Supporting Documents
Tambussi letter - Challenge to Taylor petition - April 4, 2019
| tambussi_challenge_to_taylor_petition.pdf |
Schmidt letter to Petrone re Tambussi Challenge - April 4, 2019
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Gulbranson Letter to Clerk Ripa - April 8, 2019 (received April 9th)
Gulbranson letter - page 1 of 2
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Gulbranson letter - Page 2 of 2
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Sokol Letter - April 8, 2019
| sokol_letter.pdf |
Determination Letter - April 10, 2019
| determination_of_the_challenges_to_petitions_2019.pdf |
Tambussi OPRA Request - April 11, 2019
| tambussi_opra_april_11_2019.pdf |
Schmidt letter to Tambussi regarding OPRA request - April 11, 2019
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Verified Complaint - filed in Superior Court April 11, 2019
| verified_complaint.pdf |
Kabir "Same Hand" Challenge - Kabir Petition
Pages 7 & 8
Kabir petition - Pages 7 & 8
Kabir "Same Hand" Challenge - petition
complete document
| dem._clerk_-_kabir.pdf |
Kabir - "Same Hand" Challenge
Kabir -"Same Hand" Challenge - Signature does not match.
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Kabir -"Same Hand" Challenge - Signature does not match.
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County Clerk Office election worker marked "NO"
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Clerk office finds non-matching signature on petition Kabir circulated
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From the challenge against the petition of Mohammed Kabir made by a Democrats of Camden County supporter. Notice Jacklyn 30 to 35 at right: apparent “Same hand” signed the signatures, in a petition whose signatures were collected by the candidate. A signature comparison showed one of these signatures indeed did not match the voter rolls, and that signature was simply disallowed.
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Kabir Petition - "Same Hand" Challenge
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Semple - Witte Challenge
| semple___witte.pdf |
April 11, 2019 - Judge Kassel on Margulis v Ripa - [click for audio]
Unofficial transcript of NJ Superior Court Judge Michael Kassel’s oral comments in the matter of Margulis v. Ripa, April 11, 2019.
Brief timeline: On April 10 at 4 p.m., Deputy County Clerk Schmidt disqualified Freeholder candidates O’Donnell and Lovett from the ballot despite no finding of fraud from County Prosecutor Sokol. On April 12 at 3 p.m., the ballot placement drawing was to take place, and without O’Donnell and Lovett on the ballot, some 100 other candidates would lose their chance to draw for Column 1 on the ballot and instead would be relegated to Column 4. That was the emergency that caused the plaintiffs to prepare and verify their complaint between 4 p.m. April 10 and 9 a.m. April 11.
Brief timeline: On April 10 at 4 p.m., Deputy County Clerk Schmidt disqualified Freeholder candidates O’Donnell and Lovett from the ballot despite no finding of fraud from County Prosecutor Sokol. On April 12 at 3 p.m., the ballot placement drawing was to take place, and without O’Donnell and Lovett on the ballot, some 100 other candidates would lose their chance to draw for Column 1 on the ballot and instead would be relegated to Column 4. That was the emergency that caused the plaintiffs to prepare and verify their complaint between 4 p.m. April 10 and 9 a.m. April 11.
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[UNOFFICIAL TRANSCRIPT]"Margulis versus Ripa, under docket L1444-19. It’s an order to show cause that seeks to temporarily restrain a ballot placement drawing scheduled literally for tomorrow at 3 p.m. I’m denying the order to show cause.
First off, I want to preface this by saying it may not have been the fault in any meaningful sense of the plaintiffs but I got the paperwork in this because of conflicts in the [inaudible] literally at 3:25. It is now Thursday afternoon at 3:25. And I got just the order to show cause that seeks essentially to stop what’s called a ballot placement drawing scheduled to take place tomorrow, April 12 at 3 p.m. The verified complaint in this case reflects, is a dispute in regard to, let’s see, I don’t even want to try and summarize it, because I really don’t know. The verified complaint itself is 77 paragraphs, and there is no way I would be able to wade through and verify complaints to determine to what extent something that’s called a ballot placement drawing scheduled for tomorrow at 3 o’clock should go forward. I can’t fairly deal with it in such a short amount of time. Apparently the actual primary is not until June, looks like June 4th. So I’m not going to be enjoining the ballot placement on April 12, however it is without prejudice to the plaintiffs seeking a return date on a normal motion to address some of these issues. If there is an actual serious problem with the ballot placement then arguably something could be done after April 20th but obviously well before June the 4th. But this, an apparent emergency, was created less 24 hours before this ballot placement drawing is scheduled to go forth, and I absolutely do not feel comfortable on the basis of what’s been presented to me in regards to these allegations, which I [sic] and citations to various, numerous statutory provisions. I have no idea what it means. Just [inaudible] example NJSA 19:23-14, 19-14-1, 19-13-12, 19-63-5, and 19-63-9. 19-49-2. I have no idea what these statutes mean, whether or not the plaintiff has under Crowe v. DeGioia set forth all four prongs to justify such extraordinary relief, literally the day before the ballot placement. So I seriously doubt there will be harm that can’t be remedied, irredeemable, harm that cannot be remedied, after April 12, irreparable harm to use the terminology of Crowe v. DeGioia. So I am denying the order to show cause. [sound of stamping].” |
COMMENT: Judge Kassel was incorrect that this matter could have waited until April 20, because by statute the County was required to start mailing Vote-by-Mail ballots on April 20, which was 45 days before the election. https://www.njelections.org/assets/pdf/chrons/2019-chron-06-primary-election.pdf
In 2017, 25% of Camden County Democratic primary voters cast their votes by mail. http://www.camdencounty.com/service/voting-and-elections/election-results/
Judge Kassel’s comments ignored the first item requested by the plaintiffs (paragraph 57A of the verified complaint, page 11 [Click to view Page 11]), namely the restoration of candidates disqualified from the ballot. Under NJSA 19:13-12, the disqualified candidates were entitled to a Camden Superior Court judicial hearing within three days of filing a verified complaint.
"A judge of the Superior Court assigned to the county in which any petition of nomination shall be filed, on the application or complaint, duly verified, of any candidate, which application or complaint shall be made on or before the twelfth day after the last day for the filing of petitions, setting forth any invasion or threatened invasion of his rights under the petition of nomination filed with the Secretary of State or with any county clerk, **shall hear** such application or complaint in a summary way and make such order thereon as will protect and enforce the rights of such candidates, which order or determination shall be filed **within three days** after the filing of the application or complaint."
https://nj.gov/state/dos-statutes-elections-19-10-19.shtml#ele_19_13_12
In 2017, 25% of Camden County Democratic primary voters cast their votes by mail. http://www.camdencounty.com/service/voting-and-elections/election-results/
Judge Kassel’s comments ignored the first item requested by the plaintiffs (paragraph 57A of the verified complaint, page 11 [Click to view Page 11]), namely the restoration of candidates disqualified from the ballot. Under NJSA 19:13-12, the disqualified candidates were entitled to a Camden Superior Court judicial hearing within three days of filing a verified complaint.
"A judge of the Superior Court assigned to the county in which any petition of nomination shall be filed, on the application or complaint, duly verified, of any candidate, which application or complaint shall be made on or before the twelfth day after the last day for the filing of petitions, setting forth any invasion or threatened invasion of his rights under the petition of nomination filed with the Secretary of State or with any county clerk, **shall hear** such application or complaint in a summary way and make such order thereon as will protect and enforce the rights of such candidates, which order or determination shall be filed **within three days** after the filing of the application or complaint."
https://nj.gov/state/dos-statutes-elections-19-10-19.shtml#ele_19_13_12
Courier Post - March 6, 2017 - Judge ordered to read before ruling
The Courier Post reported that Judge Kassel has been ordered that he must read briefs before ruling.
Ties connecting the Camden County Clerks Office and the Camden County Democratic Committee
Deputy Clerk John Schmidt- $4,000 in contributions to CCDC since 2015
Deputy Clerk Christopher Morris - Serves as CCDC Treasurer
Helmer, Conley & Kasselman, P.A. - Judge Kassel's former law firm - $1500 donation to CCDC in 2015
Source: https://www.elec.state.nj.us
Deputy Clerk Christopher Morris - Serves as CCDC Treasurer
Helmer, Conley & Kasselman, P.A. - Judge Kassel's former law firm - $1500 donation to CCDC in 2015
Source: https://www.elec.state.nj.us