatives in retaining possession of the
Confederate Monument constitute an unauthorized exercise of the rights, title, and interests of
ownership over personal property that rightfully belongs to Plaintiff (as the owner of any and all
legal and equitable rights, title, and interests in the Confederate Monument, including any and all
choses in action related to the Confederate Monument).
139. The actions of Defendants or their representatives in wrongfully retaining
possession, dominion, and control of the Confederate Monument were and are intentional, willful,
wanton, and show a reckless disregard of the legal and equitable ownership rights, title, and
interests belonging to Plaintiff.
Monument.
141. Asa direct and proximate result of the actions of Defendants or their representatives
in converting the Confederate Monument, Plaintiff has suffered certain damages, including
monetary damages in excess of $25,000.
NINTH CLAIM FOR RELIEF

(Replevin/Claim and Delivery)
25
Monument.
144. As the owner of any and all legal and equitable rights, title, and interests in the
Monument, and the constructive possessor of the Confederate Monument, Plaintiff is entitled to
actual possession of the Confederate Monument.
145. UDC, the predecessor-in-interest to Plaintiff for the purposes of ownership in and
rights, title, and interests in the Confederate Monument, requested on August 22, 2018, that
Defendants or their representatives return the Confederate Monument to UDC.
UDC.
147. Defendants or their representatives continue to withhold possession of the
Confederate Monument from Plaintiff (the owner of any and all legal and equitable rights, title,
Confederate Monument) intentionally, willfully, wrongfully, and unlawfully.
148. Plaintiff is entitled to recover possession of the Confederate Monument from
Defendants or their representatives.
149. Plaintiff is entitled to a judgment against Defendants directing delivery of the
Confederate Monument from Defendants to Plaintiff.
TENTH CLAIM FOR RELIEF

(Quasi-Contract/Unjust Enrichment)
26
151. UDC conferred a benefit onto Defendants through the conditional gift of the
152. Defendants accepted the conditional gift of the Confederate Monument from UDC.
153. Once Defendants or their representatives did not reannex the Confederate
Monument to the realty of the University campus on or about January 14, 2019, the Confederate
Monument reverted to personal property of which UDC possessed any and all legal and equitable
rights, title, and interests, including any and all choses in action related to the Confederate
Monument.
UDC after Defendants did not reannex the Confederate Monument to the realty of the University
campus.
155. By retaining the Confederate Monument after the legal and equitable rights, title,
Confederate Monument, reverted to UDC. After having not returned the Confederate Monument
to UDC after UDC asked for its return, Defendants have been enriched at UDC’s expense under
circumstances that, in equity and good conscience, call for an accounting by Defendants.
Monument.
157. Asa direct and proximate result of the actions of Defendants or their representatives
in retaining the Confederate Monument and being unjustly enriched, Plaintiff (as owner of the
legal and equitable rights, title, and interests in the Confederate Monument, including any and all
27
choses in action related to the Confederate Monument) has suffered certain damages, including
monetary damages in excess of $25,000.
ELEVENTH CLAIM FOR RELIEF

(Constructive Trust)
159. Defendants have been unjustly enriched by taking possession of the Confederate
Monument after the legal and equitable rights, title, and interests in it reverted to UDC and by
refusing to return the Confederate Monument to UDC.
Monument.
161. Because of the unique nature of the Confederate Monument, Plaintiffs claim in
this regard cannot adequately be satisfied by an award of money damages.
162. As owner of any and all legal and equitable rights, title, and interests in the
Monument, Plaintiff is entitled to an order of the Court imposing a constructive trust on the
Confederate Monument for the benefit of Plaintiff to secure Plaintiffs right of possession of the
TWELFTH CLAIM FOR RELIEF

(Negligence/Damage to Property)
28
164. During a time when Defendants or their representatives had possession, dominion,
and control of the Confederate monument, the Confederate monument was damaged.
165. At the time that Defendants or their representatives did not reannex the Confederate
Monument to the realty of the University campus, Defendants or their representatives had
possession, dominion, and control of the Confederate Monument.
166. Upon information and belief, on or about January 14, 2019, Defendants or their
representatives damaged the Confederate Monument in the course of handling or securing the
167. Upon information and belief, the failure of Defendants or their representatives to
use ordinary care in handling or securing the Confederate Monument was a concurrent cause of
the damage to the Confederate Monument.
168. Upon information and belief, the failure of Defendants or their representatives to
use ordinary care in handling or securing the Confederate Monument was a proximate cause of the
damage to the Confederate Monument.
169. The negligence of Defendants or their representatives resulting in the damage to
the Confederate Monument is not insulated from the intentional torts and/or negligence of others.
Monument.
171. As a direct and proximate result of the negligence of Defendants or their
representatives with respect to their handling and securing of the Confederate Monument, Plaintiff
has suffered certain damages, including the diminution in value of the Confederate Monument and
29
the costs of repairing damages to the Confederate Monument, including monetary damages in
excess of $25,000.
THIRTEENTH CLAIM FOR RELIEF

(Injunction)
173. Equitable relief such as an injunction is appropriate when an award of money
damages will not make the plaintiff whole.
174. The Confederate Monument is a unique and historical creation that is over 100
years old and is protected by Chapter 100 of the North Carolina General Statutes.
Monument.
176. Because the Confederate Monument is a unique and historical creation protected
by law, Plaintiff has no adequate remedy at law if the Court does not grant injunctive relief
compelling Defendants to reannex the Confederate Monument on the realty in the location where
it was originally installed on the University campus.
177. Defendants’ breach of the contract between UDC and Defendants and failure to
reannex the Confederate Monument in its original location on the realty of the University campus
in accordance with N.C. Gen. Stat. § 100-2.1 entitles Plaintiff to a permanent and mandatory
injunction ordering and compelling Defendants to reannex the Confederate Monument on the
realty of the University campus at McCorkle Place, the location where it was originally installed
on the University campus.
30
178. In the alternative, because the Confederate Monument is a unique and historical
creation protected by law, Plaintiff has no adequate remedy at law if the Court does not grant
injunctive relief compelling Defendants to deliver the Confederate Monument to Plaintiff.
179. In the alternative, Defendants’ conduct resulting in the failure of the condition
subsequent of the gift UDC presented to Defendants, Defendants’ ongoing and continuing trespass
against Plaintiffs legal and equitable rights, title, and interests in the Confederate Monument, and
Defendants’ conversion of the Confederate Monument, entitle Plaintiff to a permanent and
mandatory injunction ordering and compelling Defendants to deliver the Confederate Monument
to Plaintiff in its capacity as the holder of any and all legal and equitable rights, title, and interests
in the Confederate Monument, including any and all choses in action related to the Confederate
Monument.
WHEREFORE, based on the foregoing, Plaintiff prays to the Court and requests the
following relief:
A. A declaration and order of the Court that Chapter 100 of the North Carolina General
Statutes mandates that the Confederate Monument shall be returned to its original location and that
Defendants reannex the Confederate Monument to the realty at McCorkle Place on the University
campus; and
B. A declaration and order of the Court that UDC and UNC-CH formed a valid
contract about the placement of the Confederate Monument on the realty of the University campus,
or that Mrs. London’s statement “Accept this monument and may it stand forever as a perpetual
memorial” was a parol modification of the valid contract that UDC and UNC-CH had entered into
about the Confederate Monument, and that Plaintiff may enforce that contract in its capacity as the
31
Confederate Monument previously owned by UDC, including any and all choses in action related
to the Confederate Monument previously owned by UDC; and
C. A judgment of specific performance ordering Defendants to replace the
Confederate Monument on the realty of the University campus; and
D. A permanent and mandatory injunction ordering Defendants to replace the
Confederate Monument on the realty of the University campus at McCorkle Place; and
E. In the alternative, a declaration and order of the Court that UDC’s presentation of
the Confederate Monument to UNC-CH was a conditional gift with the express material condition
subsequent that the Confederate Monument be annexed to the realty of the University campus
“forever,” and that the actions of Defendants in failing to reannex the Confederate Monument to
the realty of the University campus on or about January 14, 2019, resulted in any and all rights,
title, and interests in the Confederate Monument reverting to UDC, and that Plaintiff is the current
owner of any and all existing legal and equitable rights, title, and interests in the Confederate
Monument previously owned by UDC, including any and all choses in action related to the
Confederate Monument previously owned by UDC; and
F. In the alternative, a judgment directing delivery of the Confederate Monument to
Plaintiff, the owner of any and all legal and equitable rights, title, and interests in the Confederate
Monument, including any and all choses in action related to the Confederate Monument; and
G. In the alternative, a judgment quieting the title to the Confederate Monument in
favor of Plaintiff and against all Defendants so as to free the Confederate Monument from the
cloud resting upon it and to render Plaintiffs title to the Confederate Monument clear and
undisputable; and
32
H. In the alternative, a permanent and mandatory injunction ordering the delivery of
the Confederate Monument to Plaintiff, the owner of any and all legal and equitable rights, title,
Confederate Monument; and
I. In the alternative, the imposition of a constructive trust on the Confederate
Monument for the benefit of Plaintiff to secure Plaintiffs right of possession of the Confederate
Monument; and
J. The recovery of actual damages from Defendants, jointly and severally, in an
amount sufficient to compensate for damage to the Confederate Monument resulting from
Defendants’ conduct and other injury to Plaintiff; and
K. The recovery of costs and expenses incurred in this action, including an award of
attorneys’ fees, to be taxed jointly and severally against all Defendants; and
L. A trial by jury of all issues so triable; and
M. An award of any other and further relief as may be just and proper.
This, the AT- day of

No v s Îl u .,2019.
DAVIS, STURGES & TOMLINSON, PLLC
cWf
Attorneys at Law „
C. Boyd Sturges iff, N.C. Bar No. 22342

101 Church Street
P.O. Drawer 708
Louisburg, North Carolina 27549
Phone: 919-496-2137
Email: bsturges@dstattvs.com
Attorney for North Carolina Division Sons of

Confederate Veterans, Inc., a North Carolina
corporation
33
STATE OF NORTH CAROLINA IN THE GENERAL COURT OF JUSTICE
COUNTY OF ORANGE SUPERIOR COURT DIVISION
File No. 19CVS
NORTH CAROLINA DIVISION SONS OF )

CONFEDERATE VETERANS, INC., a )
North Carolina corporation )
)
Plaintiff, )
)
v. ) VERIFICATION
)
THE UNIVERSITY OF NORTH )
CAROLINA and THE UNIVERSITY OF )
NORTH CAROLINA BOARD OF )
GOVERNORS, )
)
Defendants. )
I, Kevin Stone, depose and say that I have read the foregoing Verified Complaint; that I
have the power and authority to sign this Verified Complaint on behalf of Plaintiff; that I declare
that the contents thereof are true of my own personal knowledge; and that I declare that, as to
matters about which I have no personal knowledge, I believe them to be true based on my review
of the attached documents and other matters of record.
(Signature follows on next page)
34
Kevin Stone
Division Commander
North Carolina Division Sons of Confederate
Veterans, Inc.
cowfHO Q>°'io in?; £>

I, , a Notary Public for said County and State, do hereby
certify that _______ personally appeared before me this day and
acknowledged the due execution of the foregoing instrument.
^ day of
Witness my hand and official seal, this, the ,2019.
Ct^>
(Official Seal) Notar^J Public
My commission expires
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A
EXHIBIT A
TIGL.ES OF INCORPORATION
OF
Sana Veterans, Inc.
W«M of Corporation)
A NON-PROFIT CORPORATION
We> the undersigned natural parsons of the tge of twenty-one years or mna acth g os
Incorporators for the purpose of cnstlog a non-profit corporation under the laws of the 8fa ,te of
North Hu HIu p . aa contained In Chapter SBA. of the General Statutes of North Carolina, oi titled
"Non-Profit Corporation Act", and the several amendments thereto, do hereby set forth:
1. The nemo of the corporation la_HQJdJt).Qara}Jjri&J&^ iXatoxana,!*
2. The period of duration of the corporation shall be__.patpohnl———
T» anoestsv. W » oultlv*.
pa.peUBta and sanctify the ties of fraternity and frienddiip entailed thontoy; to aid
and encourage the history and achievement ffon Auuestxwn to this present en i, constantly
endeavoring to see that the ovents of the Mar Betmen the States and the he do
contributions of the confederate soldiara of Indian Dsnltoty an authentic illy and
clearly written, and that all doaroents, ralics and mementoes produced and ' landed down b;
those active participants therein are properly treasured and preserved for posterity; to
aid and assist in thetrectlcn of suitable and enduring monuments and man to all
Southern valor, civil and military, wherever done and wherever found; to
into our descendants a devotion to and reverenoa for the principles repr fay
the Confederate States of Amrico, to the honor, glory and memory of our fitters
who fought in that cause.
i The corporation is to have the following; class or classes of members: (If thera < ra to bo
no members, so state.)
Nano
6. Directors of tha corporation shall ho elected in the following manner: Director 9 and
Officers to be elected annually in accordance with the By-laws of this organisation.
0. The address of the initial registered office of the corporation is as-follows:
Street address. (If none, so state) Pofet Offico Beat 1927IT - A-PJC&KP
3?r.-
City or town Rnlfdqta.
County---- Moles-------------------------- —----- —.----------------- ——----J-------- —
The nemo of the Initial registered agent of the corporation at the above address Is-----------
_________Rgoqp-Rgaîe*JOiviaiqii3rM^ __________________________________
Exhibits -1
7. Ths number of directors coMtftutfng ths Initial board of directors shall to four. MX—
and the namee and addresses (Indadimr street and number, if any) of the persona who are to serve
as directors until the first meeting of the eerpoxatlon or until their successors ate elected and
qualified are:
NAME STKRIT ADD BBSS orrr cm t o w n
P.Q- Bene 19271 _______________________________

____13aiLJBfMalevLBQa4____ __________
--imnny Moogy,___ *m Q^B£S&-2§S __________ gtiqtray VBrlna, N.C,
---------- b ntpimtjaaaf_________ AEdena GUCfu
8. The names and addressee (Including street and number. If any) of all the Incorporators are:
NAME STREET ADDRESS CITY OB TOWN
<If none, so state) .
TVuw*.
Pft 1W> lOOTl ... Rftlfiiabr- ______
---- Loulaburg, N.C.
____________________
0. In addition to the powers granted corporations under the laws at the State of North Caro
lina, the corporation shall have full power and authority to
None except allowed by the Um s of the state of North. Carolina and as
aothidixed the' fiy-LUra of tfilff organization not Inconsistent v±th the laws
of the State of North Carolina,
lo. * The Internal affair© of this non profit corporation shall bo

governed by the By-Laws of this organisation duly adopted and ratified as
act forth in the By-Utue of the North Carolina Division Sons of Confederate
veterans. See attachment "Rider to Articles of Incorporation of North Carolina
Division Sons of Confederate Veterans, Xnc.
Exhibits - 2
4
IN TESTIMONY WHEREOF, m have hereunto act our hands, this the_____ 20th-. day
----- , AJD. 1968__
COUNTY OF BTMfcUn-----------
This is to certify thst on the__ Qftfh day at ____ ------- - AJD. 1*9.. befon
me, a_____Notary ftiKI ^ ------ personally appeared
Byron E. Brady and larzy E. Nbxnsn
who, I am satisfied, are the persons named In and who executed the foregotas Article of Incorpo
ration, and 1 havtaff first mads known to thorn the contents thereof, they did each acknowledge
that they signed and delivered the same as their voluntary set and deed for the uses and purposes
therein expressed.
In Testimony Whereof, I have hereunto set my hand and official seal, this the __ day
of-----aSlfeJ________ , A.l>. 19JB8-. _ s'? /y
(LS.)
9S : 4*. X/-9J
■MM, nuMlMl lo N Mi t—A la tt, Vv •,«, «, In CkMMr WA of On 0,001,1 fttBiln
Exhibits - 3
FXDER T
o ARTICLE OF INCORPORATION CF NQKXH CAROLINA DIVISION SONS CF
OQNFBSBHIB VEEESttMS, INC.
lO*
Said corporati on i
s organised excl usively f or charitable(
reli
giooB, •dneati oaal, and scient if
ic porpom , i ncl udi
ng, f ar
snob purposes, the Baking of di stri
butions to organi sations tbat
qual i
fy as «nw m pt-organisations under section 501 (o) (3) of the
internalR evenue C ode of 1954 (or the oorrespondlng provi sion of
any future united States i nternalR evenue Law ) .
H o part of the net earni ngs of the corporati on shal li nure to
the benefi t of, or be distributabl e to its anbers, trustees, of ficers,
or other pri vate persons, except that the corporati on shal lbe
authori sed and em pow ered to pay reasonable com pensation f or servi ces
rendered and to m ake paym ents and di stri
buti ons i n furtherance of the
purposes set forth i n A rti
cle Thi rd hereof, h o substanti alpart of
the act ivi ti
es of the corporati on shal lbe the carryi ng on of propaganda,
or otherw ise attem pti ng to influence l egi slati
on, and the corporati on
shal lnot parti ci
pate i n or intervene i n (i ncluding the publ i
shi ng or
di stri
but i
on of statem ents) any pol i
ticalcam paign on behal f of any
candidate f or public office, notw i thstandi ng any other provi sion of
these art icl es, the corporation shal lnot carry cm any other act ivi
ties
not perm i tted to be carried on (a) by a corporati on exem pt: from Fedora1
incocao tax under secti on 501 (c)(3) of the i nternalR evenue code of
1954 (or the corresponding provi sion of any future uni ted states
internalR evenue Law ) or (b) toy a corporat ion, contributions to
w hich are deducti ble under secti on 170(e) (2) of the internal R evenue
C ode of 1954 (or the corresponding provi sion of any future uni ted
States i nternal R evenue Law ).
U pon the di ssol ution of the corporati on, the Board ofTrustees
shal l
, af t
er paying or m aking provi sion f or the paym ent of al lof the
liabilities of the corporati on, dispose of al lof the assets of the
corporati on excl usivel y for the purposes of the corporati on in.such
m anner, or t o such organi sation or organi sations organised and
operated excl usivelyf or ahari tahle, educati onal , rel i
gious, or
sci ent if
ic purposes as shal l at the tim e qual ify as an em apt
organi sation or organi sations under secti on 501 (c) (3) of the
internalR evenue C ode <Sf 1954 (or the corresponding provi sion of
: any future uni ted States i nternalR evenue Law ), as the Board of
Trustees shal ldeterm i ne. Any such assets not so disposed of shal l
ho disposed of toy the court of com m on pleas of the county In w hich
the pri nci palof fi
ce of the corporat ion i s than l ocated, excl usively
for such purposes or to suoh organi sati on or organi sations, as sai d
court shal ldeterm i
ne, w hich are organised and operated excl usively
for such purposes.
Exhibits -4
EXHIBIT B
<?{
92 2 5|9 5 03 7 AR TIC LES O F INCO RPO RATIO N FU>gD

OF SEP 1 < m
THE U N ITED DAUG HTERS O F THE CO NFEDERACY -
NO RTH CARO LINA D IVISIO N , IN C .
-CflPOUWfl
I, the undersigned natural person of the age of eighteen
„ or m ore, acting as incorporator for the purpose of
creating a nonprofit corporation under the law s of the State of
N orth C arolina, as contained in C hapter 55A of the G eneral
_I — i:— ™ I ___ II i entitled "nonprofit C orporation Act,"
and the several am endm ents thereto, do hereby set forth:
i 1. N am e. The nam e of the corporation i s The U nited
D aughters O f The C onfederacy - N orth C arolina D ivision, Ino.
2. D uration, The period of duration of the corporation i
s
perpetual.
3. Purposes. The purposes for w hich the corporation i s
organized are to achieve the objectives of the U nited D aughters
of the C onfederacy, w hich include historical , benevolent,
m em orial, educational and patri otic program s, plans events and
scholarships by m em bers w ho are lineal or collateral descendant,
of m en and wom en w ho served the cause of the C onfederate States
of Am erica.
I G . To establish a fiscal system to receive charitable
donations, trusts, etc., and to carry out charitable trusts and
trusts for benevolent and philanthropic purposes in line w ith
the above stated objectives.
H . To engage in any law ful act or activity for w hich a
non-profit organization m ay be organized under C hapter 55A of
the G eneral Statutes of N orth C arolina.
I
. N otw ithstanding any other provisions of these
Articles, the purposes for w hich the corporation is organized
are exclusively charitable, l i
terary and educational w ithin the
m eaning of Section 501(c)(3) of the InternalR evenue C ode of
1986 or the corresponding provision of any future U nited States
Internal R evenue Law .
] 4. M em bers. The corporation shall have m em bers, received
by application in a m anner provided in the By-law s.
5. Election of D irectors. The directors of the corporation
shall be elected i
n the m anner provided in the By-Law s.
6. Address. The address of the i ni tialregistered office
of the corporation i s 302 N orth Blount Street, R aleigh, N C , W ake
C cunty, N orth C arolina and the i niti
alregistered agent at such
address i s M rs. E. Thom as D rake.
Exhibits -5
^%
7. I nitialD irectors. The num ber of directors constituting

the initialboard of directors shall be nine {9), and the nam es
and addresses of the persons w ho are to serve as directors until
the firstm eeting of the corporation or unti lthei r successors
are elected and qualified are as follow s:
M rs. B. Thom as D rake M rs. C . Knox C ouncil, Jr.
358 Brevard R oad 314 C ountry C lub D rive
Asheville, HC 28806 Jacksonville, HC 28546
M rs. Benjam in Tart M rs. Kenneth L. M oney
R t. 2, Box 317 3532 Kirby Sm ith D rive
R am seur, HC 27316 W ilm ington, NC 28409
Pam ela C arter Foy M rs. R oderick A. M olinare
R t. 21, Box 1490 3789 Kirklees R oad
Lexington, HC 27292 W inston-Salem , HC 27104
M rs. Annette M acR ae M rs. D on R . Averitte
P. O . Box 940 420 O lde Shannon R oad
Bethel, HC 27812 R ed Springs, HC 28377
M rs. Jesse F. G rim es
R t. 3, Box 230
Pikevi lle, HC 27863
8. Incorporator. The nam e and address of the incorporator

i
s:
A. Frank Johns
P. 0. Box 3585
G reensboro, HC 27402
9. Pow ers. N otw ithstanding any other provisions of these
Articles, thi s corporation w illnot carry on any other
acti viti
es not perm itted to be carried on by (a) a corporation
exem pt from federal incom e tax under Section 501(c)(3) of the
InternalR evenue C ode of 1986 or the corresponding provision of
any future U nited States Internal R evenue Law or (b) a
corporation, contributions to w hich are deductible under Section
170(c)(2) of the InternalR evenue C ode of 1986 or any other
corresponding provision of any future U nited States Internal
R evenue Law .
10. D issolution. In the event of dissolution, the residual
assets of the corporation w i l
lbe turned over to one or m ore
organizations w hich them selves are exem pt as organizations
described in Section 501(c) (3) and Section 170(c)(2) of the
InternalR evenue C ode of 1986 or corresponding Sections of any
prior or future law , or to the federal, state or local
governm ent for exclusive public purpose.
Exhibits -6
W ITNESS W HEREO F, Ihave hereunto set m y hand this the
/O rday of Septem ber, 1992.
(SEAL)
NO RTH CARO LINA

G UILFO RD CO UNTY
Co»4
personally appeared before m e this day and acknow ledged the due
execution of the foregoing Articles of Incorporation for the
purposes therein expressed.
W ITNESS m y hand and notarial seal this the day of
N otary Public
N y C osnnission Expires: DENISE Y. WILUS
NOTARY PUBLIC
nUttfORO COUNTY, NC
taaUn Expire 84-M
Exhibits - 7
EXHIBIT C
MEMORANDUM OF ASSIGNMENT
This Memorandum of Assignment memorializes an agreement by and

between THE UNITED DAUGHTERS OF THE CONFEDERACY - NORTH
CAROLINA DIVISION, INC., a North Carolina corporation (“UDC”), and
NORTH CAROLINA DIVISION SONS OF CONFEDERATE VETERANS, INC.,
a North Carolina corporation (“SCV”).
WHEREAS, UDC desires to assign to SCV, and SCV desires to assume, any
and all of UDC’s reversionary and other existing legal or equitable property rights,
title, and interests in and to the Confederate Monument presented by UDC to the
University of North Carolina on or about June 2, 1913 (“the Monument”), to the
extent that North Carolina law provides for such interest(s).
NOW, THEREFORE, UDC and SCV assert and acknowledge that UDC has
assigned any and all of UDC’s reversionary and other existing legal or equitable
property rights, title and interests, to SCV pursuant to a written agreement entered
into on or about November 5-3 ^ 2019, for good and valuable
consideration, the receipt and sufficiency of which are hereby acknowledged, and
assert and acknowledge that the signatories to this Memorandum of Assignment
have the power and authority pursuant to the by-laws and governing rules of their
organizations to enter into this Memorandum of Assignment on behalf of their
organizations and to bind their organizations to this Memorandum of Assignment.
IN WITNESS WHEREOF, UDC and SCV have caused this Memorandum of
Assignment to be executed by their duly authorized and empowered representatives
as of the Effective Date.
1
MEMORANDUM OF ASSIGNMENT - SIGNATURE PAGE
THE UNITED DAUGHTERS OF THE CONFEDERACY NORTH
CAROLINA DIVISION, INC., a North Carolina corporation
Date: //-23-n___
By:
. %,tt. H- ffhmll
Name:
Title: President
STATE O F N O R TH C AR O LIN A
C O UN TY O F /JU~
L Cflty n , a Notary^
I, ublic for said County and State,
do hereby certify that /v • fy/well personally appeared
before me this day and acknowledged the due execution of the foregoing instrument.
Witness my hand and official seal, this, the day of , 2019.
(Official Seal) Notary Public
AVAHOLTCOISY
My commission expires Notary Public - North Carolina
Lee County
D-/6 .
My Commission Expires Feb 15.2023 I
2
MEMORANDUM OF ASSIGNMENT - SIGNATURE PAGE
NORTH CAROLINA DIVISION SONS OF CONFEDERATE VETERANS,
INC., a North Carolina corporation
Date: )h P3-/7
By:
Name: A- 6ibAf
Title: Division Commander
STATE OF NORTH CAROLINA ;

COUNTY OF
C^MlDQ Go YQ ^~T i>

I, ___________________________, a Notary Public for said County and the State
of North Carolina, do hereby certify that l(t __________
personally appeared before me this day and acknowledged the due execution of the
foregoing instrument.
a
Witness my hand and official seal, this, the day of , 2019.
(Official Seal) Notary Public

°*r •
5O2 fcv \ o
My commission expires _o r-
/d/ °1 ,20^-d IS*.£'V |c
VfeV ^ /fi
si"-
3
!
EXHIBIT D
MINUTES OF ORGANIZATION
AND OF
1ST AND 2ND ANNUAL CONVENTIONS
2£ntte& iDau^ljtcrs
of tb«
Confederacy
NORTH CAROLINA DIVISION
Exhibits - 11
CN
.-3
:S
■g
W
Un it ed Da f c .h t e u s of t he 0>>:rEDE::;vcY 5
perlv tntight in the public schools of the State and to use

its influence toward nhainiug this object in all private
schools.
CONSTITUTION AND BY - LAW'S 4th—To honor the memory <>: those who (ell in the
services ot the Confederate States, and to remember grate
OF THE fully those survivors who having faithfully served and
suffered, remain loyal to the Confederate Cause.
NORTH CAROLINA DIVISION UNITED DAUGH ARTICLE HI.
TERS OF THE CONFEDERACY, Me m b e e s nil*
CONSTITUSIOX. All chapters which are properly chartered in this State

thereby become members of this Division—seven or more
ARTICLE 1 women can organize a chapter anywhere in North Carolina
by applying for a charter through the State headquarters.
NAME, The qualifications for membership.in the chapters are
North Carolina Division Daughters ol the Confederacy. laid down in the Constitution of the United Daughters of
ARTICLE II. the Confederacy, and are such, as to render the Daughters
OBJECT. of the Confederacy in time a strict!} hereditary Society.
ARTICLE IV.
The object of this Association shall be social, benevo
lent. historical and memorial:—To accomplish these pur Of f ic e r s
poses, it will seek, 1st T.> bring into its organization all
women tnroughout the State who are loyal to the memo The officers of the Division shall l>e a President, four
ries and principles of the Confederate Cause. Vice Presidents, Recording Secretary, Corresponding
2nd.—To give assistance when needed to survivors of Secretary, Treasurer, Registrar and Historian, the last to
the war and those dependent upon them. be elected for a term of years a*, the discretion of the Divis
3rd—To collect and preserve relics, objects and inci ion, the rest to he elected annually.
dents of historic value, to record deeds of heroism, espec ARTICLE V.
ially those of Southern women, and to unite with the
Me e t in g s
Confederate Veterans in the determination that the portion
of American history relating to the late war shall be pro- Section 1. The Division shall meet annuallv near the
£
■§
lu
6 Min u t e s of 1s t and 2n d An n u a l Co n v e n t io n UNITED I).UT.HT1-7*S OF TEE CONFEDERACY 7
second Wednesday in October at such a place as the pre adopt such rules and regulations ::nd by-laws as it mar
ceding convention shall designate. deem proper and expedient, provided such be nt t repug
An annual meeting shall be held by all the Chapters in nant to the laws o) North Carolina or the Constitution oil
the State on the 19th of January (General Lee's birthday) the United Daughters of the Confederr. -\ .
or on the day following if that day falls on Sunday. ARTICLE VIII.
Section 2. Each chapter shall be entitled in all meetings
Co n s t it u t io n
of the State Division, to one representative for even-
twenty five members or fractions thereof over seven. Any This Constitution can be changed or amende!; y a two-
one or more delegates from a chapter cau cast the whole thirds vote of the delegates rej reser.lntit r: in r. g’dnr Mis
vote of said chapter. sion assembled, and after notification cf. at least, thirty
ARTICLE VI. days before the meeting at which amendment is to be
made.
Fe e s , Du e s . Et c .
Section 1. A fee of five Dollars (5.00) shall lie charg HY - LAWS

ed each chapter lor its charter and one hundred blanks ;
fifty cents shall be charged for each additional one hun No. 1. The President shall pres hie at all meetings,
dred blanks. announce the business before the Division, state and put
Section 2. Upon organization and upon each succeeding all questions, preserve order and decorum, and decide ail
Januaay 1st, each Chapter shall pay into the Treasury of questions of order. She shall have the general supervision
the State Division ten cents per capita for every member of all affairs of the Division, appoint all committees and
who may at that date he in good standing on its roll. approve all orders drawn on the Treasurer for payment of
Section 5. The sc-al of the State Division shall he the money. She shall call special meetings of the Division at
same as that of the United Daughters of the Confederacy, request of the Chapter.
with ike addition of the name of the State on the outer No. 2. The Vice-President shall assist the President in
rim. her work, especially that of establishing chapters, and in
Section 4. The 1-adge to be worn by members of this convention in the absence of the President the senoir
division shall be the same as set forth in tbe Constitution Vice-President shall act as President and discharge the
of the United Daughters of the Confederacy. duties ol that office.
ARTICLE VIr. No. 3. The Recording Secretary shall keep a minute
Spe c ia l Po w e r s . book, it: which an accurate report ol the meetings of the
Section I. This Division shall have power to make and Division shall be recorded and keep a roll of the Chapters
2
r2
•sw
S Mi n u t ns on 1s t and 2k u An n u m . Co x v b k t id k Un it ed Da u g h t e r s of t he Co n f e d e r a c y 9
No. •«. The Corresj)onding Secretary shall conduct the all historical papers, aud shall claim the cooperation of all
correspondence, file all letters of importance, and keep an the Historians of the various Chapters of the State.
accurate note oi all letters written by her for the Division. Adopted April 2Slh, IS97.
She shall notify all committees of their appointment and
shall iurni h the names of nil to their respective chairmen.
No. 5. The Treasurer shall collect all State dues and
disburse the same under orders or the President for the
current expenses of the Division, she shall give receipts
to Treasurers of Chapters for the annual assessment receiv
ed from thc-m. a:ui shall .-cud her report with her book to
.the auditing committee two weeks prior to the annual
Convention.
No. (■>. An auditing committee composed of three mem
bers, shall be appointed by the President, whose duty it
shall be to audit the books of the Treasurer two weeks
prior to the annual convention and make report at same.
No. 7. The Registrar shall keep a register of the names
of all members of all chapters, and the date of their admis
sion to membership. The Recording Secretaries of the
various Chapters shall send to her from time to time, the
applications for membership they have received. The
Registrar shall have custody of all applications for char
ters.
No The Historian shnll collect all records and inci
dents connected with the Confederacy and its glorious war
for independence, e.-pvdally the part taken by North Caro
lina. ami by the women of the State, as well i:i self sacri
fices and untiring effort after the war. in the reconstruction
of the South, as in patient endurance of hardship and
patriotic devotion during the struggle, and shall safely
keep and preserve the same*. She shall have custody of
C3 i
Ub K
I 3 17_ i 9 oo
ORGANIZATION OF THE
North Carolina Division,

United Daughters = Confederacy.
A meeting called for the purpose of organizing a North
Carolina Division of the United Daughters of the Cooled*
eracv,
Pursuant to a call from the Charter Chapter, the Cape

Fear Chapter, United Daughters of the Confederacy, dele
gates from several chapters in the State of North Caro
lina met in Wilmiugtnri, X. C. at the Wilmington Light
Infantry armory April. 2<s. LS97 at 1! o'clock. A. M.
Meeting called to order by the President of Cap«-• Fear
Chapter U, D. C. who announced the first ihiug was to
decide who should preside at the meeting. It was the
unanimous sense of the meeting that Mrrs. Win. M. Pars
ley preside at:d Miss M. F. Sanders act as Secretary.
A committee on Credentials was appointed 1 y the Presi
dent consisting of Mrs. Jus. Carmichcal and Miss M, F,
Sanders, upon examination of same reported as follows : —
Mrs. X. Louise Blount anti Miss Annie T. Bragaw from
the Pamlico Chapter, and Mrs, Parsley, prox) for the
Asheville Chapter. Delegates then took their places in the
Convention.
Exhibits - 15
2 Min i 'TSS q y 1s t and 2n d Ax x u a i . Co n v e n t io n
A communication from the Raleigh Chapter, regarding

an article in a Baltimore paper showing that the G. A. R.,
and other organizations at the North proposed to have a
school history prepared in which all persons participating
in the war for Southern Independence were to be branded
as ‘ ‘traitors and rebels’\ the great hero, Robert E- Lee,
especially to !*c denounced, was read and the Raleigh
Chapter's sentiments of indignation heartily endorsed, ft
was decided to refer the m alter to the United Confederate
Veterans with the regci-st that they present same for action
at their nest reunion at Nashville. Terra.
The greater part of the time was occupied in reading
and discussing a Constitution and By-laws- The Consti
tution was Tead seriatim, very thoroughly discussed, and
after some slight amendments was adopted.
A nominating committee, consisting of ?dr>. Jas. Car
michael and Miss Bragaw, was appointed, who made the
following report.
President. Mrs. \Vm. M. Parsley, Wilmington.
1st Vice Pres. Miss I.ida T. Rodman Washington.
2nd. Vice Pres. Mrs. J. S. Henderson. Salisbury.
3d Vice Pres. Mrs. Jno Hinsdale, Raleigh.
4tl: Vice Pres. Miss T. L- Patton. Asheville.
Cor. S»c. Mrs. A. A. Watson, Wilmington.
Historian Mrs. Fannie F. Tieman. Salisbury.
Registrar Miss Annie T. Brngaw, Washington.
Treasurer Mrs. Col-Gaston Meares. Wilmington.
Rec. Sec. Miss Kate McKimmora, Raleigh,
The above officers were duly elected, and the President
authorized, in case of a refusal to accept on the part of any
one or mere of the same, to appoint a substitute.
Mrs. Jackson, the widow of the lamented I L
Stonewall
Exhibits - 16
Un it ed Pa v g h t e Rs of t he Co n f e d e r a c y 3
Jackson'’ was proposed for nomination for President but

up on examination, her name could not he found on the
roll of any chapter, the nominations therefore resulted as
above. Instructions were given to the secretary to ad
dress a letter to Mrs. Jackson asking her to allow her
name placed on rhe roll of the Cape Fear Chapter, this
being tlie Charter Chapter of the Slate.
The time and place ot the next convention was taken up
resulting in the second Wednesday in October, l SO7,
as the time, and the place, Wilnir.gton, N C.
No further business being on hand the convention ad
journed to meet at time and place above named.
M. F. Sanders.
Secretary.
Exhibits - 17
EXHIBIT E
M I M V TES
OH Tin
Eleventh Annual Convention
OK THh
ol lhe *
Nt•*' 1 nrolir.i l> i>u>.
HELD AT
Greensbcro. N. (.. Orlobt r 9lh. 10th. ami lllh. 1907.
Mils W S l\\ UK KB. I *k i -it* i: n i

MKS KlvANK M WILLIAMS, ItwomuNi; Si..
N H.WTON N C
h'.-.. k v w is . I. < PviNt
im
Exhibits - 18
7“ \}<v . i :s <»k Ki -k v k n t h An ’n i al ‘ «*n v k n t h ».v
Tie* ;n of eiv*Un#i • n»;tin in Rihitfli in-:

endowing s 'hnlMohiiiH at tin* A and Ai f» r Hu- de>
• ■ ul.l lit - • *f • I, • I I > V. ;-(■> \n 1 }•» !'.'*ruuriv tf
Henr.v Wyatt. the lir-’ -tn ki !• t i 'In- *• r
between tl <■ St itf»s x »v. _i-vs. -.i to i?«*• « *n\ .*•.»«i*
by the Selma chapter Tht* fiisnl iin id <*1 vfi’ii hearty
endorsement. ami n?h rhapt* - agreed t.» iicl in it"
. !Vt'1loi> i- ]t the *t \m: ijsdttps • r«* dis.l;* rO\«'<lot,
they W4-r* » • »*• fin ;!.*• I**ncflf • J»oy*
The St.o ;■ ' :11i JaoUôn scholar-*1' \». **. Inch
U.\*s been — t*blish“d by Sat* m AcidÛiy. wa-. heartily
endorsed
A telegram from Mrs. Parker, in response to th*
om* s**nt the first day. was re. mved und »• l to tin-
• 'onvctition
Phapter report> were now agiin rak.-n up. hut
motion » ng made to dispense • :,li tin- reading of a ny
others. «inl» sH special work bad beendone during'h*-
year, most of tin- r- j*»rN wm- him tori in tmr** <d
Some of t .1 Pldldivn^ * I it i »t *r reports \. tisn read
and all wet** apnror . d at onn
A ui -tion to endorse the Reformatory was inim
cluoed ami passed, after which th*- Convention udjou**n
**d U »r dm
THIRD DAV vFTi hnoon .Hfrtssn ci.

At -»« »*l<vt*k the hail was • j ■- n filial with d<
gates. all < tgep to eonrinue 111« '>U"iness <d ’!»•■ «l:«\
A mornoM wa> n»;o i.* to h. i pnrtr s of Jo"
Turner -minted, Inst no definite act son v\ • *ak a.
A motion was then made an*i imanimou'dv cam* a
*hat hereafter all general $nxe> •** sent wch State i ix-
• *s to the State Treasurer, ami by her fo d to thi
Exhibits - 19
\ MTi.l. !),\i HU 1 »»t* <*►' Tin * 'o\ h‘ !•: 1 if k.\» \ 71
urt*neml : ensurer.
i :iv■ • !:■ m* 11> ImM file Convention of l-*1' in their
»'it ,.»s, then re e; from Castoni; , ('unr u«l, u tin v<<* Iv
tnvT 11* kee I iohlsUir*• .t* dee] ar-■<«. to tie the place o!
till IJCXt :;H et III".
After -O! f ()’K4’U^!0|1 ' Tie* lee Stotlr" r.»* •-hijseri .1"
tin1 ortici.f orâii ot •]■> North t rolinn i>: siou. ami
Mrs. i! i*- It VVhU .im Hri<»rir.i t*. its r* >r**s»*ntiit..iv>-
Hi llie Mate
M : » -Mines Ke.vui 1 lieu . ' ■"■! Jeed t j.- : •»! !o 11, _
resol lit .or. vvhH-li W x | .,ssed
"Tli.it tie- next work tinderbifien by the North
t’iirolun 1* luehtiTs. " thr on »li** «*ampus .o
t no Soit- I 'niv rrsiiy. *►! a monument to i !»*• students
ami faculty, who went out from its wall' in 1**11 to
tight and die for th»- Sooth."'
Mi x l W K.iison was uniinitiicnisly xi tod t.» ivj.
iv mimh No: i\ i Au ’o Iim i it the Norfolk I'om tttiott, and
retd lie ! Vi sklent's report w is also nstrurod
to vote *e . list tIn* r osing of 'lie êmn*al tax to st <NI
}H*r im?*nU»r.
The continuing of‘ *■ isi if the (chapter i^{)oil
blanks v i" taken in* o k! disi 'issed md it was d**eid« d
to use tii* in anoti e|- year
Mis K. K. Moffitt here ilPro lit -e I 1 I rh rollVetl
• u*i» < ;t; t Rs iirnoml lVarson tlobsoii. *f M'-nimae
: i ate. n ho 1 :ade a xi,i<d talk t .t ... ilf;d<*e
It s decided lo otr (a I'" - Mrs II \ London
to druv :*»mlheSr ?•■ Trojisi; - the until u needed t*.
make U - he UlUOtlO touted ho ■O•■ to fir 'It dei i e« •;
by Iter it Lid.!’port to the W’irz ni«m<nit<-ttT.
1* h» re l>*ine announced ?h e t a- c;tis vv.-re wo?
iiifg ?o »• irry tie Uu ers to 1 ■ wpti'ir, ,tt rh** St e<
Exhibits - 20
EXHIBIT F
175
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lu-ft W--C ^-<^1 t^. fvCZ, ■.- , ’ - i- /a ^-— ... 7)^ iJc- ••—
/v*-« , i ft c4- Jr*. r*-i i T-o ^-^ZCL. 7 '-*'-Z._
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(%. _Ô-.
■ k *Wis7*-^kV.*K -v-t^ft ."i t . ,J~v'i (._C «x o r'> Z<- O a.^X~^^
£7u a i ^<^.»- ^Ci 'Cft..,*. Tiv«- It ft A :--^l, 1ft, .X-, iu /V-I u Z?T> ^Li^',-,.w,2J'-
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S'u. - . L
Exhibits - 21
17<*
<t '“x-4v
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■ -ft *rV~‘ —.Vt.-uc —s >v.X
?JC-L~ !>■> Z^c

ê^/rwc *-* {S~^-'~"-+~t -L{L, <-oAfciu_
^X- ^~‘J%~>£~:' -1'- t-+-eJi~-s~^ ■Sz- C-fc, efc. . ~K<-^ t-u /i^
■ u.r-y+r rWi’-<— i-'I ^ •->*_ C~-.—^rl^4
n-J^-^2 f *t /? y^Stâ. 45 A~ ,-r-a. -XX_
V?
A -• £" <r c-—^ ^t--* ’ 1-<-<-4. iA^-C_
k-J? t> M* -5-ife-w . -, RL*. ,’u^n^J^y tX%~; v-l^rx «.vXv^>p^
li I A :—-C. ^ - ;-. X, 4o . X I_..^. /v*_ . «2t ti-.- <L{--. X>-X aX?*. O c Tv s TC.
~z U''"OC< '._ -?^l.. v,!. Ti {.4. /?■;*-Xt. X-. w % ••—,.-~ -Xr-j 'X_*lc/V.s 3
. '-•«•>- A. 4 tvA-v C-.--=-Cc.( £■-•<_ 4 &,r-l+J.*.t ,~^Xs 7;Ci-l*. Cfi^^

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tJtU^&XZAa c.'Tj^Kcr.
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Exhibits - 22
177 ;
c\- ^ rVi—jti-C <L>0 rC. /S*— .y 'cL.

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£ aCVv< ^-iw 2^- /v s ^_,-^k Z1-<» tt. 6i^-A.l<>^

d^t_ A>— ~*~ •*-*_. 1— î Titu. fit"''£ ^V-J-O .. U f.n- •a/3-
3. b-,--Ct^€^ r~C if^~r di-—<~,—2*. 0-^-TT70 J.V—1<"»*-—^

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Exhibits - 23
EXHIBIT G
l
\
\
June a,
1‘ • o- J C » > : ,r...
Chatman Ceasittee U, D. C •»
ffollnce, K. C.
tear l : i'.or.nr.j
A': the Basting cf the Trust*.-. 2r-t, J
presented your l
etter ri
th regard to the Boaoriai proposed
by the U . 2. C . The lr*;:.ivut: tor© f..uch pleasej*Vy the

)
otiggestion made- by tie R. C'. ^Division nd rill be glad to
oooperat* vitl you i’.i ‘any ray. It *ao suggested that a very
appropriate r.erori 'J m■! ■: vt i roaori c.l c.ler iy t o ih-
c c-. I thl \k it -•■■■ i : It- beet for socw oi the ladisa on

the C»*altt«e to visit t.;$ Uniieroity srd «♦•■•.•-do -?or. i. •
proper ftjrn of Msu-iftl.

To shall be very g? »• h*ra you oo ns her*- ’i' 2 it vli^.
gi*« re p\o\-r-.i c to eld you In tr.y *c.y i t rn Tiorer*

Very truly youre.
; '
r! -c'}'-
f resident.
Exhibits - 24
EXHIBIT H
MI y V T £ s
Or TH£
T vveKlli Animal Convention
>P THE
United Daughters 01 t i* Confederacy,

NORTH CAROLINA DIVISION,
H KID AT
Gol4bc.ro. N C.. October 13ih. 14th. tMi. 1908
mh s s. w. Fa is o n , pjvsktent.
VIKB r M WiUJ.vMS. KOOSr t>.
NfrWTOH, v I
KvrKHiKisK m m\\
1909.
Exhibits - 25
VO
CN
.s
.■s
7:' M i m - i» .-! ♦ jp Tv. i .n n a Xu i 'a l »'o.s v i N'l u ■§
Un it e d Da i 'u u t k k s or t hk i’uxPKDiitACY 7li Lit
Bethel Heroes Cluptcr, Rocky Mona* i.moo

flank Bard Chapter. Windsor •* • •* 5.00 :tiii:uu) Af fmw • 'tU'i ' ’< -iv ni. • 1 -v n I u» Mt*» t*IUu
Gr.tum Chipler, Graham 5 <X> . :?£•, as :i a s . a iv . \i' H-it ftmd« from
(iao Andenno Chapter, Hillsboro 12.00 vim . iiu •: -i - *•»< at- iu-.'i.ttii- ut :• ;1 ■ — '••ssiuc
'•’e- :“ti Comity Chapter, W;.»boi** 7.00 <5 ijy. II, i'..111 • 1'• ... » to • mi "!•' •*' ••'•'»'.l»ti'i|t t»r U:t
Ansois Ch*j:tci, Wiiilesbofo........... 4.50
Scotla.l Ntefc: Chapter. Scotland Nre* JO 03
; n. ir.ri • »>T ff iff -.t Uoi’i'-t K Vo' >n «. ■ I.K'U
Bell Battery Chapter, Edeotou 2. Oh
John Dmihau Chapter. Wthon 25 m
>nlian Carr Chapter, Durham 5 Sid
S K' *< > \* U l » \ V A <- 1 *J V s t.K) \ sKHS MW.
Hoauolcc Minute Mca, Littleton ....... 8.43
>.intc»*iUe Chapter, alalttdUe 5.00 \t tin opening <»-r i!tt» »rt«*r'intuti s'-<*i«n: Mr*.
Han *mr-Stmt M Clap ter, Newton 1.00
A M WidJill Chapter. Kiueton fe 75
Hi*it!jj;- - -Ai'v i •;•••*! 1 to m i v «*. •• !*»♦- mtrtjex
Ksniton Children Chaptre 5.00 for li« i*«»t W»o. L. St'.jtiddi*.; .u^namoi-t ltd t do ^rnvn
Kobeiua CLaptai*. Lusiibe. ten • ••ft 5 00 -••V lit:- tvhttivr* ami s,» i:I;:ii'.‘liiiiili. 1 ,v Hi.-
lolwIon-Frtttcrvw Chapter Ksh-'JH 102 lit) cimpioo-tmtl : • ti n‘hii:ttA»l i>> utmit Im* following
Jhonias Kutriti Chapter, Goltliboro 5 00 i:i am - i.:; n m • .1- • Ail ;ra * * tl t by Jit* cl» t| lor=:
Confederate (Ha t Chapter. Mt- Olive 5.0Q
rerqttimana Chapter, fiertlont i bow ch.ipur;-. til iyt ."U. «*. lliVtf A.-utcJ lu the
1.50
tytn. Allen Chap ter. Kemtatrllht 2.W Was. L htfiMilo • ittenuawnl hr • n turn the money over tu
rfolt-Sander* Chapter. Southfield. At%» tietut J;ur.tr U: the George U.»xi* u*iiiHAWAII
50 00
Henry Wyatt Chapter, Selma.................... Mr:-- Cmc c t .
5/2.27
Total • **»« ■ ■•(AfKt* |7H M Th • *"i I iiii si . . I 1 licit I'i-ntl
Daughtrrt ol Hi . Con led* racy. I»:« tt- r.•* *«.'•-• grow neary, on:
IjV Mth K- I ’. t111-.:* Wl’lt Ilrtnr »)f UfilU-Wai of
atari the #«•» fra.* *nth renewed energy n--.il/r.- dim! »«.
ti.'Sii'i' lu the Tnmucr . o( Henry Wyatt. t!-• • M:»rh- ! «.-• rr.utl v m- np}.mv--»l s p. .d. willt the
Will not t»cty dupU; Uia I lu • lutid no par: t’i this work ao.< 1*2 L*i . lion t iiii: •-.!< it 1.1 i • •MunliO i s pn.v liflv tvuls lu
ple.tje rhe.uevlve* * » lend » helping hand, «n.t t!>r..k- th^t li.iu-hf.u ivttnls It • ;ti: .1 > .Mf.
u (artldal will yon itvnd by im until t!ir moauroca! to Henry
CHAPfeL HIM -HONUMBNl KfiPOKT.
Wyatt r-i on lo«.;*-t a 1 mj hope, hat a psond tializiti-.?..
Respee’Jttllr sr.bmitteU
M■ »n,t Brm:fc*iwt* p; tui.ii-i OAWMUff* « -or. l‘*wr”»r v-
Chairman llrury V. ra ■ Won s on. :Vt mil 3ut-. riser tin j* u : October -.a »*b.v ■>, the njjeetion
„•.% made f.< bu I ’ .» handnoait tueunsriaL tube placed ua U.c.aiApue
A vol'Mtf Usitils A,.'. lu Mr. >.f|)chf't’.er fi t
oi the s.itr Mnive-my, to the tlndr.ii! body, a ho laid *»:dc thew
his .tiu t-1 • «• U> .1 ' I’.i . u r in tl.i • tv ,-- ., .-.ml Mrn '. j-
c •llejie <lo tic. *i*d jo me • on -.not hern amty >••• ‘-s;.
WtJi ii tjimslt <1 Its •- lit*' lluuttvs. li r.i.s itifft-.il I’.nt [i i5 ,aid the Uaiiuutf t.tmiJhcd l.(tti) lolriurr lor :hi< eimt.
£
74 Min u t b 8o f Tw e i .h t m An n u a l <’o x v e n t io .% Un it e d IUr«inrc:;s or t h s (v>.NKBr»i-:ttA<*v l •* r£
■§
UJ
many Ol then were hardly grown. hut like their |iHviattwi\, w*»*
rhaptcr crdl- .'i iro.-.i rich member ,v their .-haptcr 2S rent- in Jane
brave faithful and (mu, willing to ]|ht their lives » ssacrtfiicc to?
ary and June each year, making til I ai-.c«iir*n! >0 emti.
principle. S>«: , Daughtci will gladly pay it i believe i! t riled upon. I
Four hundred >f these soldier* wen' killed, w.tnc (if them j|«li
;*»k tvt~\ tiaplrr t ■ »«»*.• kUtd o> 1 eulrrUiatncot t.i t.’w
r-1 i; U'm >n«u »»«•, both • • personal and intellect ..«t xinieaU «pnr*.‘ and la ■ ' r • I-1 :»r-. •. ■, vit lithe k*
With our Banner farlid. and their iond hops', gone,the rcmusMl
Ice* .-eprvaeatiug i.SOO iif i* . -'. me will tur* a good begiauia.;
tlul w a s left, bare kui .aid are still passing away, Our cvKiiuit'te iluu'i. *Luuld le able to bu.ld thi; .cut. uncut tu
Thr.e men have a history, that most he left to po-perity. rhe.r
a f. « ■tai - aud * itnsld ti . and ul» llicsudn! ait « a*.4 at oacc.
lire are worthy cl every honor " i'beir likei-cain tl*r eailh aid We tra-ri- tnat to you amt i» any -nggestioui 4»e to be mad • *t
scarcely it*.' would gladly hear them.
In chronicle o: oa the toacicl lvrc. acne i.r:.i*;r admiration As lire chaplcn pa. ia each assenmeat, tint chapter yrtiidcul
will h»-plr«. con lorward ^ chcc^ pu .jb'.c 10 tie. as cluirmau *>: the Uoiversty
The Stale University b o w lias over 700 (Indent*; every year rmmumcat camaitUrr. 1 .vill rctvru receipt lor <amc
til. . com-: and 40; with Itw* hntanc moan meat «•. .1 1.;; silent »» • Oaugiilerc ol jiorth Carolina o«r work i* one oi lova but it re-
(lone, appealing to their noble cntiuscaia ot courage and palr.o uc quire* boli> pit»«Uit arid dtitVrmtiukUao, and we are a»rt a hand to
love oi ho ••••_•. our Southern history will be fea.l M!h ;i>r- lulttri! Lv diacabra ’cd. 1 am unt ol your seulo; Qwmheru uo*», but 1 wa* a
.0 rhat our -ci. can challenge the world and ret Mr. ny char-;* •*■ I;flic girl dti 1 14 tlul period. I did mil then surfer the heart ache*
tlccling upua ttu: honor o onr cans*. and. anrience that oldtr members cl n:, family did,bat I kimw aotli-
The Daughters of our StMt. hate the Aaensd privilege at payin' :u4 but to love ;t.. Southland, it • sons and daughter? Every day i
ihi; tribute ‘o them. live 1 realize what lk*c men were U> «j u i couutr. and if «« hope
• vr it*, h •• r«i tin* not.i i-.caJ, -ml br-«UI it quick, i.. :• t ia , . for v uoys to ;>.* worthi o »i.:h * • ten let ir. place their noble
palling and «<. art 1<_-..ag opportunities. deed- fore t'. r. :H rnouament will m-.pi:. -.'Ut« pride and I
Mr* l aisuii appointed me chairman »■( the Uiii*e**li> mouu- am core mil do good, betidci it u u tribute wc owe ibosc soldier*
iiieitl Con nittec, ami ate me .He had given measti mgcontnmtve boys.
1 need not tell you * fell gratified ami onr pre..deut too**«. ki..dly Mrv Ja w > G K> -an,
to the suggestion, lor »«y heart »» in shir work, nol alone lor t.-.*e Chairman U.!i»ver>.aty Mon Com
ol the Southern ulilittl, but alio loc pride .rt the living
A. m v : n I Ijlifttd ol my *ppOiii;..ieual * 1. «*■:» i-KtT* r 1 *0.1; iKtarnar.
■Member ol uy eo umittce. cilia;} hern had .-nly prrlnmnar/ Mo. JsM- »G KfiJtAd. ClMtitALtM Co»Atrrei U D C.
!- »•».- t‘. >i»r, l’/‘ »4 p'-iii1 * 'c VVAUACfc, N C
' f'.ieu /rote Dr. Venable. prciidut o. oui University, u.-.a n.-:- D*an Miri Kr*au
u t ol courtesy. iciltn; Ulut wf-it we y oposed to do, an 1 would t--.- At the mcctiag ol the Usiiieci Jucc n \ I ; ;c mlcd your letter
yjl»J to have turn, wit: 1 (S board o- trustees, n>-operate w.th u» wllh icjard to the 'ntui-.'i;*! piapow.1 by the U. D. C. Tb. trustees
fix- idea seemed to appeal to aim. aim 1o tile tr»i!«* »• you .<*11 were pinch piemsed by the tuggetliqu by the Harth Carolina Jtvis-
»«c from a coii-iiiBu.e»tloo. uni and Wilt tv glad to co*op«rate with yon n any way. It wav
M committee will tied the help and lutere-it of all chap ten loa: a very appropriate memorial «<n>lrf be a me mortal
. tb" d«vi>l«a tor Tim work t ron*«drr t;i.- hr uv.rt . mporlan. gateway to the dathpus, f llm»a it would In- Se^t ft» acme oue ol
Bad bcatrlifui we hare ever uudirlakcn in onr •;*»; Stale, it w.ll the tadie% on the eott.a.Utec U v-*:; the Univcnlty and decide up
U*« patience and *c must dt*i« meant ol railing n-uus*. on the proper tortv. of memoriel,
To bt*»i:l vlrh, * 1 < . >st urnedlt Hut cadi. ,v.i 1 It.it t'tc Ve ‘hall t>: very glad o heve yon cum* her.- ia t it wiU give
oo
70 MifnvruH or Tw e l f t h An n u a l Co n v e n t io n i \m:) Da u g h t e r s o f i .»: < Y>n k h l r a c v •<
<N
2
£
• >*•-»k Pvt 'ivn.r, tiAtxttrrri ■- or t hr Ca*»i'.sv suev •g
tu
me plea are t.» aid y*u tn am wav n r:y powtr
Very truly you.-i. Ak .-hiirfla i ci* the Kobci? Kantc-i horinti Committer, 1 r<-
FrAt :■ 1* Ylmtar*, iVc.idcn! • pctl»-iy submit re rex I al cum: iL>u!io.t. o u'lj.i* »:
Cap: real Chapter....... ...................... 52 CO
Psmlteo Chapter. ................... 400
V* -»? *.li»***‘t. ' i ri .It* f*v 4n.| I- Julittmon PBtUgMw.......... - .. ....... 1W
k U|1, !5 .'v s foil iv. a; Albert)!* Chapter ---- too
M I W FA I ON CbarlatL-, Prendnl »'*acc Canoij Cluplit.......... ...... ...... 2.00
MISS SCt COi-UBK. GoUit-oro. ftrvl V .ce Praeidml dent Chapter .............. . ....... 2.00
'•JR.-: *1 WULAKD; W»linto *100. ce'o-J Vice FrcaideuL JJuner & GorJua Chapter ............... HW
MRS i t AH J oTKVtNii !4r>t Re- rh rd Vice Pio.dent Dodxin-Ranwar Chapter , 2.00
VK’v ‘ M WILL: li’IS He .ton . icordto* Sect*-.ary '•-ooewali JacLznu Chapter............. :.u>
MRS GORDON FINGER, CbirUrtu. Corrcspondtn* Secretary Wuuiic Dim Chapter. ....................... i IHJ
MRS KUGEH1. LITTLE, Wad- ttmo, Tr ..wer timUord Chapter ... .......... . 21At
MRS. UOD. UEAKTT. Raleh'ii, K**t*v*r Robert E. Lee Chapter , . 200
MRS 'I'H-JS t sE CR AIG. Recorder o* Croiver. Geu. It AaJ:r;t‘a Chapter ........ LOO
MISS REBECCA CAMEH3K, * Ml .boro Historian Ybotu.it Kit flirt Chapter........................ U»
MRS VV O SH.-‘ OR it. A* • .u! Hi* urtan. Julian fa Carr Chapter l uo
MKs JAMES RENAN. Walter- Chap fat. Anuta Chapter ..................... too
Jckn »Y- Dsabam Chapier 300
A muti.' i . i- mudti ttial tn* tit appoint a A. M. IVadiinl Chapter ........... too
KfHAndt I’Ot't; • 1Y ; -MCllait '. •* i.. !..- »!Ji‘- • lo I •ittVidt i Cleveland Goarils Cl;ap!t- I 00
t|« Hll< !• •• • t I tl r. I- ■'.!•• •• * ' *1 Southern Start Chapter...... ... 1.00
J, £L Q. Stiiort Chapter ............. .......... LOO
a ns.
fiel! 3»lUa> Chapter .......................... LOO
Mr*, Ku2«>n LLik- >•. u . .. t - • s-i. .1 -.ipoft of tl«»* J.t* pit i. Dm > ■ Ciiaplci UK)
No j M'i • tl w .i • • i: , . * . . - ! . - - :fl» Fai-soa-HicA* Chapter
.t s Ir m I. .ini*. tit*1 ton * • iitinn ti: : -u* ' nrv. nflii'r Lvuuivta i Pole Chapter . . ........ 1.00
Aj»|*»«h‘tit1',ttl its i •! ■ i" in trt, ■ i i ! i* r< ’ ‘ ■I rev. it *: - Red Springs Chaplet ................. It»
Ml. Airy Chapter..............-.................... LOO
lllit* m*t ’ll! t-|s*r . II. :• . -|t’ t; • ! • ;. U-l
Kncicinjthai i Ctupt. ‘ 2ud
'irr I*:!' tl Willia.it D«arv«y Pender Chtpter ... 2.00
.in1 iV-.'i I IT.-. .1 Uni-nn iVn-uuit ‘stmm.iit Bethel ilcroo Ciuptei ................... .
; •* ...% iv. .ti lv. • • !•• •? .M;,r:*r* : s tl ■' it' Kannim-Slumt) Chapter..................... fct/j
vionr.*t»r »!»«* f'hntt i:i:ui ;Mirt ;i i»« <* I Pmjni-.caa* Chapter . . iu>
Chicor* Chapter ................................ t.Oi
Li * AL REPORT OF ROBE RT -AHSOM 1VRTRA11 CO.V- Hairy thintwya Ctuptet ................. 1.00
MtlTBJL Hoary Wyatt Chapter....................... LOO
SebtbUHt Chapter ....... ............ 1,00
EXHIBIT I
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Exhibits - 34
EXHIBIT J
\
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bifft i*l** T.imA,
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j« See, TL-itfuj
1 have' lc. '. th? ufcir* a good «4al abort! Voe pro/y«ed tnoaup-
u tht- '.feudaait - )( its VeLvelteity «9xc entered tbs Confederate aerrtoe#
I Velievs tlw* year orlgiaiu -.lea Via tbs wisest one and that really tbs
.■nly ft J-t4.r~: manorial »«rold be an artistic atatne or the Hal varsity grounds
-hinh wild jstaaibly t some $BOOO or $SQ00o 1 do not know Jaet how much
the XAttfhtarc • f Vh. Coiifaderaoj- in foie State aan raise, hat I am confident
tfcat * V. r • rai -i rrcni the alarm! and that the Urnsteea will
■r • ■ th* *3aiv* «■ ; *ertaiiily9 2 shall strongly
»■>-. i . y-'T- V a T u •.*.*■*■ 4.-.'d l- -‘i\» to .raise this
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P:.-> v-That I a» -;l n«4 b-fir* m% tow appeal to ms as :a
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a” -v f . . „ Vi-r .r ' U.i lid; as of yocr Conniitre flam visit the
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Exhibits - 35
EXHIBIT K
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Exhibits - 36
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Exhibits - 37
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EXHIBIT L
MINUTES
i.H i’ rt i-
THIKTEENTH \NM \L CONVENTION

Ot- TrlF
UNITED DAUGHTERS
OF THE CONFEDERACY
NORTH CAROLINA DIVISION

HKLD AT
Wl! AUNGTON. N 1 . OCTOBER ISA. I Ilk 15*. 1909
\!i;s i \V l-VMSON, PiwssmKVT,

Mils, r m 'X\i. a AMS. Uix See.
Me* TO* W i,
CcttadftUHl
lam
Exhibits - 39
o
£
:S
-7.
ill MlNTTKS of TlllUTKKNTU A NN1 \ I. < \ : v V KN'TI'>N LU
Dn ITKI* DM'OHTEHS OF TfIK ('ONFIJIKKAFV. frit
Tills sti|r,_.t.^!ioi| w:i • V i nt.I.Y •llHTllifi-il, ••'.il (in.i l.V SKI ’ONI) I > \ A Moi.'MNi; SKHMION.
lost
4th. Also I be Convention i« asked to decide whether North Af»**r tit*- roeit tlion of tin; Lord's prayer in unison
Carolina want* lo adopt June .'I a- Memorial Dnv li d i>y lhi> t’huphtin, Mis. tin* •ni-dm.’Ssuf tin*
This ••biuitt* w;i- Ibiketl ;iirili»*t ii\ a liire- runni-vi 4io.v liuttan. 'Pin* Vlinutos of tin* ptv\ iuu* day won*
of :-iiil ill*' l onvoiition lo ;<•■* :> May r**Htl and approved A udouram was rviul from Mrs.
l"ili .. . Meinon.i1 1 >.«y. wti.iotu on* dts-oniim.' vox .*. i 'i 'iu. lii.iitUiii” tlu* t-ons**nti"n f(»i*th<»lrl{indr'*ni<;iJi-
Slh. Further, whether the ne* chnlarships be placed in the liitnu-i* of l»nr, nlso a tttlmnuii of tfriftintf from tlio
hands oi the Committee we have that attends to Stale Normal (ii*nvi*ai I'rosidt'nl Tin Pre*id»-'nt then unnounwd
Scholarships, r>r shall .1 new committee l>c formed to hud wav.. and ih»* followiim '»<Mnmiio ',s.tliat onKi*>oiutionsofThanlis,
means for award' Mrs. \V. W W ilt, dl.itinnun; Mrs It. L (JnfTen, Miss
Wry indi-tiniiH.v voted m -v Marui'ivt Kiln riilui*. Mis. .1 M. third nor, Miss t’arrii*
6tli As Mn Latta Johoslou has been appointed Regent oi North la iz m i Miss lMsii* William*. Miss Emily Austin; to
Carolina room m Richmond Museum .1 ...i deemed best to have fount '■ lie vot** at •*l«*f iionf M.s.futlii.art Marfctn.«*hiiir*
her also made Chairman oi the SUtr Committee (or that room " man; Miss M.i.lî* Wthu. Mi** l,i.li Itodmun. Miss
V*s. l.o*. ry Sim for-i
'Plio Metnurlal''x imv .Is * to our dt***ea*pd ttanuhlers
To place the $100 giveu by the stale to tin . North Carolina
of tlu you wi*n* ilii*rt lt*-lil ('iiapti-r* sol.-utrd.v paid
worn, in i»or sta'-c treasury, to be drawn on b'. regent through our
prc.ident and treasurer for current .:xpru*e» oi maintaining the
Intuit*- to liifii* m< nil»M*s who lta\<- erosst-d o* **r tin*
room, and ..uy surplus to be held m the treasury toward., the $2,001' iiwr, and so**nt Mriyor *vas tht.*n held for a few
endowment fund nu iiii iits. rill* Vloinoriii! pttffs vlii*r»* in tin****
M -i.t. s v. h i slum thus-tints tv*tniNnbt*ivd
A i i*.*pt«*J
At tl ■ .'Ins '.,, tin sr . \i*!i*isi-s 11!<• lJn*s.i|i?nt li**au
8th- The President further recommends that ra It chapter send
$1.00 more than tax*. or u>ual obligations to :tic state treasury to
tifully intiodii«*i*d Dr. I*’. I’ Vena hi*.*. IVesi h«ut of tin*
((lmi a inking land, to be Used lor unusual expenses, lor instance St.to* I m i *i spy. who in * loipii*nt touching words
to meet state pledges to general work Adopted. pi*-:td tor till* Mounnifiit to ti," I Joy Soldiers of (>I of *
9th. It wa. deemed bed to dtsehuigc the S-ddrer • Home *'l: i»' Hill. win. titii *.v iisiil. tin ir liooks tird uiarrlmd
Committees till lurthcr work lor that institution seems necessary or forth to w\r. many of thorn never to n-turn.
advisable Adopted
Anitiiuni-.’-uii'ilt m i * lit'," iuiith* th.it tlx linn for UK VhNABt.KS ADDRESS.

lit*- inf.it rid** down ih** river lt.nl airivod tnd tl..* i on-
\cntion .Hiji)urn* *i to mt-t-i Tlitirsd ty inornin« nl 10 (IKOH WU.MINf.TON STAN.I
o’cloi'U, Dr Venable began In short but intcrcstm;,; and instructive

r.t> Mix h k s or rmiM'f kv: ii An n * a» i'r\\i :\t io v .2
r\-ri’KM of t iii (’OM'Ki»i;i{.\rv. <•.7 :2
■5
address l>y congrH u la t tug the Daughter upon their h>-*U im m o ii ,
Hie honoring oi the braver ot the obi riche r ■ and lire cheering of 1 move it lit! every effort be made f-i unveil this monument tn
flic di-appntutrd war md time worn veteran. »nd the prr .i rvii'imi Iftl, the fiftieth anuive.i *ry of the departure .»i tin sc boys for the
of the history of lh«* -tru-Jglc "They arc duties ' lie ...id, "and war
nobly ate you fulftllio.; them. I addrr you today, not ot my own MRS HENRY A. LONDON.
seeking. but rather at your command A tew month' ago l receiv
Mis. Kin.m tln’ti l I’jr-t, to tal.i’ plmlir. s for th*>
ed .i communication from Mrs Kenan a -king Hut 1 -r cure the
j t i niis-icii ut th' trustees ot 'In University t.* er.. t upon t tic Iiii‘11111 ffil. Iilit on inu tit tin* I .ft ol its thst •irniiii'
. jn-.pus a mtmamn l t•- tL students who volunteered to fight in aft-'iUum of tlip - tins vas -toppi'i b.V vrH*\
dele .e ol Hi. Southern Cause 1 In permission was rtadily given
by the trustees f
Hr Venable m.l lldl It •*> u an id opt I son ol North Carolina, Tim i nopt ot tlm *■* >lc*i« rs Home 'otiimtlti*'* from
hut one who loves the Stab is •; native son. He had n en thr.lird
lit- 't ;< to a ml Mrs Ui (h )Io tt;is next tv .1 itml apurovrl.
with the historic store u! the University aud knew ot no stor-, m
history Hut would com par* With it \Th- i'b. ot,. ,»l »’>■■ m-aUm-nt SOLDIERS HOMb. EASTERN SECTION
on the campu- is not i lo it • attn for North Carolina •nd the
Ma PAM PKt.Sim>t tHO U.V e.imKS Ol rill CuM’KOr.KACV.
llinmnlv arc inn parable fh« pan • the es* *1 Instm , ot the
State ire tilled with tin- deed >>l Ifni . rsit . mm He n greitcd Tt. work your Soldier- Horn. Committee during the past
that till records lud been imperfi.tlv kept, and stilted Hut even y>ai has bi«.u tight owiut Ip the tact that it ha*, not tieru necessary
thou di ti e record- an not om, let. the stor> i. <n ...-.po .ng oi... to make an effort to raise money lor tins cause
There were all told more than t 000 University men in the struggle A detailed account ol the work is contained h i Hie report of
between the States enlisting from vancu • S' ales ol the Serai l> md Mrs. K II Brook.. and a financial .utemcni from our State
us of th - number on. thud were killed. least 4d pcs cent of Treasurer, Mrs fcngcne i.ittlc, both ol which are attached hereto
tin students entered t:.« military *<rvict •-.inch i. .. r. -id not Th. work ot Mi Brooks during the . ■•. has been conducted
..puled by any other institution From some of the big Northern with the same ftdeUty and love, tor the cao-e that has always char
institution-, there were 23 pci cent troui University ol Virginia, acterized In i efh't fs aud the Home is now in as good condition as
the npe.it-»-r‘* atm» muter ?s p. ceil. Ol thr-s. oh voli.ti. -.1 w« could dr ir- The improvement in the health of .Mr. Brook' is
Iron- Virginia 225 were killed while oi Hie North Carolinians be gratifying to u% all m.l i! is our sm.crc wish that iic m«y be fully
tween .140 anil 350 ite.er tetinned lionit l'hey laid il. *» lin n re “toted to complete health
lives in the most important h.uHc.s oi the win Although there his b eti no nrgent call upon ns during the past
Ur. Venable said that he would like to sc-c the monument .it y. >t in tn l. .Ii oi Hi Sol.tier II. tin w should hear tin-, great
llu University he. »use it would tilt ch>.|ue:t>iy of II.. sto: y ot the work on out1 hearts at all times and be eve; ready to respond when
-.untie. made by the students j k h to tin. Civil war I hew record nccess.ii y.
-•howl-.l ever t-c before, the « * th- present .lay md. .is Tabtels He sped ally submitted,
have bees erected in memory >i those who lost t' . n l.vesan.l MRS. MARTIN S. WILLARD. Chairman
ihbse who enlisted are worthy at a inomnurnl MRS BROOKS REPORT
\ ■ isittj* voit> ol * li.ittj.s o .is div- t: Or. \"- it mli for Maty a h Pri.MWKT, l>At-i.»m>s m ttl» Cm*. Hike Air.
in-. fXft'Mi-nt :t>illr*-ss As onr rep:eseittati • • at the Soldier- Ilf I ■ uh ut a report
ol such matters of interest during the past year as have come under
'ritls iii.ilioM w is ili«»n u. nit ami irarritMl
iiiv po oua 1 or .mmed.it*- • api-rvi.ton the Home about lulj
EXHIBIT M
\\
\
\
U3Q5 f*\>ruLT7 28, 1510,
lire J*c«* d. I't j is ,
Tallac*. *. V
Dear Urt learvir
I than'* for your kind l*tt»r of fsbruary 2i*t Hi*
Rj-a jhctctrr*^ hav* b**n reo#l»«d end X will bold tb*cs for th*
Cf th* Cxsltt**
i ■*■. «vil **ry rsich la favor cf tba Deaton c**len If w* cor. po««ibljr
*a»»* t«i ’ey 1 etyert yen art rlrr.t about th* ena.>c«» in th* dl»*c*ion*
• f • h» jwa»*ta!
S? devlr* ia rtfard to thl* sen rant ii to b»»a It Bj~w*r not a* a
t i» • tie dead vet to a nobis idsal and a* rotHier th* horde porlod
r th* Ite'.ntiMr y hlttory I hoy* that tJ» OccritteB *111 as»** with e*
tc thl*
V.th rs-.r.rd to t.'je oheok *uoh yun to kindly otcloiod, I hoy* yru will
j*rr”.t re dovote thl* te th* ace aevnt And* frea th« taak of *r**ob-
mawirg «fci<tfc :■ »iway* a j »;t «**:u ; on* to ct 1 neatly *nJoywd ey Tl*lt
V. T Ir-i.-.- t r. aai 17 r*»tlRf: with y.o ard lh* ladlw of th* 0. D 0
I *3411 * g2 id to b* *t yew Movie* at any ti»* »jth r*onl to thl*
■t »r • '■taer satter
81noer*iy year*.
(//a 1, a
Exhibits - 42
EXHIBIT N
(from https://en.wikipedia.org/wiki/John A. Wilson (sculptor)')
John A. Wilson (sculptor)

From Wikipedia, the free encyclopedia
John Albert Wilson (1877-1954) was a Canadian sculptor who produced public art for
John Albert Wilson
commissions throughout North America. He was a professor in the School of Architecture at
Harvard University for 32 years. He is most famous for his American Civil War Monuments:
the statue on the Confederate Student Memorial;Silent Sam) on the campus of the University
of North Carolina. Chapel Hill, and the Washington Grays Monument (Pennsylvania
Volunteer) in Philadelphia.
Renowned sculptor and art historian Lorado Taft wrote of the latter work, "No American
sculpture., however, has surpassed the compelling power which John A. Wilson put into his
steady, motionless 'Pennsylvania Volunteer'."^- Wilson created his studio (the “Waban
Studio") at Chestnut HilL Massachusetts. Walter Gropius , known as a pioneering master of John A. Wilson sculpting Washington Grays
modern architecture, said the studio ''is the most beautiful in the world."® Monument (1907)
Born 1677
Contents [hide]
New Glasgow, Nova Scotia
1 Life and career Died December 8,1954
2 Death New Glasgow, Nova Scotia
3 Works Nationality Canadian
3.1 American Civil War Known for Sculpture
3.2 Firemen's Memorial, Boston Notable workSilent Sam, Daniel A. Bean,
Washington Grays Monument
3.3 Harvard University
Movement American Renaissance
3.4 Nova Scotia
Awards Kimball Prise
3.4.1 The Lion Series
3.5 Other
3.6 Image gallery
4 References
5 External links
i
Life and career [ edit ]
He was bom in New Glasgow, Nova Scotia (Potter's Brooki, son of John and Annie (Cameron) Wilson. His grandfather was a
stonemason who emigrated from Beauly, Scotland.^ Wilson attended New Glasgow High SchooL At the age of fifteen he
created a sculpture of a lion out of freestone (1691). W
In 1896, at age nineteen, he went to Boston to study art. During the day he attended the Cowles Art School of the Museum of
Fine Arts, Boston, where he studied drawing and painting under Bela Pratt. He worked in the evenings as an usher in a
I theatre, and he worked on the weekends as a professional boxer at the Boston Athletic Club. While at the Fine Arts school,
Washington Wilson displayed his work The Crawling Panther (also known as the Stalking Panther> at the Boston Art Club (1905). He
Grays
received attention from the Boston Globe and Boston Herald newspapers for this work. The latter wrote that it was a "powerful
Monument,
Philadelphia work by a very young man'J5- He graduated from the School of the Museum of Fine Arts, Boston m 1905. He next worked as an
assistant to Henry Kitson. •6-
r-’
Exhibits - 43
Beginning in 1906, Wilson taught classes for the Copley Society of Art in Boston.^ He joined the board of directors in 1913 and taught there for
32 years until 1945. In 1927. he was named Director of Classes.^ One of his students at the Society was John Hovannes (1900-1973). ^~J
In 1917. Wilson started to teach at Harvard University when the scholarly Abbott Lawrence Lowell was president. He was appointed Instructor
in Modelling, School of Architecture, Harvard University. He served at Harvard for 32 years, retiring in 1949J10j During his tenure at the
Copley Society and Harvard, Wilson also taught in various other places.
Wilson taught for 5 years at the Worcester Art Museum (1917-22), where he would complete the Hector Monument (1923) with his student
Evangeline Eells Wheeler. t1 *•' He taught one year at the School of the Museum of Fine Arts, Boston (1921-22),three years at Children's
Walter School, and three years at Bradford College. He also taught at his own studio in Chestnut Hill.
In 1913, he had built his home and his "Waban Studio' at 101 Waban Hill Rd, Chestnut Hill, where he lived for 36 years. After 50 years, when he
retired, Wilson returned in 1949 to New Glasgow, Nova Scotia. He lived there for five years at East River, Potter's Bridges, New Glasgow,
[citation neea'ed]
Death [edit]
Wilson died on December 8,1954 at Aberdeen Regional Hospital, New Glasgow. Before his passing, he donated property to the Aberdeen
Hospital. It was later replaced by Glen Haven Manor now stands. A plaque in his honor hangs in the Hospital's cafeteria, He is buried m the
Riverside Cemetery, New Glasgow, Nova Scotia.
Works [edit]
American Civil War [ edit ]
The year after Wilson graduated from School of the Museum of Fine Arts, Boston (1905), he received his first major recognition
when he was commissioned by the State of Pennsylvania to make the Washington Grays Monument in Philadelphia to the men
who served in the American Civil War ^14-
In 1909, Wilson's soldier's monument for all soldiers of war was unveiled on Dudley’s Town Common (in front of the First
Congregational Church), Dudley, Massachusetts. A crowd of 1200 was in attendance.-1^ Four-sided and capped with the
sculpture of an American eagle, the multiwar memorial has inscriptions for the American Revolution: "To the memory of
John A
Dudley's Heroes who bore arms to found an Independent Nation - 1776": the American Civil War: "Her Patriots of 1661-1365 Wilson in
who offered their lives to Preserve this Union”; and the Spanish-American War'Philippine-Amencan War: "her soldiers in the studio
Spanish-Philippines War, 1373.” creating
In 1909, Wilson created the "Massachusetts Monument" in the Baton Rouge National Cemetery. The commemorative Washington
Grays
monument on its grounds, was erected to honor Massachusetts sailors and soldiers who died in Civil War battles in the Gulf Monument,
region. The granite monument is inscribed with the names of the Infantries and Light Batteries that served in the Gulf theater Boston
of operations. Massachusetts Governor Ebenezer Sumner Draper attended the proceedings.
In 1911, he created a statue of Private Daniel A. Bean of Brownfield, Maine, llt'n Maine Volunteer Infantry Regiment. Major Sylvanus Bangs
Bean--C- served with the 11th Marne Regiment along with his son, Daniel A. Bean. Daniel was killed in Hampton, Virginia as a result of being
shot in both thighs dunng the war. Daniel died before his father Sylvanus could see him at the field hospital. Daniel died on 06/06/1364 and is
buried at Plot: D 2820, Hampton National Cemetery, City of Hampton, Virginia. USA. The statue of Daniel Bean stands in Brownfield, Maine,
where the roads to Hiram and Denmark diverge. Of all the Civil War memorials erected by Maine towns, this remarkable monument was the
only one cast in the image of a real person. The absence of weapons distinguishes it even further. The boy stands as he would have on his last
day at home, taking the Oath of Induction. [IT]
Exhibits - 44
In 1913. Wilson was commissioned by the North Carolina Chapter of the United Daughters of the Confederacy to mate the Confederate
Monument (Silent Sam) for the students of University of North Carolina at Chapel Hill who served in the war. It was the first major work
Wilson created in his new "Waban Studio". At least 40 per cent of the students entered the service, which is a record not equaled by any other
institution. Similar to the unarmed statue of Bean, Wilson created a 'silent" statue by not including a cartridge box on the Confederate soldier
belt so he cannot fire his gunJ-~- On August 20th, 2015 a group of protesters surrounded the statue and tore it down, one person was arrested,
the University made a comment understanding the sentiment but not condoning the actions and vandalism.-1^
Firemen's Memorial, Boston [ edit ]
pa
Firemen's
In 1909, Wilson created Firemen's Memorial (Boston) for the Firemen's Lot at Forest Hills Cemetery, Jamaica Plain,
Boston. Each year on the second Sunday in June, memorial services sponsored by the Charitable Association of the Boston
Fire Department are held at the Firemen s Memorial at Forest Hills Cemetery in order to pay tribute to deceased members so
they would be assured of a decent and final resting place and they would not necessarily end up in Pauper's Field.
Memorial
On a lofty granite base a larger-than-life fireman in bronze, attired for sendee but in a moment of contemplation. On each side
of the pedestal were set bronze plaques, 3 ft. by 4 ft., depicting the life of a fireman in the spirit of a renowned set of Currier &
Ives prints. Shown in vivid bas-relief were horse-powered equipment and men en route to their duty. The plaque on the rear of the statue
pictures a nineteenth century pumper as it would have looked between fires in the firehouse with no horses, men, or background. The memorial
was dedicated in grand style on June 14, 1909. On that day, set aside in all the state for past firemen, the memorial was dedicated in a ceremony
partially presided overby John F. Fitzgerald, grandfather of John F. Kennedy and former mayor of Boston
Harvard University [ edit ]

While teaching at Harvard University (1917-46), Wilson made numerous sculptures of figures connected to the University.
Perhaps the best known figure is the Janitor in the Fogg Museum entitled ''George’’. Articles with a photo of George
Archambeau were printed in both Time Magazine and the New York Tunes when the bust was unveiled in September 1932.[22J
Wilson also made two busts of William Crowninshield Endicott, one in the Fogg Museum and the other in Harvard University
Law School (1932). Wilson also made two busts of Harvard president Abbott Lawrence LowelL One is a marble bust in the
Faculty Room, University Hall (Harvard University) (19-30)^:- and the other is a bronze bU3t at Lowell House Residence,
Harvard University^4} Wilson also made the mould for the commorative punch bowl and dishes for Harvard University's Abbott
tercentennial (1936) J2^ Lawrence
Lowell by
One of Wilson's most famous Harvard graduates was sculptor Wheeler Williams who wrote to him. John A.
How very lucky I was to find myself m your class in the basement of Robison Hall. If it had not been for that, classes at the Wilson
Copley Society of Art and Sundays in your studio, I fear my life long dream of being a sculptor would not have materialized.
Where anybody today could get the sound training you gave us, I have no ideaJ26’
Nova Scotia [ edit ]
The Nova Scotia monuments were made in the same year (1923). The Hector Pioneer was made in the Worcester Art Museum. Wilson’s assistant
for the work was Evangeline (Eells) Wheeler. The sculpture was unveiled 17 July 1923 on the 150 Anniversary of the arrival of the ship Hector.
The Governor General of Canada Field Marshal Julian Byng, 1st Viscount Byng of Vimy led the proceedings.
Exhibits - 45
The Lion Series [ edit ]
Wilson made a senes of nine lions in freestone early in ins career. The location of siz of these liens is unknown. Three of these
lions remain in Pictou County. Nova ScotiaJ-,J One of the lions is on the grounds of the Lionstone Inn, an establishment
named after the sculpture -"'* The other two lions are at the Carmichael-Stewart House Museum. One of these Wilson made at
the age of 15 before he moved to Boston (1591). The other lion at the museum Wilson made while studying in Boston (1902). The Carmichael-
sculpture representing Great Britain in South Africa during the Boer War and was noted as being "an admirable piece of Stewart
modelling from one of his age" J~s-! In March 1902 the Royal Canadian Academy of Arts accepted this lion for its annual House
exhibition in Montreal,^0* Museum.
New
Other [ edit ] Glasgow,
Nova Scotia
. Monument on the American Civil War Antietam National Battlefield. Maryland
. Major Henry Gustavus Dorr, made at Grundmann Studios (1915)
• William Crownmshield Endicott at the Harvard University Law School (1932) ^
. Death, mask of .Admiral William Sims
. Soldier's monument Dudley, Massachusetts
. Massachusetts Monument, Baton Rouge National Cemetery, Baton Rouge, Louisiana
• Abbott Lawrence Lowell, Marble Bust, Faculty Room, University Hall (Harvard University) (1930)^;
. Abbott LauTer.ee Lowell, Bronze Bust, Lowell House, Harvard University^0*
. "Dancing Figure", Algonquin Club, Boston
. Symbolic Panels, Brookline High School, Boston (1923)
. "Panther"
. "Stalking Panther", Boston An Club Exhibition (1905)
. "The Chase '
. "Goat", Sandy, Poland Spring, Maine
• Alexander Forrester tablet. Nova Scotia Community College, Truro, Nova Scotia^* (c. 1923)
Exhibits - 46
EXHIBIT O
2r3 Jclm filaa&o .

400 lorthampton fltc.
Button, lfaak , t
Jfc&r MTo Tilaona

On my return bon* fwo Suropt X found oertala Ifttera from Xrs.
Londun^ and slab w in receipt >f yv-ix sha-jg* of design fcr the noatnaat*
1 flc not wl on to write ataut thwt n**ter«„ however0 thip me mins Vat to
$'.*(• to you the •'sat- - r Vhlnl* 1 find in ojarodtton with the
l A 6cnvtr«atl»« "^th 'low who i* me oi the fraiUx aud

* w-w ft uf the :&uraufct Conti 1 tee„ Va find thr.t the Udiei of the
sctriHec only * « Vw/4 ftt K«««nt aw are We in* their u.
^-*<,1* Wooi ?£■«« tU aonweatlon ofthe O aughtera of the Bonfederaoy thie

fail- a *rocteev G«w>r»l J unwilling to *Jgn a .contract, and ha
adv.eei a* that an frc«&t*Qt of Va Onirereity X ounot lign ft ocntmot
.U»h TOli lDMl*. U» r fltttoO!*!
\ only V« den. by pamlee-ion of the Cmcil of ft&tt under the not of the
X*gi»Uiure. *0V» X «a *1together BUlla* that you ahculd exp** and
BOXkVf
** Mamal w*lMa 1 oca leaxly ate Wore me the fnnda from
I
XW
which 7°a wa to Ve repaid • a •* detain** «*t ha moment .hall he
Ii*
Exhibits - 47
IL' •tata Tilin
ill* MIQ?
ter* *#t :* r. -* *i*'V.ft nJl u o Ux u x m tot Partter enUtttiia

at Pu u m cut j ;j • *- -.d *»•<* » oontewt lt>r jour work mi 1 m &i )
atgs rack & wiml until 3 PH tti bmmj titter al\og»Mmt m ttert n*
t; r*ij to Mat. IUi nuu i itPpurrui Hittk 1 grull; npit toil It U
*
•tv nit7 affect >f te iftlto 3 ocult l*sd nj
X ft* furry tiut 1 Bin** you ttea y: ntltel tte Bnitonaty nod X
top* ▼*?!■ wach W*t | U toitotf ixftfw turing iha y<mr uA »rtl
Uj-fii jra» :■ 5‘our *w*U
At l vrctft r* l» M <Kli* 1 torn Mtlng only u u mat ft>r
taw k s k i Uh afipolt^ tj 1M hagMirt of tte Qoa/iliruj tot if tte
raftyoteiKlity tf It «1 t« to ti Um»i d i m Iw i only tote tte oavtt
it .-ttllTttfti in *M* Utter-,
1*0 Vttly jaaxa.
ftMltnl.
Exhibits - 48
EXHIBIT P
* HBH v fK
' • ‘
/ . .
■«
. *
•' • * ' 5h. «-
:' V/'
r‘ -- ?s
4 4
v
j
•V •J
46657 Bepfc. e, 1910. •
*
\s
v' 1 Ur, John Uilaon, I

»• . J
40:- northanptcm St*
.Bouton* I^-oa. r
v*.
Be r Ilr. V71Inon«
§:? »
Your letter of A«Gant .09th bon been received. 12ro.' London ms raio-
> .• r
%■ ' toiem in the idea that the University «a to famish -eay .port of the nonoy
I ,
for the nioisxnent. It in hardly jjroWblofliat those who havo the appropriation
m
•v of the Univerity funds in'tend would oonoont to any diversion of the State
.! \ funds fra-, the direct mlntonanoo of fan Institration.
ft
m.
V
I had baaed ny hopes on a lare^* contribution fron oiia wiio 1 thought
I’
wan finaxAy intereoled nod me Troll ahlo to pay the .larfioot ]^-xb of the en-
. pansoo; int oo.far I have been dioanpolnted in this. if
• - . Her? tho taattor xoaio Just aa I told you in try last letter. The lalioo
of'the- U.i.V. Con -ittoo will use every effort to ro&o their oolitatVua' onfi
xnaaaThilo I Shell enter upon the ovroolsn end Corny bort to raioo iho ncooo-
oary foods• I am unwilllncj that you should (P to' farther esjvmoe wifi the
‘z* uncertainty involved in such cubocriptionn rend oolleotiono. The lruSieowill
*
probably have to abandon their plan of the fio> ication of the nonroent nert
-
oprinc.
^ if you will clve pc a 'ctatci.-'nt no to the amount of expense already
*
Incurred 1 will son that you oxo rcir.buropd out of t'.rt flroi fftfcdn oolloctod. t-
1
Very truly yours.
i
< «
|
' •• - \ President.
■ / •v
Exhibits - 49
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Exhibits - 51
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Exhibits - 52
of1 /£. -r' l Z-,—-7 Z^ff 0*L
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Exhibits - 53
EXHIBIT R
.
*9196 Jttna 19, 19114
i
I
tot Jloncy a . Loado^r

mtahojro, H, C„
JhtiT Mrtk London*
1 «»1c b « a latter and occtraet received to-day toon Mr- John fflftacm.
Wcaue road this over and *«e rtuthor tha fora and all too entirely aatio-
factory to you*
2 have m b need that yes wold prefor the btoinoaa and of thJa to to
1 handled ty aa, but It la entirely eatiafaetoxy to oa If you wiab to alga thia

oentreat and to have tha sade by tha fraaanror of the 0,I/,0»'8. In
that eoaa, to. London, «ho its tha aeoretary of the airmail association, ooold
taaito the oolleatlcmn Cor the altmoi uaoalotion and turn over tha mendJt to
year treasurers X hate sewed a few subscript! on* since tha eloce of tha
m salon or.4 would tarn over all fuada in my hand# to hln. Either method of
hisdlino thla matter will he satisfactory #o t&s aa 1 as oonoarnad. Of ooaraa0
to Bison understands that ay signing this do«« not hied tha Uulvereity nor
nyself per»or.nllyu
X hone that yoa can arrange to coca o«r acre tine socn and Ulh over the
location of the nor.icentj alad eaoh ohaasea in the dsslsn aa you h.id thought
if last fall or a* cay oocor to aa- X notice in the oentroot that to. Wilson
Exhibits - 54
i
H. A. London.
**B*®«1» one of t»oJ*ladj of iiraolt* Of ©earn,

* CiUJlo* worsia hare to be
Bode *W “* *“»• «* I Ml M e Im A to Iu t p
yoxi mw . •vaR “'-*7 »!** ui who&
*• Set *11 ibo JotaAl*

»*ttled i think it wmM be boot for aw to
Boston and explain
,a j»r.<m to Mre «2*o»0
d! Merely your#.
Exhibits - 55
EXHIBIT S
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Exhibits - 56
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Exhibits - 57
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Exhibits - 58
IP/n/njh}
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Exhibits - 59
EXHIBIT T
/
/* •
n
rZ>'# Oa-<
. / <*<«. <f
REVISAL OF 1905
OF
0+
NORTH CAROLINA
PREPARED UNDER CHAPTER THREE HUNDRED AND FOURTEEN
op t hk t .a w s np n\g TiinrsAxn n in p .
HUNDRED AND THREE
BY
THOMAS B. WOMACK, LL. D., NEEDHAM Y. GULLEY,

WILLIAM B. RODMAN
AND ENACTED AS A LAW AT THE SKSStON OF THE GENERAL ASSEMBLY
OF ONE THOUSAND NINE HUNDRED AND FIVE
0
IN TWO VOLI1MRS
VOLUME TWO
nnar-H
I'jK <1
UH
* » .* —
* ; -
Exhibits - 60
2091 MARRIAGE—HI. The License. Cb. 50
tion; in the tenth, the place of the celebration; in the eleventh, the
names of all or at least three of the witnesses who signed tbe return
as present at the celebration. The original license and return thereto
shall be filed and preserved.
Code, s. 1818; IBM, c. Ml, a. S; 18712, c. 103, a. 9.
2092. Penalty for failure to record license and the return.

Any register of deeds who shall fail to record, in the manner above
prescribed, the substance of any marriage license issued by him,
or who shall fail to record, in the manner above prescribed, the
substance of any return made thereon, within ten days after such
return made, shall forfeit and pay two hundred dollars to any
person who shall sue for tbe same.
Code. a. 1810; 1871 2, «. 103, a. 10.
CHAPTER 51.
MARRIED WOMEN.
StcUoss.
L Separata estate of, 8003—2101
IL Eights sad liabilities of husband*. 2102—2106
HI. Contract* between husband and wife, 2107—2108
IV. Divorce and separation, 2100—2111
V. Free traders, 2112—2118
I. Se pa r a t e Es t a t e of.
2083. Secured; disposed of by will; conveyed with husband’s

written assent. The real and personal property of any female in
this state, acquired before marriage, and all property, real anil per
sonal, to which she may, after marriage, become in any manner
entitled, shall be and remain the sole and separate estate and prop
erty of such female, and shall not be liable for any debts, obliga
tions or engagements of her husband, and may be devised and
bequeathed, and, with the written assent of her husband, conveyed
by her aa if she were unmarried
ComL, Art, X. ». 8.
Nets. For purchase money mortgage executed by husband alone, see a. 3093.
2094. Can not contract without husband’s consent No wo

man during her coverture shall be capable of making any contract
to affect her real or personal estate, except for her necessary per
sonal expenses, or for the support of the family, or such as may
ew
Exhibits - 61
2084 MARRIED WOMEN—/. Stpanle Estate. Ch. .“.1
lx* necessary in order to pav her debts existing before marriage,

without the written consent of her liuwhaud. mile** she be a free
trader, as hereinafter allowed
Cod*. ► 1**6; 1871-2, c. 193. .. 17.
Nwt«. K«r Utiuirr’ii »i><] tn«l**ri«l lien* »«•* •- 2Ul(k
2095. May draw checks. Rank deposit* uiade by or in the* uaxne

of « married woman shall be paid only to her or on her order, ami
her check, receipt or acquittance shall be valid in law to fully <I»>
charge the bank from any ami all liability on account thereof.
1881. C. 22t, «. 30; 1893. c. 344.
2096. What leases require joinder of husband and privy exam

ination. No Iqn*: or agreement for a lease or sublease or assignment
by any married woman, not a fr»v trader, of her lands or tenements,
or chattels real, to run for more than three years, or to begin in pos
session more than six months after it# execution, or any conveyance
of any freehold estate in her real property, shall be valid, unless
the same lx* executed by her and her husband, and proved or acknowl
edged by them, and her free consent thereto, appear on her examina
tion separate from her husband, a* is now or may her*-after 1**
required by law in the probate of deeds of femes covert.
Code. a. 1*04; 1871 2, c. 193, «, 26.
2097. Land of. not sold or leased without their consent: hus
band's interest exempt from execution. No real estate belonging
at the time marriage to females, married since the third Monday
‘■t Novemljer, one thousand eight hundred and forty-eight, uor atn
real estate by them subsequently acquired, nor any real estate
acquired **n and since the first day ••{' March, one thousand eight
hundred and forty-nine, bv femes covert, who were such on the
said thin! Monday <>: November, one thousand eight hundred and
forty-eight, shall be subject to be sold or leased by the husband for
the term 1' bis own life or any lew* term < i' years, except by and
with the consent *.f his wife, first had and obtained, to bo ascertained
and effectuated hv deed and prtvv exam I* nation. according to the
rules required hv law for the sub- -t land* belonging to femes covert.
And no interest o: the husband whatever in such real estate shall
lx* subject to -ale to satisfy anv execution obtained against him:
and every such sale is hereby declin'd null and void.
ro.lr. * 1*40; R C\. * Afl. 184*, c. 41.
2098. May make a will. Every married woman shall have power
to devise and bequeath her real and |»er*onal estate a* if she were a
feme sole; and her will shall lie proved a* i* required oilier will*.
Co4*, «. 1830; 1871 2. c 193. I. 31.
ftIO
Exhibits - 62
EXHIBIT U
PUBLIC LAWS AND RESOLUTIONS
or Tn«t
STATE OF NORTH CAROLINA
r*A»jrn nr rn»:
GENERAL ASSEMBLY
AT ITS
SESSION OF 1911.
OEGUN AND HELD IN THC CITY Or RALLlOH
ON
WEDNESDAY. THE POURTH DAY OF JANUARY. A D. 1911
PUBLISHED BY AUTHORITY.
I! A LEIGH:
K M. L’mi-I. &. CO.. STAT»: PRINTER*: AND BlNOKhS.
ttJJ.
Exhibits - 63
272 lhll—Ch a pt er 107 10b- 1 On.
Compensation to jo lieu thereof lilt* words, "The coinpeiisiHiou of the Sjupreuu-

be fixed by court.
Court Reporter shall uot exceed fifteen buwired dollars l*er «n-
nnni. to be fixed by the Court."
Six. 2. That tills net shall be in force from and after Its ratifi
cation,
Ratified this the Util day of March. A. D. 11)11.
CHAPTER 108.
AN ACT TO AMEND CHAPTER S30 OF T11E iTItLIC LAWS

OF 1007.
Tin: (laicrut Ax.saitl/lij of Xorlh Carolina tlo enact:

Se c t io n 1. That, section live of chapter eight hundred owl thirty
of the 1'uhlie Laws of one thousand nine hundred and seven be
Chid cierf ro and the same is hereby amended as follows: ity striking out the
auditor. words 'Vighteen hum!ml," in fine three of said section, and In
serting in lieu thereof the words "livu thousand."
Sue. 2. That motion ten of diopter eight hundred and Lhlrty
of the I’uldie Laws of one thousand nine lniadml anil seven be
tjcpun insur.iMta* nud (in* same Is hereby amended as to I lows: Hr striking out th*-
comimnsldner. word "liftoeu," in liuc four of said section, and inserting in lieu
thereof the word “eighteen."
Sti. That all laws and clauses of laws In conflict with this
act are hereby repealed.
. Sk i \ 4. That ibis net shall lie in force front and after its rciLlH-
cation.
It a titled this the Cell day of March, A. IX 11*11.
CHAPTER 109.
AN ACT TO AfTHOKlZB MARRIED WOMEN TO CONTRACT

AND DEAL AS IF T’NMAttlvlED.
The tieneml Assembly of Xorlh f'urolimt do enact:

Se c t io n J Thai section two thousand au<l iilnety-fuur of the
Revival <>f one thousand nine hundred and the he and the Paine is
power of married hereby rejicak'd. and the following substituted therefor: '‘That,
women to con subject ii. the provisions of section two thousand one hundred
tract and doal
with property. and seven of the Revisal <,f one thousand nine hundred and five.
every married woman shall bo authorized to eon tract and deal si
ns n> affect her real and personal projterty In (he same manner
conveyance oi awl with the same effect ns if she were unmarried, hut no eon*
i«U eslfttc.
Exhibits - 64
1012—Cii .U’T hi: 1.09— 110- 111. J7.‘5
veyance “i lift- real estate shall If valid unless made with the
written assetif of lier husband us provided Jiy section six <>f article
ton of Jin* Coustinuhni, ami her privy exaiuluatinn as to the ext- P«v> •wamtua-
llOll.
ctitiou of the satin taken anti certified as now required by law."
Si.( 2. That this act shall lu* la force front and after its rutitl-
i-atioii.
Unlik'd this the 'itli day of March. A. 1*.
CHAPTER 110.
AN ACT TO AMBNO ( IIAn i.rt MCI OF Till*: IT BUC LAWS

OF 11KJ7. KllLATIVE TO THE SALARY OF THE AD.IKTAN'T
t.'KNKKAI.,
Thv Ocnt'rai I HMruiblji nf \'<n th Corolimi <lo vii#et:

Sm t io .v I. That chapter elsrht hundred au<l three of the Full lie
Laws ut Ninth Carolina, so-i.m > t on. thousand nine hundred
and seven, I** into) the same is hereby amended h> striking out
tlit* words "sixteen hundred.” in Him * lour of section one of said
art. and iusoittii^ lit lieu ther.-.f the words “two thousand.' Salary 000.
Sk i That this act shall »»• in force from and after Its ratifi
cation.
liutlthd this the dlh day of March. A. O. lull.
CHAPTER til.
VX ACT 'in A.Mi;\0 THE OLNKKAJ. L\SI RANCH LAW.

cn.\i-n:i: ion o f t h e l k v is a l o k im>:, u k n o r t h CAR
OLINA. IN RECARO To CLASSES OF IN'SKitAN't’K.
J I" nr/iii ts Min hi if of \;rth < oiothio do r««r#7:

Sm iio .x l. That sift Ion four tlmtlsjind seven hundred and
twOdy-KlX 1-tTitO of tit.' lb visa 1 of one lliotisand IIIue hundred
and five ol North Carolina If auendid to read as follows;
b'unufl tunin' urtith'* nf ot/i'n mi nt; tuMfUtnl It, Ii Hk Ih i -n s tt/it cl- Formation ot
finl. Insurance eoiiijia n:< s, assocIntitnis. ».r orders may Is- formed . <wi:<iiide«
as provided in the next two sn-eeetlimr sections for any one ot tin*
follow hit: purposes, to wit:
1. 't o Insure nuninsl loss ..r damage p. pr.-js-ny hy (ire. lieht- lToj.i>uy Ir.sur-
aiws*.
niuir. wind. hall, or tornado, use mid occupancy, mid for nuiioceu-
tmtu-y. itpuii the rimk or nintnnl plan.
-■ To insure upon the sro. Ic or mutual plan, vessels, freights. Mnrim- uisnruncu.
ij o ih Is . money, .-ifeets, and lUPt.cy lent uu huttiimry or rctjmmh olio
1*1,11, — 1S
Exhibits - 65
99 - sijqnpg
» MCI
Ms "•
m jo aapcw «T%
PW «9 •I w *w tm p » ttotiii *« 0% *w» um i
°W»ox3 liM K a* aomvmvMTv m m imfua* ‘w*
n *A«| tw* »• JC8TO x WHIH nonwotiffft UM o o t w j o i m o
-•IP •CM *l m «r «* j« imwi m autf
IW >** mn «<• nn <* «*o MO no/ w odoq x
“mm-** putto mi jo
po* pxpp»«w) o«*j °q *a jo ooiMolMf «cp ttpo op® "loo/ gurnoo
9o mb » r. Oft 00|M 0% BWTtood /xim * «*•(■ %j
woo or tr? /f«0Jr» »T imoao apft j* Jt^ «*W Moot *w*% piVMJOpa |
*009*# %ooot M oofM •joodn* ®o®ttcii «rv m u ^ j »poaj «& jo uon
*» 40J MOJJ* £uu xiwaj ycd 0\ «o u tsm •* TO* 01 ftM*0 m
» 01 jo 0000# *•*• Jtoj *P0BJ "*0 » 0008# WWOHM
m iw«it» m or* poa* ^ ®0 P*l* im no/ «ocoi j
laopaoi •«* my ip
•o #t <ouxncu
°T Atm| *M|
°TMt *9 ; cato
a xmiHxa
EXHIBIT W
Turn .tanssscm, wide im « X, ■ 3 to? Of June A.D. MU, by rad

beteeen jo h h ffltuO*. anulplor of Boston, fc»»*M>ra"»tta# of tho flret port ,•
rad
«r
of the oooond part, *JtaHirtW
The* tbs party of tho flret port, for iho consideration hereinafter aoa-
Honed, **sr*e» vith the p»r»y of the eeoonJ port to p»rfors In a faithful and
oorfcaanlike oanoer the follovlos spool fled eert. Till
To erost a aoTr-isiwst on the College Ground* at OJwpoi Bill, H.C. Bio d*-
ijpi qonelntlss of a ficuro la Drome oicht foot in height «mp?nr*ed by a Oroo-
Ito Pedestal of « design heretofore shooti la a »k«toh »t»bam*i to th* Ooanlt-
too. Bio front of tb* Pedestal shall War a bronse panel 48 in. x TS in. *ith
l*o flour** in r«li«f no ahom in the aiotah subeitted. On the JisBber bolov
and aloo on th» front or tho Pedestal shall be lsaiaed tho Inscription "Sroot-
ed under th# auspices of tho Sorth Carolina Division of tho Dnltad Daufihtora
or tha Confederacy.• Th* tna'l of tho dla shall boar a tablet. Tho tablet
oontelaliv biatorlaal data. Thla tablet shall be of applied brense. The an-
tiro deetim throughout to be oarriod out ao shnvn in oufemtod sketch annopt
for ouah cham-ss e« shall be Bale for the lirproTenant of tho oonuaent. Those
chinas* boiivs reooaneadet by the Cosatttse. the fleure and »*o praols ahall
bo oaot in 3. 5. Coveriwent Standard Bronso. Tho Podostel or crey arenito or
•Balfour Fink* 5ra.1lto. A suitable oenoroto foundation ahall he oeiurtruatod
and the Todeetal erooted ea it. The brome figure and praols fixed in jilaoo
as! tho somount ©ocylsted for unrei 11 ryj. Tho entire work to bo ueoutod in
an artistlo rad voriaralifce sanasr subJout to the approval of »h« party of
the second ;«rt. lad la addition to the above to seccne responsible for all
tutorial alloyed or used la the osld vert, ahioh in to bo aossenoed tho fif
teenth day of June A.B. 1811, rad Deleted free froa all neohsnlo or other
liens before tho t*wh?-ni«th d«y of Be- A.3. Ml*.
And the party ef tho nsoorrf part agrees eith tho party of tho first part
in oonaldaritloa of the faithfbl perfornanoo of tho above spoelfied sort to
pay to tho party of the first part Bio gem of n«r«n thousand five bundled dol-
laro(»TMO.OO), as followet 0*8 *K»35A3fS »1* jnar«Sfl MUASSt 1800.00) on the
alsalcs and delivery of thl« oeairuat. Too thousand d«llars(8000.00) *b*n
*odols are approved, oraploto and ready for the bronso foundry, and the ro-
ilolns four thousand doUrero to be peld on the oo.*?letloa of tho sunk.
Tho ooulptor shall give hi* peroonal suprfvlsien to all tho sort.
Di WT3J3CT YWtHar, *» hereunto sst out hond« and aoala on the tiny as!
year flrat above vrlttoa.
Sioouted In preserve of
),
Exhibits - 67
EXHIBIT X
59663 March 29,1913.
Mrs. U.A.Ii'-iuluni
V|vtabano, N»C«
' r.1* r Urn. Lonilnni o aha?, ontt OB Unno
In th- *u.fr,n:* of dnara-ntl^rtn,
I hr.vn ia letter frora Mra. 2112lomc about the j.rujjraau
I tr;*nk vim nsnr»aIo«a should b» not lender than .on hour mu an
fcelf nt‘ tnr ontnlda, Thorn nru oo ?r/.r.y lufrlr.n ht.i']t**nfn£ ir. Cot*-
Roncsf^nt «o«k that It !■ difficult to Hold on tuJianao for s
longer period than that. Of courai, If you dooir-> ft, J *hfcll

I
ha *Xii«J to pronlU* ovon thn oAorolaou *nU iwko a fan infer'**.
♦ *
4uotorjr wnarks which will ho If ml tv., to two or throe nfmitnn,
M**n, ’/l Allr.mw suQ^wato that both you und hornolf ohculd m*y
nomnthJftft me thnt otrike* r« t.a {•'Hntmtiy appropriate, X d-jubt
uhefhitr It noul.i ho hotmror, to hnvo cjty other npoooh in
nrtriltl'in tc thons than the rno to l»*» 4.trlIvoreU by Govern r C?*.i£,
Jlr», tfil.tlanu mifrunin Cclor.nl Bra<4faet mid you have nphtlonod
Kejor Ftodrnn, hut I fnol euro thr t It «oti2rt be wlanr for u*» to
rent contort with the rrogrm» an nminru t&ovo. •if
TJjw next 0*«*U»m Jet uo «,c. cstmibna nhr.u*d
• V
** •;* -
---
»•-
Exhibits - 68
[fr-at Z4,r'ii3]
cb*«l* *>t% Slid. Pnr-fin«lly f tluil H *cul>t b* i * vj
!»•/-. * r ■/<■»*.*■ In th* eUnjel tt-,.1 ‘.roc*i*t4 fro* Uwri ?.o t,»u>
■wumwwrn*. 'Cf U>* «r|BTft!ltat« It. vUl it* clfflfluit .* pm n./ fer
t ;4 (f tfin a-Urtlnnrw our-ff-3 «tad alt* tlfTlcu.it. ter
t:.* ajjd|*ne- tv ha«r aayfcMtir i' - <u.u.
Ti*. etttli «u h Jc by !*■?* tv"■wmaartwfli o* kpj.,

* <» I si* Bt. r r«t« ’.07 -« 0»u#d tarry fttft Urn. wt *,>■«»• *U£«*
f, < il r ®f itnclnf* hy khv CJ.ft* fllttf, *.* tutu iiu^c nfft&itl m »«
\:rn In p-'^h yt *f <%Ai ftlrt**** dl rûdmut *»*M nt tJ\<w
oc«ln<t trt Uw levin* aX**««* JrJ*« fon»
fot'*“ <> » %.n tm t,bn»»* rxni*?n* %!<»»•• rm *.v*r. It
yv it, •**«*■, * tM.i* . oeul/i »s rr.fcMr*>.
jrwum.
SVaJkUnW
'4:
Exhibits - 69
EXHIBIT Y
https://archive.Org/stream/aschairmanofmonu001ond#page/nl/mode/2up
Exhibits - 70
Aa C -ir.'-'.n wf the ?'onu\'.ent Co:n:'.itfcoe of the llorth Carolina Di
vision of tS> !.* United D‘.ugh tero of tho Confederacy I have tho honor,
and it gives trio much pi vuuro, to present in tholr nano to tlio trus
tees of the Univcrtii ty of ITcrth C irolina this nonnnont which is creat
es’' in manory of those student a o' this University who served in the
ami oo of tho Confederate St it of Anorion.
-To non i:i ..ny a.;o or country < io t o richly donerves to he oo-iner.-
orttad in bronze or otono than those youths .tho at the call of -their
roupootivo states rushed to amn and suffered the Indeanîhahl^ hard

ships and dangers of a Confederate soldier's life. Tnllo thio :no nu-
nent i
s an outw ard exprcoolon of our love for them and our adriration
of thei
r horoiom , yot also the loving hearts of the w om en of the South
wi
llever he m em orial tablets on w hich t
illbo inscribed the r.o *ory
of thei
r virtues and valor. G overnor C raig hao givon you in ; art a
history of tho services rendered by the students of this U niversity
to the Southern C onfederacy, but no tongue can t
ellnor pen -'.ascribe
al
lthat can be said or 7ritten in thei
r praise.
Irihonoring the nanory of our C onfederate heroreo w e m ust not '
e
nisunderotood as having in our hr-^rta any hatred to those /ho w r.
31uo, but vfc do not w ish to forget w hat has boon done foruo by thos-e
•who ’.ror'' the G ray. The love that wo have for them i
s l
ike the f
ait
’-
fulclinging ivy*
"G o 17e w ho stand beneath the stripes n-d stars
U pon tho threshold of thoso l ater ye*v?fi,
Lilcc ivy, clinging to a -2 ur Loot C ause,
St illyi eld tho tri
bute of our love and team .
TJiua m ay, w ith all the future’s slow decline.
The reverence of gonerationo bo,
?orcvor an ivy, that w i l
l st il
lontw ine
The ruins of the proud C onfederaay."
"Jq have erected this none ’ent not only in honor of tho dT.d but
-1 so
.of* the l i
ving. To the latte* w ould any in bahalf of the w o'-on of
Co. t.. that .c hope that t r last years m ay ba thei
r liaj-pieot uni
Exhibits -71
w hen they C roce over the R iver that they nay reet under the ohade of
the trees w ith their im m ortal leaders, Stonew all Jaokson and R obert
L. Lee. O f thoae w ho have died wo nay w ell any, in the w ords of
ther R yan, the poet prioot of the South,
"W o core not w hence they oam o,
D ear in their l
ifel
^ps olay;
W hether unknow n or know n to fum e,
Their cause and ooun'ry at
illthe sam e,
They died— and w ore the G ray. "
Accept thi
s m onum ent and m ay i
t stand forever as a perpetual m e
m orial to those xha sons of the U niversity w ho suffered and aaorifioed
so m uch at the cal
l of duty.
Exhibits -72
EXHIBIT Z
https://archive.Org/stream/aschairmanofmonu001ond#page/nl/mode/2iiD
mm
■4ri
37f
Vl K34
&
rt;
'
D edication of M onum ent
-S3
c
,4
AW*;-
V
.
m
■
MW i m
Exhibits - 73
Acceptance of the M onum ent
hy
Francis ?. Venable.
To mark the last resting place* of fallen he-
roea ar.d to erect monuments In memory of their hirolia

la the duty ftfid privilege of a Tory .grateful people. The
eon* of the Univoreity fall on mnny n battlefield in the
gr*«t war between the etnteo and to their manary the eorrow-
InE mother h&e placed tablets in her XMCrUl Rail, and now
In commemoration of u grant ora and of a r.obla Ideal there
hoa been araoted on her oaepua thie beautiful monument.
This then la no raero monument to the dead but a
worthy manorial to that heroio era in the hlotory of the
University when men’* her.rte were stirred mightily and the
olear call of duty wua answered *v«n at the sacrifice cf
life lteslf. It is wall to remembor the record of the
Unlveroity in the great etruggle, for I believe it to be
without parallel.
It to thet pot riot la organisation, the United
Duughtara cf the Confederacy, that the gracious thought firet
CMS*
of aroot lug thie monument to the none of the University
*■ •*. entered the War. Tour yours ago the Worth Carolina Div-
Uion af rhe Daughter* asked permlBSlor. of the Trustees to
Exhibits - 74
■t
-2-
p2.(ioo the monument uj r. the campus, which Was gladly granted

them. A committee was appointed, coepatItIvc* designs wore
submitted and the d«fl|B of- a young Canadian artist, John
W ilson, Wf * seleat.ed as the most boatltiful and as moat
appropriately carrying out the groat Idsalwhich It was t-c
coamemer ate. It might well be entitled "The Call of Duty."
The alumni cnme to the aid of the ladles and through their
Joint efforts the necessary fttnds wore subscribed.
And now the monument etnads complete, ar. a-rnament

to the caapu*, and n splendid ladson in granite and bronze
to all cosing generations of atudents throughout the years,

that in the words of the immortal Lee " Duty le the subllmest
word in the English laogucje." If they learn this leoeon

thoy will not fail to anuluto the virtues of the heroic sons
of the University who hove gone before them, and will nobly
nnawer ’• o tho call ae It cornea to them day by day In great

thing* and in •mall.
T» the name of the University tr.d with an abiding

gratitude I accept the gracious rift of this aonumen^ em
bodying as it does grateful memory far tho past and high

hope for the future.
Exhibits - 75
EXHIBIT AA
iMimitcs
nf the
^climtonitl] Annual (Couimtiiou
of the
lluitt'b ihmqhtprs nf tin' CottftAi'rnnj

Knrtfi (Lnrnlma Oitiisinu
beib ni
(Larborn, North Carolina
(Odnlirr 8. 9 nub 111. 1913
MRS. MARSHALL WILLIAMS. Pr«,dem

MRS. THAD W. THRASH. Recording Secrelaty
OWEN G DUNN. PRINTER

NEW BERN. N C.
Exhibits - 76
r-
.3
.-s
•§
Ml MINCTCS OK nil: PKVKNTKKNTH VN.NC.U • • i.VVl- NT|f»N
-
1NITKD I'AIMHITKIIK "H Till: (»NKKI«SHACV, '.I
the -i-liools. Mr>. \Vin>lt*a<l r«*iul tin* iv h i Iu lions ilrnwu now h stands ther. lor nil tilin' ami ll will be an object bo-sou
to nil future co»erations and will Impress upon the present day
til» by Mrs. Ar«*I*lM»II. students their obligation to respond to the fall of duty
Mol ion in appoint a Manntdm: i nnwiittce <>l t L»r**« ■ There wore more than 1 *>"<> Uttulveraity no n in tile struggle
between the Slates In the word- of our linmortu! leader, "duty
!n k**«*|» up ihi- miigtuiiip, '(*«*nn<I(Wl ntnl «*f*Vri«**l. it the suhlino M word in tin Kitgllsh language
MUS II A LONDON.
A«lj*mrm*«l until J oVItwk. P. M.
Motion was mailt1 t«» fall roll of ('luiptei - to fcivr for
llii> I'uiul. Onl\ s.*»DO is iifftlt tl.
Second Day—Afternoon Session.
Kleetion of officers: Motion 'ftioiitlfil ami oarriftl.
President Mrs Marshall Williams. Faison l Hitting Votet. Motion by Mrs. L. I), llnaiit
F rst ........ President Mrs Frank lluggim • I nanlim.!* \'m. .
That North < arolltia endorse Mrs F M Williams Record
Second Vice President Mi* M O Wln*o ad | Unanimous Vote 1. ing Secretary General."
Third Vtr. I'r- .-ddeuL Mr> II. L Higgins < Pnanimou* Vote!
Recording Secretary Mr- T \V Thrash (Rising Votej Motion seeoinl.Ml ami curried. Mrs. WillinniK was
fort eaponding Secretary. Mins Winnifred Faison t Rising Volet. endorsed.
Registrar. Mi* Foil* Harvey t Majority •
Treasurer. Mis* Margaret Kthercdgo (Rising Vote). Kojmrt on Woman’* t'on fedora to Ilontf. Approved
Recorder ol t roR* -*. Mt" II I. Reid « Unanimous Vote» anti ufffptfil.
Historian. Mis- Carry Lessor t Rising Vote.
Chaplain. Miss llettie Junn - t Rising Vote t lllirni.i t»l CONIT.DF.K \TF WOMAN’S lloMK.
Director of Children'* Chapter. Mrs Gordon Finger (Kitting
Votet. Madam President and DaugbterB:
I.fpofi >>ii (Impel Hill Monument Committee rend l*\ It Is with deepest regret that I am unable to meet with you
.Mrs. II. A. London.i-lmirumn. Approved aud accepted. and read my report, for I feel 1 have so much to say to you that
I cannot write, but Providence lias prevented no- aim I am in the
ItKItiHT OF C»L\PK1, MILL MOM MG NT COMM1TTKK. hospital, but my heart and thoughts are with yon.
The Chapel lllll Monument was unveiled during Hie last 1 send you glad tiding- of great joy that our four yearn’ ol
(Otnnencement at the University It is very beautiful It is not labor litis been crowned with sue. e-- ami in the near future, our
only in memory til the boys who left the University from 1St> 1 fond hope will be nnlized In the erection at Fayetteville. Of it
to Utir>. but also those who attended the University and after Confederate Women'* Home: a building that will stand for all
ward* been me font-derate soldier* ages as a comfort to the homeless I wish I .lllll! thank e.tell
Daughter personally, who has responded so cheerfully and work
Tablets have been erected in Memorial Hall In memory of «*d so faithfully for the erection of this Home and I feel this liv
I ha*, who lost their lives, and till who t nllated ur- surely worthy ing monument to alleviate the sufferiiu:*, ant! provide comfort
ot a monument for thot. that remain of tin follower- of l.ee and .larkmii, will
Dr Venable and other* hove worked unceasingly it.r it aud lower high In Glory to Hi. credit of the women of North Caro-
EXHIBIT BB
https://www.dukechronicle.com/article/2018/1 1/timeline-of-silent-sam-statue-unc-diike
Timeline: The latest on Silent Sam
The Chronicle
By John Mark is
November 27, 2018 | 12:00am EST
In the months since protesters pulled down the University of North Carolina-Chapel Hill's
‘‘Silent Sam," a Confederate monument, the statue's place on campus has been mired in debate.
This timeline provides context for its creation, the subsequent controversy and what the future
entails.
1908: The United Daughters of the Confederacy proposed building the statue to honor the
"Chapel Hill Boys" who left college to join the Confederate Army. John Wilson sculpted the
statue and images on the base and modeled it on Harold Langlois, a young man in Boston. The
project cost $7,500—equivalent to roughly $200,000 today.
June 2,1913: Delayed by two years due to fundraising difficulties, UNC formally unveiled
Silent Sam to the public. Governor Locke Craig spoke at the ceremony, as did Civil War veteran
Julian Carr, who boasted about “horse-whipping’' a black woman for insulting a Southern lady.
1955-1968: UNC officially integrated its student body in 1955, and conversations about Silent
Sam’s presence evolved as a result of the broader Civil Rights Movement. After Martin Luther
King Jr.’s assassination in April 1968, students defiled the monument for the first time.
2011: UNC history graduate student Adam Domby unearthed the transcript of the dedication
ceremony from 1913 and published his findings in The Daily Tar Heel in a letter to the editor,
quoting Carr’s remarks. Students calling themselves the “Real Silent Sam Movement’’ then
attracted the attention of national leaders, such as former North Carolina NAACP president Rev.
William Barber II, to the statue.
2015: Silent Sam was vandalized several times in 2015. That year, the North Carolina General
Assembly also passed the Cultural History Artifact and Patriotism Act, which barred the
permanent removal of any “object of remembrance’’ without the approval of the North Carolina
Legislature.
August 2017: At the “Unite the Right” rally, the so-called “alt-right” and counter-protesters
clashed in Charlottesville. Va., about the removal of a Robert E. Lee statue. Just days after,
protesters toppled a Confederate monument in Durham. In the wake of these events, Chapel Hill
Mayor Pam Hemminger asked the university to remove the statue and Chancellor Carol Folt said
in September that it would be best for the statue to be moved. However, she said that the
university would follow the law—which banned the statue's removal without the state
legislature's approval.
Exhibits - 78
September 2017-April 2018: Debate raged throughout the year. Activists petitioned Folt,
holding rallies outside her office.
April 30, 2018: Maya Little, a history doctoral student, splattered red paint and blood on Silent
Sam, justifying the action as ‘‘providing historical context" for white supremacy. The University
charged Little, who was arrested, with an honor code violation.
Aug. 20, 2018: Protesters gathered around Silent Sam and tore down the statue. Police arrested
several participants. Groundskeepers drove the statue to an undisclosed storage location. The
next day, UNC and Chapel Hill leaders issued the following joint statement:
"Last night's rally was unlike any previous event on our campus," the statement read. "This
protest was carried out in a highly organized manner and included a number of people
unaffiliated with the University. While we respect that protesters have the right to demonstrate,
they do not have the right to damage state property."
August 31, 2018: A neo-Confederate group rallied at the site where Silent Sam once stood, but
the group was heavily outnumbered by counter-protesters.
Oct. 26, 2018: The undergraduate Honor Court ruled that Little violated the school’s honor code
and sanctioned her with 18 hours of community service and a letter of warning. Little has
since appealed the ruling, saying that she did not receive a "fair and impartial trial." The case has
not yet been decided.
Present: University leaders have said they will have a proposal on what to do with the statue
before the Dec. 14 Board of Governors meeting.
Exhibits - 79
EXHIBIT CC
https://vvvvw.wral.com/unlawful-and-daimerous-unc-chancellor-on-silent-sain-
toppliim/17783175/
Unlawiul and dangerous: UNC chancellor on 'Silent Sam' toppling

Posted August 20. 201 8
Updated August 23. 201 8
By Natalie Matthews, WRAL.com editor, Sarah Krueger & Candace Sweat, WRAL
reporters
CHAPEL HILL, N.C. — Protesters on Monday night toppled the controversial "Silent Sam"
statue on the campus of the University of North Carolina at Chapel Hill.
More than 200 protesters first gathered at the Peace and Justice Plaza at about 7 p.m.. before
marching to the base of the statue, calling for its removal. By 9:30 p.m.. the statue was on the
ground and the crowd erupted in cheers.
Chancellor Folt released a statement about the toppling.
UNC-Chapel Hill
>/@u n c
A message from Chancellor Folt on the Confederate Monument: https://unc.live/2nTniOv
Dear Carolina Community:

As you are probably aware, a group from among an estimated crowd of 250
protesters brought down the Confederate Monument on our campus last night.
The monument has been divisive for years, and its presence has been a source
of frustration for many people not only on our campus but throughout the
community.
However, last night's actions were unlawful and dangerous, and we are very
fortunate that no one was injured. The police are investigating the vandalism
and assessing the full extent of the damage.
I appreciate the actions taken by the police to ensure the community's safety
and will keep you informed as additional information is available.
Sincerely.
Carol L. Folt
12:48 AM-Aim21.2018
"Silent Sam" had been standing on the UNC campus since 1913.
Exhibits - 80
Gov. Roy Cooper issued a statement Monday night, saying that he "understands that many
people are frustrated by the pace of change and he shares their frustration, but violent destruction
of public property has no place in our communities."
On Tuesday, other North Carolina leaders issued statements.
"Many of the wounds of racial injustice that still exist in our state and country were created by
violent mobs and I can say with certainty that violent mobs won't heal those wounds. Only a
civil society that adheres to the rule of law can heal these wounds and politicians - from the
Governor down to the local District Attorney - must start that process by ending the deceitful
mischaracterization of violent riots as 'rail ies* and reestablishing the rule of law in each of our
state’s cities and counties." said North Carolina Senate Leader Phil Berger. R-Rockingham.
‘‘There is no place for the destruction of property on our college campuses or in any North
Carolina community; the perpetrators should be arrested and prosecuted by public safety officials
to make clear that mob rule and acts of violence will not be tolerated in our state," State House
Speaker Tim Moore. R-Cleveland. said.
Protesters on Monday night first sectioned off the area around the controversial statue with large
banners, blocking it from view. Throughout the course of the evening, people in the crowd
speculated about what might be going on behind the banners, but no one confessed to knowing
the plan.
People chanted "stand up. tight back" and "hey. hey, ho. ho. this racist statue has got to go."
Many also held signs.
Chelsea Manning, the former U.S. soldier who disclosed 750.000 government documents to
Wikileaks, was also in attendance.
Chelsea E. Manning
Y @xychelsea
we stand in solidarity with UNC students tear them all down or we will
#silentsam #WeGotThis
10:08 PM - Aug 20. 2018
WRAL's Candace Sweat said she saw a rope that was connected to something behind the
banners, and that she heard a creak before the statue came down.
Exhibits - 81
At one point, there were tense moments between protesters and poliee officers. Protesters
deployed smoke canisters.
One person was arrested and charged with resisting arrest and for concealing one's face during a
public rally.
Around 9 p.m., protesters left the base of "Silent Sam" and marched to Franklin Street, where
they formed a large circle in the street, briefly blocking the intersection of Franklin and
Columbia.
The march continued down Franklin Street and ended back at the base of "Silent Sam." Soon
after, the Confederate statue came crashing down.
Once it was on the ground, protesters were shoveling dirt on top of it and stomping on it.
UNC issued a statement Monday night, calling the actions of the protesters "dangerous."
"Tonight’s actions were dangerous, and we are very fortunate that no one was injured. We are
investigating the vandalism and assessing the full extent of the damage." the university said in a
statement.
Police surrounded the statue once it was on the ground, but they made no further arrests.
Overnight, university officials carried the toppled statue away.
As a precaution, authorities were patrolling the area around the Confederate statue on the State
Capitol grounds in Raleigh.
Some of the people who were charged in connection with toppling a Confederate monument in
Durham were at Monday's protest. One of those people was Raul Jimenez.
"I'm supporting all the students here today." he said. "As someone who was tried and found not
guilty of taking down a statue in Durham. I am here to support them in taking down this statue."
First-year students Nora Dickson and Gretchen Mackie said the scene was tense and emotional.
A biology professor at UNC-Chapel Hill said she came out to the protest after she put her kids to
bed.
"...all people deserve to be treated with dignity," she said.
Exhibits - 82
t
The "Silent Sam" statue has been the site of protests for the past year, with students, faculty and
alumni calling it a racist image and begging for officials to remove it.
Exhibits - 83
EXHIBIT DD
https://vvvvw.vvral.com/hours-after-folt-orders-reinoval-of-silent-sain-pedestal-crews-arrive-to-reinove-it-
from-unc-campus/18124227/
Hours after Folt orders removal of’Silent Sam’ pedestal, crews remove it from UNC campus
Posted January 14
Updated January 15
5.8K
By Natalie Matthews, WRAL digital journalist
CHAPEL HILL, N.C. — Hours after University of North Carolina at Chapel Hill Chancellor
Carol Folt said she would step down following graduation and authorized the base of "Silent
Sam" be removed, crews descended upon McCorkle Place to do just that.
Around 11 p.m., crews with a large construction- type truck and flood lights arrived at the UNC-
Chapel Hill campus, along with a group of law enforcement officers. Wood was being put down
over the grass to create some sort of track.
By midnight, a man was seen drilling into the stop of the statue and a forklift was on hand, and
by 12:45 a.m., the pedestal had been removed.
A crowd of people gathered around to watch and a small cheer erupted when the pedestal was
lifted.
The last piece of the base was removed by 2:40 a.m. The pedestal was later towed away.
A spokesperson for the university said the base and plaques of the Confederate monument would
be stored in a "secure location."
A small group of people were involved in a scuffle with police, and one person was arrested and
taken away in handcuffs.
In a letter to the UNC community on Monday afternoon, Folt said that, before she leaves, she
plans to focus on the university's core mission and will "push forward with Carolina’s campaign
and history task force."
Exhibits - 84
"I’m deeply proud of what you’ve accomplished and what we’ve accomplished together since 1
became a Tar Heel nearly six years ago in 2013.1 am writing today to let you know that I have
decided to step down as chancellor following graduation, at the end of the academic year," Folt
said.
"I have authorized the removal of the base and commemorative plaques from the Confederate
monument site in McCorkle Place. As chancellor, the safety of the UNC-Chapel Hill community
is my clear, unequivocal and non-negotiable responsibility. The presence of the remaining parts
of the monument on campus poses a continuing threat both to the personal safety and well-being
of our community and to our ability to provide a stable, productive educational environment."
The Silent Sam statue, in honor of UNC's Confederate dead, stood on the campus from its
dedication in 1913 until August, when a group decrying its racist history toppled it from a
pedestal. Since that time, campus leaders have considered next steps.
Late last year, Folt announced a plan to build a $5.3 million "center for history and education" to
house the statue on campus.
A few weeks later, UNC Board of Governors rejected that plan, saying the cost of the center -
beyond the construction expense, it would cost $800,000 a year to operate - and concerns over
safety made it unworkable.
Board of Governors members Darrell Allison, Jim Holmes, Wendy Murphy, Anna Nelson and
Bob Rucho were named to a committee to work with Folt and the UNC-Chapel Hill trustees to
come up with a new plan for Silent Sam that the full board can take up at its March 15 meeting.
Board of Governors Chairman Harry Smith said Folt decided in a closed-door meeting with the
board on Monday to resign. But her announcement regarding Silent Sam caught the board off
guard.
"We are incredibly disappointed at this intentional action. It lacks transparency and it
undermines and insults the board’s goal to operate with class and dignity," Smith said in a
statement. "We strive to ensure that the appropriate stakeholders are always involved and that we
are always working in a healthy and professional manner."
The March time frame for the Board of Governors to discuss Silent Sam's future remains
unchanged, he said.
"Moving forward, the board will continue to work tirelessly and collaboratively with all relevant
parties to determine the best way forward for UNC-Chapel Hill," he said. "We will do so with
proper governance and oversight in a way that respects all constituencies and diverse views on
Exhibits - 85
* ft
this issue. The safety and security of the campus community and general public who visit the
institution remains paramount.”
On Twitter, Gov. Roy Cooper praised Folfs efforts to make the university more inclusive.
Governor Roy Cooper

V @.NC Governor
I appreciate the Chancellor's actions to keep students and the public safe. North Carolina is
welcoming to all, and our public university should reflect that. - RC
https://twitter.eom/ChancellorFolt/status/l 085144839979745281
Carol Folt@ChancellorFolt
Overnight, workers removed the base and tablets from the Confederate Monument site. I
am confident this is the right decision for our community - one that will promote public
safety, enable us to begin the healing process and renew our focus on our great mission.
7:49 AM-Jan 15.2019
Folt said in her letter that "safety concerns alone should preclude the monument from returning
to campus," adding that the UNC-Chapel Hill Board of Trustees also supports that position.
"The base and tablets will be preserved until their future is decided. While I recognize that some
may not agree with my decision to remove the base and tablets now, I am confident this is the
right one for our community - one that will promote public safety, enable us to begin the healing
process and renew our focus on our great mission," Folt said.
Leaders with the Board of Trustees issued a statement supporting Folt's actions.
"The chancellor has ultimate authority over campus public safety, and we agree Chancellor Folt
is acting properly to preserve campus security. Nothing is more important than keeping our
campus community and visitors as safe as possible," the statement said.
Gov. Roy Cooper echoed much of the same.
"I appreciate the Chancellor's actions to keep students and the public safe. North Carolina is
welcoming to all, and our public university should reflect that," he said in a statement.
Exhibits • 86
£
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From: Ppqqy Wondltid Johnson

Sent: Wednesday August 2Z. 2018 ICtCM AM
To: havwxxfc-cchfane
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X I as a representative of Ihe United Daughters of the Confederacy. request that *he Boy Sokner. refered to as $i»ent Sam
be returned t o the United Daughters ol the Confederacy We are voting to take possessor* of oath tfe case and the
sculpture We have been saddened that the menage of this morvunienl as been: so misconstrued He no longer belongs
on the campus of UNO Chape1 Hir
Peggy W. Johnson
NO HOC Division Prcs»dtr-it
-•

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STATE OF NORTH CAROLINA IN THE GENERAL COURT OF JUSTICE

File No. 19CVS IO / V

corporation, respectfully alleges and states as follows:

1. Plaintiff North Carolina Division Sons of Confederate Veterans, Inc. (“SCV” or

Carolina with headquarters in Sanford, Lee County, North Carolina.

provide that SCV was organized for the following purposes:

To associate in one united, compact body men of Confederate ancestry, and to

Said corporation is organized exclusively for charitable, religious, educational, and

Inc. (filed Jul. 11, 1988)).

authority to institute this action on behalf of Plaintiff.

4. The University of North Carolina (“the UNC System”) is a public, multi-campus

Constitution and Chapter 116 of the North Carolina General Statutes.

governance, dominion, supervision, management, development, administration, direction, and

9. Non-party The United Daughters of the Confederacy - North Carolina Division,

with headquarters in Raleigh, Wake County, North Carolina.

Carolina Division, Inc. (filed Sept. 16, 1992)).

the Confederate Monument, under N.C. Gen. Stat. § 1-75.9.

1-79(a), and 1-82.

limitations within the North Carolina General Statutes.

University of North Carolina”) with a monument (“the Confederate Monument”) honoring

throughout North Carolina to honor various Confederate heroes and ideals.

permission to place such a monument on the University campus.

nothing can dim ....” See Exhibit I (letter)

See Exhibit K (letter).

Thirteenth Annual Convention at 65-67 (1909)).

(September 5, 1910, letter).

women could do it of course.” See Exhibit Q (letter).

See Exhibit R (letter).

See Exhibit S (letter).

1911, c. 109 (attached as Exhibit U).

statue”), representative of a Confederate soldier, to be placed on top of a granite pedestal (“the

and made the following remarks:

See Exhibit Y (remarks) (emphasis added).

the following remarks:

See Exhibit Z (emphasis added).

made the following remarks:

Seventeenth Annual Convention at 50-51 (1913)).

Monument and numerous incidents of vandalism. See, e.g.. Exhibit BB (article).

pedestal of the Confederate Monument. See Exhibit CC (article).

of the Confederate Monument.

representatives, including representatives of UNC-CH, loaded the statue portion of the

Confederate Monument onto a truck and took it to an undisclosed location.

removed from the University campus. See Exhibit DD (article).

damaging the Confederate Monument further in the process.

See Exhibit EE (email).

Defendants or their representatives.

FIRST CLAIM FOR RELIEF

incorporated by reference as if fully set forth herein.

N.C. Gen. Stat., Ch. 1, Art. 26.

59. An actual justiciable controversy exists between the parties.

61. The Confederate Monument qualifies as an “object of remembrance” under N.C.

Gen. Stat. § 100-2.1.

North Carolina Historical Commission.”

very limited conditions.

Defendants and as such is “public property” under North Carolina law.

65. An “object of remembrance” that is temporarily relocated must be returned to its

66. An “object of remembrance” that is permanently relocated may only be relocated

cemetery, or mausoleum unless it was originally placed at such a location.

buildings, open spaces, parking, or transportation projects.

Place on the UNC-CH campus within 90 days.

boundaries of the jurisdiction from which it was relocated.”

Defendants to do so for construction, renovation, reconfiguration of buildings, open spaces,

parking, or transportation projects.