Issuu

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SUPERIOR COURT OF NEW JERSEY LAW DIVISION, CIVIL PART HUDSON COUNTY, NEW JERSEY DOCKET NO. HUD-L-001558-21 APP. DIV. NO. SYDNEY FERREIRA, Mayoral : Candidate for Town of : Kearny, and ALEXIS CAMPOS,: Council Candidate, 2nd : Ward for Town of Kearny, : : Plaintiff, : TRANSCRIPT : OF v. : ORDER TO SHOW CAUSE : HEARING ALBERTO SANTOS, Mayor of : Kearny; PATRICIA : CARPENTER, Town of Kearny : Clerk; E. JUNIOR : MALDONADO, Hudson County : Clerk; GURBIR SINGH : GREEWAL, Attorney General : State of NJ, : : Defendants. : : Place:

Hudson County Admin. Bldg. (Heard telephonically) April 21, 2021

Date: BEFORE: HONORABLE JEFFREY R. JABLONSKI, A.J.S.C. TRANSCRIPT ORDERED BY: MICHELLE F. SPENCER, ESQ. (Castano Quigley, LLC) APPEARANCES: SYDNEY FERREIRA (Pro Se, Plaintiff) Agency:

Sarah Fetz, AD/T 626 RedDoor Legal Services, LLC 44 Valley Forge Road Bordentown, NJ 08505 (973)985-3668

Digitally Recorded Operator - Catarina Ortiz

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APPEARANCES, CONTINUED:

2 3

ALEXIS CAMPOS

(Pro Se, Plaintiff)

5 6

GREGORY J. CASTANO, JR., ESQ.

(Castano Quigley, LLC)

Attorney for the Defendants

9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25

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I N D E X

PROCEEDING

Order to Show Cause Hearing

Arguments

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By Mr. Ferreira

12,41

By Ms. Campos

28,44

By Mr. Castano

8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25

Judge's Decision

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(Proceedings commenced at 1:33 p.m.)

MS. ORTIZ:

On the record, Judge.

THE COURT:

Thanks very much, Cat.

We're on

the record in docket number L-1558-21, Sydney Ferreira

and Alexis Campos versus Alberto Santos and others.

Mr. Ferreira, are you on the line?

Sir.

MR. FERREIRA:

THE COURT:

MR. FERREIRA:

THE COURT:

MS. CAMPOS:

THE COURT:

And --

Good afternoon.

And Ms. Campos, are you on the

line?

I am.

Very good.

Yes.

Good afternoon,

Yes I am.

Good afternoon.

Good afternoon, Ms. Campos.

And

counsel for the defendants? MR. CASTANO:

Judge, good afternoon.

Greg

Castano, Junior from the firm of Castano Quigley for

the two defendants from the Town of Kearny.

THE COURT:

Thank you very much.

This is an

application that was opened to this Court by the

plaintiffs, Sydney Ferreira and Alexis Campos, bringing

an action by means of an Order to Show Cause that was

accompanied by a Verified Complaint in lieu of a

prerogative writ.

19, 2021, which is the deadline for the filing in the

The application was filed on April

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Superior Court to protect a primary election

candidate's rights under N.J.S.A. 19:13-21.

Because of the emergent nature of the

application and the timing in which it was filed with

this Court, this Court did sign the order permitting a

response to the action, and that -- that response was

due by 10:30 a.m. today, April 21st, 2021.

also permitted a reply by the plaintiffs by 12 o'clock

on this same date.

The Court

Due to the -- also to the nature of the

application and the emergent relief that was sought,

this Court also ordered that any ballot preparation be

stayed pending further order of this Court and the

Court calculated the date on which the commencement of

the mailing of the mail-in ballot for the primary

election under N.J.S.A. 19:63-5 and N.J.S.A. 19:63-9 to

be April 24th, 2021, which I believe is a Saturday.

Presumably, the ballots would have to be printed in

advance of that date, making this matter emergent.

The -- and that -- so that gives,

essentially, the -- the procedural background of where

we are in this matter.

opportunity to review that which has been submitted in

support of this application by Mr. Ferreira and by Ms.

Campos, and I've also had an opportunity to review that

The Court has had an

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which the Town has submitted through Mr. Castano, his

brief, and the -- the certification of Ms. Carpenter.

Mr. Ferreira and Ms. Campos, we did check the

Judicial Electronic Document Service, or JEDS, and did

not see that you had submitted anything in reply.

you submit a reply?

Mr. Ferreira?

MR. FERREIRA:

MS. CAMPOS:

MR. FERREIRA:

Did

I -- I'm sorry. (Indiscernible.) -- reply -- you're asking for

a reply for -- for what, I'm sorry?

THE COURT:

Well, I gave you the opportunity

to reply to anything that Mr. Castano would have --

have submitted, and that was due by noon.

see it.

had submitted it in advance.

I did not

I don't know whether I missed anything, if you

MR. FERREIRA:

Oh.

I think I had already,

you know, submitted what we are planning to -- to

discuss.

THE COURT:

Understood.

MR. FERREIRA:

THE COURT:

Okay.

You know.

Yup.

I just wanted to make sure

that I didn't miss anything that had been submitted.

Ms. Campos, are you -- did you submit a reply, either?

Or do you just wish to be heard in reply on this

application?

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1 2

MS. CAMPOS:

No.

I just wish to be heard in

this reply.

THE COURT:

Very good.

Okay.

Folks, before

we begin, the one thing that I did want to bring to

everybody's attention is the fact that I am a resident

of Kearny.

that, but I believe that it is my responsibility to

inform you that I am a resident of Kearny.

resident of the ward in which this seat is requested

I don't know if the parties are aware of

I am not a

and Ms. Campos is looking to be a candidate for the

demo -- in the Democratic primary for the Second Ward.

I am not a resident of the Second Ward.

I am also aware professionally of the -- one

of the named defendants, Mayor Alberto Santos.

Obviously, as a resident of the Town, I would know who

he is.

personally with either Ms. Carpenter, Ms. Campos, Mr.

Ferreira, or Mr. -- Mayor Santos in this matter.

I do not, however, have any relationship

I am not related by blood or marriage in any

way to any of the parties.

I have not been the

attorney of record or counsel in any action having to

do with these parties.

on a matter in question in the action, and I have no

interest in the -- in the resolution of what this case

is.

I have not provided an opinion

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The -- so I need to bring that to your

attention and will ask you, beginning with Mr. Castano,

whether you have any objection, based on that -- those

representations, for me to proceed in this matter.

then I'll go through all the parties.

do you have any objection?

MR. CASTANO:

THE COURT:

And

So Mr. Castano,

None, Judge.

Thank you very much.

Mr.

Ferreira, do you have any objection?

MR. FERREIRA:

Are you -- are you asking if I

have any objection to what -- what Mr. Castano -- to

what the defense -- to what the defense laid forth?

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THE COURT:

MR. FERREIRA:

THE COURT:

MR. FERREIRA:

Objection to

Being that you live in the

Town. THE COURT:

MR. FERREIRA:

THE COURT:

ahead, Mr. Ferreira.

I'm sorry.

Yes.

Oh.

you presiding over the case?

I'm asking whether --

whether you have any objections --

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No.

Yes. No.

Ms. Cam -- oh.

I'm sorry.

Go ahead.

MR. FERREIRA:

Yeah.

So I -- I mean, I --

I'm not really -- you know, I'm kind of -- I'm a little

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hesitant because -- because I mean one of the reasons

why I'm running is, you know, I've heard lots of things

about vendettas and things and such of -- you know, of

our local government, of this administration.

a resident, I'm not sure how that would affect you.

know that you are imparti -- you are a judge.

heard very good things about you.

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So being I

I've

So that is the -- that is my only concern.

-- I don't -- I don't -- I would choose -- I would want

to go forward.

that you would remain completely impartial, as I know

you have in the past, as I have been told you will be.

So that -- that is the only thing that I ask.

That -- you know, I would just hope

THE COURT:

Yeah.

Well, Mr. Ferreira, you

can absolutely guarantee, and I can guarantee you, that

I will be fair and impartial and listen to everything

that the -- any party has to tell me with regard to

this matter.

responsibility to let you know about my -- my

background.

But as I indicated, I believe it was my

Residency, as our case law has held -- held

as a -- is not a automatic disqualification of a judge

to hear a case in which he or she resides in the -- in

the -- in the municipality which may be under scrutiny.

But I -- I did want to place that within your -- your

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-- your purview.

And if you do have any objection, please, let

me know.

why I'm asking the question.

I do not hold it against one person.

MR. FERREIRA:

No.

That's

If you have an objection

I -- like I said, I've

spoken to third parties and, you know, they assured me

that you are -- I've heard nothing but good things, so

I --

THE COURT:

MR. FERREIRA:

Okay.

Well --

You know, I choose to waive

that -- you know, any objection or anything like that.

THE COURT:

Okay.

Well, I -- I appreciate

that.

Ms. Campos, I'll ask you the same question,

Ma'am.

said, do you have any objection in me presiding and

continuing to preside over this matter?

And notwithstanding that which Mr. Ferreira has

MS. CAMPOS:

THE COURT:

I have no objections, Judge. Oh.

Very good.

Okay.

So this

matter then comes -- inasmuch as all the parties have

consented based on what I believe is a full disclosure

of -- and I know it was a full disclosure of -- of --

of my -- my background, I do not believe that there's

any reason why I need to recuse myself.

can be fair and impartial.

I know that I

As I have indicated, I have

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already considered that which has been submitted to me

and I am looking forward to hearing the arguments of

the parties and I will proceed that way.

Ms. Campos and Mr. Ferreira, I -- I

understand that really, Ms. Campos, this is actually

your application; Mr. Ferreira has joined.

considered the standing argument that Mr. Castano has

made.

a procedural issue.

I have also

I'm going to make that and note that as more of I also have recognized the fact

that you are self-represented, you're representing

yourselves, and will allow you, of course, Mr.

Ferreira, to -- to tell me whatever it is that you want

me to hear.

in addition and then Mr. Castano in response, and then

we'll circle back, Mr. Ferreira and Ms. Campos, to

anything that you want to say in reply.

Ms. Campos, I'll hear you in -- in res --

Please don't think that the lack of a reply

as authorized is in any way, shape, or form dispositive

of this application.

like -- pardon me, on -- on emergent order -- Orders to

Show Cause like the ones that we have today, it is

frequent that parties do not have the time to reply.

So that's more of a procedural note, so you -- it gives

you the opportunity to tell me anything that you want.

So Mr. Ferreira, I'll look to you first, Sir.

On temporary restraining orders

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MR. FERREIRA:

Okay.

So thank you for

letting us present this before you, Judge, today.

guess -- I guess the -- the core of our argument is if

-- if the opposing side is -- is saying that Alexis is

-- or Ms. Campos is not eligible to run in the Second

Ward because she moved, they are also claiming that she

-- that because she moved into the Second Ward less

than a year ago, she is not qualified to run in the

Second Ward.

So I

Then we are saying that she is not qualified

to run in the Third Ward because she moved, because she

no longer qualifies to run in the third.

completely disqualifying Ms. Campos from running at all

in -- in this election, simply because she moved?

that the argument that the other side wishes to

present?

from my understanding, being that she is a 36-year

resident of the Town, she was born and raised in

Kearny, so she very much knows the issues of this Town.

She is qualified to run for Mayor, but she is not

qualified to run for counsel.

-- I guess that's what the argument is.

So are we

That's what I would like to know.

Because

That -- you know, that

Furthermore, I -- part of the argument is

this is a primary.

It's a contest; simply a contest.

It's not an actual election governed by state laws.

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mean, it is somewhat governed by state laws, but it is

a contest between -- it's an inter-party contest.

to find out who will be running in the actual general

election.

just a contest, that the residency rule should apply,

and there's precedence for it, that it should apply to

the date of when the general election is held.

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It's

So I would argue that being that this is

So the general election will be held in November of 2021.

The prime -- Ms. Campos moved in

August of 2020.

residency in her ward to be able to run for the second.

And going back to the -- to the other point, if she

does not qualify to run in the second, you know, are --

you know, are we allowing her, then, to run in the

third?

So therefore, she will have a 15-month

She has -- she has her signatures, so I'm not

sure where exactly the other side wants her to run.

she can't do it in the second, she can't do it the

third, does she run in the first?

second?

Kearny, so we have to pick a ward.

the ward that she lives in, where she currently

resides.

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Does she run in the

We don't have a councilperson at large in And we're picking

The residents of that ward, of said ward, have signed her petition.

She got more than enough to

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qualify; I believe it was double, if not more, than the

amount of signatures required to run.

residents are comfortable with her running to represent

them, then I don't believe it's incumbent upon the

other side or -- or the, you know, state -- or the

state or court to deny her, you know, her -- her right

as a citizen, as a resident of this Town, to run for

office.

So if the

We do believe it is a subver -- a subversion

of -- of democracy.

big -- it's -- it's something that is very prevalent

now.

when we're saying that she can't run in her ward where

she lives.

moved from, then she can't run at all and we're

completely disqualifying her from running for -- for --

from seeking public office.

You know, it's very -- it's a very

And so I think that it just doesn't look good

And if she can't run in her ward where she

She worked hard.

She knocked on doors.

We spoke with residents.

walked with her.

We are well

aware of the issues.

them before, but we're even more so aware of them.

is aware of them.

she is 100 percent qualified to run in the ward where

she currently resides and where she will reside for

well over a year when it is time for the general

We were aware -- we were aware of

She took notes.

She

So I believe that

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election.

So -- also, I would like to note that the law

that states -- you know, this local unit law that the

other side is bringing up?

itself, I do not believe it is the ward because the

Town -- the council votes on town-wide issues.

listen to -- to town-wide issues and town-wide concerns

and then they vote on town-wide concerns.

unit in question is the Town.

The local unit, in and of

They

So the local

I understand why this law was instituted.

was instituted to prevent carpetbaggers, you know, it

was a term, scalawags or whatever the term is, from

coming from another Town or coming from another state

or coming from -- at the time during the Civil War, to

come from the North down to the South.

intent of these laws -- the original intent.

That was the

And so I do not believe that that is the case

here, being that Ms. Campos has been a resident for 36

years.

(phonetic).

Town who very much knows the issues and has taken it

upon herself to go from door to door to find out more.

You know, to -- to immerse herself in -- into these

issues and to become more educated on -- on the issue.

So I -- you know, that further qualifies her to -- to

She is not a carpetbagger.

She's not a

She is someone who was born and raised in

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run for office.

I also would like to note that when I went to

the Town Clerk and I asked the Town Clerk to provide

some sort of written rule of the Democratic party --

since this is a Democratic primary, I asked her to

provide some sort of written rule, a municipal

ordinance, because this is a town-wide election, or a

precedent that provides for the one-year residency

requirement based on a primary, simple based on the

primary.

complete the one-year residency.

this example, you know, that -- that -- that governs a

Democratic party primary.

municipal election; it is a party primary.

Clerk did not provide that.

Because again, in November, she's going to So I asked her for

Not a state election, not a The Town

I also asked when I was there -- I was there

alone.

This is the second time I went, after I went

with Ms. Campos.

that she is the Town Clerk and the Mayor, or the

chairman, actually, who -- who filed this objection, he

also is the Mayor, who is also running for office on

the same ticket as the aggrieved party, Mr. Konopka,

who I may add is not in this -- did not object.

aggrieved party did not object.

running against Ms. Campos did not object to her

I asked the Town Clerk that being

The

The person who is

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petition.

So the chairman of the Democratic party of

the Town objected, who is also the Mayor of the Town,

who is, in effect, the boss of the Town Clerk.

understand the Town Clerk works for the Mayor, but she

is in an awkward position because the Mayor is, in

effect, her boss.

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So I asked the Town Clerk to recuse herself because I believe that if the Mayor, or the chairman in

this case, who is the same person, does have an

objection, I believe that the Town Clerk should have

recused herself and he, he should have filed this

motion.

do -- to -- to have to file this motion.

not have an objection to his side, to -- to any of his

petitions.

believe anyone who wants to run, should run.

as they have the required number of signatures, they

should be able to run.

that's why I asked the Town Clerk to -- to recuse

herself, because of, you know, the obvious conflict of

interest there as well.

It should not be incumbent upon us to have to We -- we did

We didn't even look at the petitions.

As long

So we did not object, and

I also would like to add that the other side

did not provide adequate notice.

You know, this motion

was filed -- granted, it is on time, but it was filed

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on a Friday, April 9th, at 4:57 p.m.

I might also add to the Court that when you

look online, the hours of operation for Town Hall at --

as a whole is 4:00 p.m.

because I noticed that, and I noticed that all the

other departments close at 4:00 p.m.

is still open is the Town Clerk and the Mayor's office.

I don't know how long that's been like that, but until

5:00 p.m.

So I delved further into this

The only one that

I would also like to note to the Court that I

specifically asked during this petition process what

time is the cutoff for me to drop off my petitions on

the last day, and I was told 4:00 p.m. multiple times,

verbally, by the Town Clerk.

I was told 4:00 p.m.

was never instructed 5:00 p.m. is the cutoff time.

had to delve into the -- the Town website to find that

5:00 p.m. cutoff because like I said, if you Google

Town -- Town Hall, Kearny, hours of operation, it says

4:00 p.m.

Hall and Mayor's Office close at 5:00.

that's just semantics, but I would just like to add

that in -- in this case.

There is nothing underneath that says Town So I'm --

Then on April 14th, five days later, Ms.

Campos received a notification at 12:26 or 12:27 p.m.

She received an email.

She obviously didn't see that

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until later on, but she was told that at 4:00 p.m.

would be the cutoff before the final decision was made.

Then the final decision was made on the 16th.

So we have, in effect, had three days, a weekend;

Saturday, Sunday, and Monday, to file -- to prepare

this Motion and to file this Motion.

there was no notice of objection before this.

sneakily done on a Friday afternoon at 4:57, right

before the closing or the, you know, technical closing

of -- of Town --

to -- to -- to note that as well.

of the Town Clerk.

There was no -It was

So -- so I'd like

So the final determination was given on 4/16

and we had the deadline of 4/19.

note that the process to file this -- you know, I'm not

sure if this was -- I don't want to delve too far into

this, but we got to the court at 11:30.

from court -- you know, from the courthouse to the

office building to the courthouse back to the office

building, then sent up to -- to your chambers.

then we were told around 2:30 that the cutoff deadline

-- we have to do it online.

have a check in hand, we have everything in hand, and

we were told that we have to file -- by your Clerk, we

have to file online.

I would also like to

We were sent

And

We're already there.

And it was already 2:30, so, you know, we --

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we're in Jersey City.

have to log onto my computer, figure this out.

know, I would have -- you know, it takes about 30

minutes to get them.

file this.

well.

you know, we should have been told from the beginning

that we couldn't file it there.

given the reason because it's, you know, in the days of

COVID, but, you know, we used to do this personally, in

person, before COVID.

I had everything prepared and if I had a check in hand,

why we couldn't just submit it right then and there,

with -- with the Court.

as well.

I have to go back to Kearny.

You

I would have about an hour to

So, you know, I just want to note that as

Not that it was a big concern, but it's just --

THE COURT:

You know, we were

So I don't really understand, if

So I'd like to also note that

Yeah.

Mr. Ferreira, just -- just

-- it's not my intention to interrupt you, but just so

the record is clear --

MR. FERREIRA:

THE COURT:

-- and we can focus on the issues

MR. FERREIRA:

THE COURT:

MR. FERREIRA:

THE COURT:

Right.

-- that we can focus on -Okay.

-- substantively, I -- I

certainly understand your concern and what I might

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perceive to be your frustration with regard to filing,

although I know that it is phrased within the -- the

confines of the temporal requirements in which to file

things, but --

MR. FERREIRA:

THE COURT:

Right.

As -- as you probably know, COVID

has, and I can't be any more glib than this, thrown us

for a loop when it comes to how the business of the

Judiciary needs to proceed.

And that has to do with

taking things and filing things, and -- and you note

bringing a check to chambers and why can't we just

leave it here.

works.

them.

Well, that -- that's not the way it

And there -- there are a variety of reasons for

One of them is not that, you know, a judge's

chambers is very different than the courthouse finance

processing unit, and there are different spheres of

reference, obviously, that -- that will control.

dropping off a complaint doesn't necessarily satisfy

the filing requirements.

Just

And in order to protect not only yourself but

also those within the building, is why we have the JEDS

system, which I know that you were able to navigate

because I saw it when it posted in eCourts.

mean by that is if it's filed in JEDS, it comes over to

And what I

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the eCourts, which is the official court record.

So it doesn't appear that there was any --

other than your frustration, that I don't deprecate.

mean, I -- believe me, I acknowledge and -- and I hear

it very frequently about the frustration that arises as

a result of these COVID restrictions.

seem to su -- and I know that you're making it as a

point and it's a -- it's a valid point to make, but it

is not anything that would otherwise prejudice your

But it didn't

application because you were in line with all of the

temporal requirements.

So I'll be happy to hear you, Sir, and I

don't mind you -- I -- it is not my intention to shut

you down as to any arguments.

there is an issue that we don't need to focus on, that

may be one of the more procedural ones of the

substantive ones that you've already set forth.

can go on.

MR. FERREIRA:

It's just that when

So you

Well, I -- Your -- Your Honor,

I'm sorry.

I'm not -- I'm not blaming you.

saying that the -- the entire system, the way that it's

set up -- you know, because if I didn't have a

computer, if I were --

THE COURT:

Yeah.

MR. FERREIRA:

I'm just

I know.

-- you know, someone of age or

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something like that, you know, how else would I be able

to file?

online because of different --

THE COURT:

MR. FERREIRA:

If I can't file in person,

I know it.

-- I'm restricted in whatever

way --

THE COURT:

MR. FERREIRA:

I can't file

You are absolutely -That it kind of makes it

difficult.

THE COURT:

Yeah.

You're absolutely

preaching to the choir, Mr. Ferreira, which is why

we're -- we're making alternatives available to those

who don't have the electronic capability to do that,

which you thankfully were able to do.

please don't interpret my remarks as being in any way

critical.

different perspective, a concern.

MR. FERREIRA:

THE COURT:

But ple --

I -- it -- we're both recognizing, from a And with our --

Right.

With our crossed fingers,

hopefully those restrictions will be lifted.

this point, everyone was able to operate within the

confines of what is required under the COVID

restrictions going forward.

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MR. FERREIRA:

But at

So go ahead, Sir.

Okay.

So -- so I just

basically, you know, want to summarize.

So you know,

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our -- you know, the other side is claiming that she

cannot run in the second.

because she just moved.

because she moved 10 blocks away, are we completely

disqualifying her?

She can't run in the third She moved 10 blocks away.

I would also again like to take account that,

you know, the -- the requirement reside -- residency

requirement should be as of the November 2021 date.

That is the date of the general election as opposed to

a Democratic party primary.

you know, a primary just determines the candidate of

each party that will run in the actual general

election.

They're two different --

And again, I'd like to say, you know, this is

-- I believe -- I -- you know, our side believes that

this is a sub -- a subversion of democracy because we

are claiming, by their argument, in nature, that she is

not qualified to run for office.

disqualified from running for office because she cannot

run for either ward at this point.

She is -- she must be

Where she lived, and where she lives now.

That's what we're saying.

She's a lifelong citizen of

the -- of the state, of -- of the Town.

rightful citizen.

able to exercise her duty as a citizen.

She was born here.

You know, a She should be If she feels

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that she wants to run for office, we should allow her

to run for office.

We also have to remember the residents who

signed for her, who stated that they want her to run in

their ward.

signed her petitions, who legally signed her petition,

and the Town Clerk verified those signatures and she

came to the conclusion that those signatures are valid.

So we should not discount those signatures and those

So we cannot shut down the people who

petitions as well.

And then -- and then I also wanted to say

that from everything that we have heard today, our side

does believe that this is a concerted effort and a

conspiracy based on the party of the Town, the Mayor,

who is the same person, and also the Town Clerk, who

works for the Town and that was placed in an awkward

position.

I'm not blaming anything on the Town Clerk.

myself that should I be elected, I will do my hardest

-- I will work my hardest to never put her and her

colleagues in that position.

So -- and -- and that's pretty much, I rest my case.

I'm not blaming anything on Ms. Carpenter;

THE COURT:

MR. FERREIRA:

THE COURT:

I told her

So I do not blame her.

Mr. Ferreira, thank you -Thank you.

-- very much.

Mr. Ferreira, I'll

Page 26

just note for the purposes of the record that although

I was happy to hear your arguments, there are a number

of evidential infirmities within certain things that

you've said.

please, if you understand these concepts, please let me

know.

explain a couple of things that I -- I have heard that

are -- are somewhat problematic.

You probably had heard the term -- and

I don't mean to be pedantic, I just want to

When you speak in terms of what somebody else

told you, when you specifically make reference to I was

told numerous times in responses to when you needed to

drop the petitions off, that would be considered

hearsay, and it -- it deprives the other side of the

opportunity to be critical by way of cross examination

of those -- those statements.

I -- I don't ask you to backtrack or

eliminate anything that you have already said to me,

and I have listened to everything that you have said.

However -- and -- and I am able to separate that which

is evidential versus what is hearsay and therefore,

would be non-evidential.

have had the right to object to anything and he

probably wanted the record to be clear, which is

probably why he didn't object, the issues with regard

to what might also be considered speculative and not

Mr. Castano would, of course,

Page 27

based on any tangible evidence, but I'll -- I don't

mean to put words in his mouth and I'll hear him if --

if he agrees with that sentiment when I hear from him.

But again, I -- I've heard what you said, Mr.

Ferreira, and I -- and I thank you.

Ferreira is --

MR. FERREIRA:

THE COURT:

Ms. Campos, Mr.

Thank you, Judge.

-- the -- is a -- is a named

plaintiff to this, but in effect is an ancillary party

to the application and really, this is truly your

application, Ms. Campos.

hear Mr. Ferreira's arguments, I'm going to ask you,

Ms. Campos, to please raise your right hand.

A L E X I S

15 16

And although I was happy to

C A M P O S, PLAINTIFF, SWORN

THE COURT:

Thank you.

And may I just have

your name for the record, please?

MS. CAMPOS:

THE COURT:

Alexis Campos. Ms. Campos, thank you very much.

And Ms. Campos, the reason why I have placed you under

oath is -- and you may have picked it up on Mr.

Castano's submission, that the things that were said

within the -- the submission that you have made, other

than the Verified Complaint, were not certified, which

means that they were not set forth under oath.

Now, there have been a number of things that

Page 28

Mr. Ferreira has said that you have agreed to, like the

fact that you've been a resident for 39 (sic) years,

born and raised in Kearny, have the petitions, et

cetera, that I can't place any evidential weight to

because that's what Mr. Ferreira has said.

you are now under oath --

MS. CAMPOS:

THE COURT:

But since

Right. -- and you wish to -- presumably,

you wish to address the Court and I'm happy to hear

you, anything that you will be saying will be under

oath and therefore will be considered by way of a

certified statement, which means that you would be

subject to the pains and penalties of perjury if you

were to knowingly misrepresent something.

are saying now is now considered, from what you say, as

long as it's not barred by hearsay or speculation,

evidential.

me, Ma'am?

But what you

So Ms. Campos, what would you like to tell

MS. CAMPOS:

Well, most of Mr. Ferreira's

points are my same, but I will repeat them.

I've been

a resident of Kearny, New Jersey for 36 years.

said 39 before.

You

I just wanted to --

THE COURT:

MS. CAMPOS:

THE COURT:

I did.

No.

-- (indiscernible) 36 years. Sorry.

Okay.

Thanks for --

Page 29

MS. CAMPOS:

THE COURT:

MS. CAMPOS:

So that's first of all. Okay. I did live in the Third Ward for

most of my life.

In August of 2020, I moved to Hickory

Street, which is located in the Second Ward.

election came about and I had been interested in

participating, I chose to run in the ward in which

lived.

run in a municipal election in the Town in which --

When this

I understand that it's every person's right to

where they reside, which I certainly do.

be able to run in the Third Ward, because I no longer

live there, so I would presume that the Second Ward is

the rightful ward that I should run in.

I would not

Now, some of the arguments that were stated

was that I have not been a registered voter in this

ward.

That's when I completed my registration for my new

address.

with mail forwarding and whatnot, you have a six-month

leeway here.

And I did register in March 9th of this year.

I understand that once you move, especially

They're arguing that I voted in the November

election.

What I voted in was the presidential

election.

I did not vote within the municipality

because I didn't feel it was my right to do so.

that -- being that I did move, I didn't feel that I had

Being

Page 30

the right to choose someone for the Third Ward when I

was no longer residing in it.

I wanted -- I wanted the Court to know as well.

So that's just something

I'm a little disheartened because this case

is being brought up and it basically states that I can

run as -- I can run for a Mayor position, but I cannot

run (indiscernible) council simply because I did move.

And again, it's disheartening, and it's a little

upsetting to me, especially considering that I consider

the Mayor's position as county chairman and also as the

Mayor to be a conflict of interest.

as the Mayor, which I understand, and I fully accept.

He is objecting as the county chairman or County Clerk,

which is his right to do so.

wears both hats, to which he has a gain from.

He's not objecting

But it's the fact that he

He's running in the same election that I'm

running in, so everyone's objective in any kind of

electoral process is to win.

serve him should there be less opponents, or no

opponents, running against him.

disheartening, especially considering that the party

I'm running against, Mr. Konopka, was not objecting to

my running.

24 25

And it would only better

So that was

It was also a little upsetting that my petitions were accepted by the Town Clerk and then

Page 31

later objected.

I usually check my emails in the

morning and then again in the evening, and when I saw

Ms. Carpenter's email to me with the objection, I was

given a three-and-a-half-hour window to respond.

the mother of a four-year-old.

(indiscernible) that I have to pay attention to.

don't always have the -- the leisure to just check my

-- my own personal email freely.

objection, it was well after the time of Town Hall

I do have I

So when I saw this

closing and well without -- three-and-a-half-hour

limit.

I'm

So when I -- when I saw this, I was -- I was

a little bit shocked and I had responded as soon as I

was able to, which was that evening.

morning, I responded with proof of my residency, proof

of my re-registering in the Second Ward, and I even

made a point to go to Town Hall with Mr. Ferreira to

present our case in person.

And the following

And again, I -- I want to reiterate what Mr.

Ferreira said before.

We have no objection to Ms.

Carpenter or anything she did.

do and she is doing her job to the best of her ability.

So this is in no way -- this is no way negative towards

her.

a little bit confusing with everything that was going

She simply has a job to

She has a job, she must perform it.

And so it is

Page 32

1 2

on. I'm just -- and again, I'm a little bit

disheartened at the date of objection.

It was filed on

April 9th.

at 4:57 p.m. when I received the final email, which is

three minutes to when her office presumably closes,

when, again, for 36 years, I have never been able to go

to this Town Hall after 4:00 p.m.

a.m. and 4:00 p.m.

I wasn't notified until April 14th.

It was

It's between 8:00

So her office closing at 5:00 p.m.

when the rest of the building closes at 4:00 was

unbeknownst to me and to Mr. Ferreira, and to most

people I've spoken with in Town, which I understand

it's hearsay, but I was curious about that myself.

So I would just like to close my statement

with saying I -- I would like to run for the Town of

Kearny because being a resident for 36 years has

allowed me to see things, interact with people, know

people; I'm a part of the PTA.

good for the Township.

competition.

want to see changes in the Town that would benefit the

community as a whole.

Ward, in which way or which position may I run to -- to

make this better, to -- to participate and become an

acting part of our community?

I think I could do some

I'm not looking at this as a

I -- and may the best man win.

I just

If I can't do so in the Second

That is what I would

Page 33

like to know.

THE COURT:

Ms. Campos, thank you very much.

Ms. Campos, before I hear from Mr. Castano, tell me

about these signatures that you received from residents

of the Second Ward.

MS. CAMPOS:

Sure.

We're required to receive

25 named petitions to run on the council.

So I went

from door to door, from home to home.

residents that had specific issues wished to speak with

Specific

me.

other cases, he was not.

doing.

-- on which we were running, about some changes we

would like to make, things that they'd want.

they discussed with me things they would want done,

some points which I agree upon, some which I had never

experienced.

is great flooding issues and sewage backup, which is a

serious health concern.

In certain cases, Mr. Ferreira was with me.

And I told them what we're

He spoke a little bit about the platform that

And then

There's an issue on Sanford Avenue, which

MR. CASTANO:

Judge, I'm going to -- I'm

going to object to this test -- Judge, I'm going to

object to this testimony.

extremely polite, but we're going far afield of the

issues in the case.

THE COURT:

Yeah.

I've been trying to be

I'm -- I'm just asking --

Page 34

I'm going to sustain the objection.

I'll ask you to do is just -- I understand -- the --

the number was what I was interested in.

got 25, which is what was required.

these individuals within the -- the ward, I assume?

And it has to be.

7 8 9 10

Are they -- are

Oh, yes.

They all live in the

You're required 25, and I was well above that. THE COURT:

Very good.

How many did you

gather?

11 12

You said you

Right?

MS. CAMPOS: ward.

Ms. Campos, what

MS. CAMPOS:

I would say it was close to 50

if not more.

THE COURT:

Okay.

Very good.

Is -- is it

more?

about that, but not -- if you can't give that to me, I

understand.

17 18

I'm -- I'm looking for some level of precision

MS. CAMPOS:

I'm so sorry.

I couldn't hear

you.

THE COURT:

Oh.

I'm sorry.

There -- I'm

looking for some precision as to how many you actually

gathered from the -- from the residents of the Second

Ward.

23 24 25

MS. CAMPOS:

I'm not sure of the total tally,

but it was -- it was around -- in or around 50. THE COURT:

50.

Okay.

That -- that's fine.

Page 35

Okay.

Ms. Campos, thank you very much.

2 3

MR. FERREIRA:

Judge, I -- Judge, I'm sorry.

I just wanted to add to that.

THE COURT:

MR. FERREIRA:

THE COURT:

Mr. Castano?

I -- it --

Well, Mr. Ferreira, it -It --

That's -- mis -- Mr. Ferreira,

I'm sorry.

It doesn't work that way.

we'll hear -- just so that the record is clear, okay?

I will come back to you so you can add what --

MR. FERREIRA:

THE COURT:

MR. FERREIRA:

THE COURT:

What we'll do is

Okay.

-- whatever you need to. Okay.

But let me just make sure that

Mr. Castano has an opportunity to be heard, and then

you can be heard, anything else that you'd like to tell

me.

Mr. Castano?

MR. CASTANO:

Judge, thank you.

I'll be

brief.

The first thing I just do want to address, I do

join in Your Honor's I guess perception of what my

objections probably would have been.

big effort to be courteous to the parties, especially

in light of the fact that they are pro se.

of course, because we're conducting this proceeding

telephonically, I didn't think it would be helpful to

the Court for me to be lodging objections regarding

I was making a

And also,

Page 36

hearsay and speculative argument and arguments that are

not contained in their papers.

Honor is more than more than competent and qualified to

separate that which is admissible and permissible from

that which is not, and so thank you for pointing that

out, and I -- I just wanted to -- I just wanted to note

that.

8 9

Obviously, I know Your

Judge, essentially, I've heard parties' arguments.

People are disheartened or they feel things

should be done a certain way or should be done

differently, but for -- for better or for worse, that's

just simply not the law.

I think that the certification that has

submitted on behalf of Ms. Carpenter as well as the

letter brief in support of it fairly plainly sets forth

what the laws and the procedures are.

there's any question that Ms. Carpenter followed the

laws and procedures to a T.

I don't think

And as a matter of fact, I think she went

above and beyond that which she was required to do.

And by -- by that, I mean that she did consider the

additional information that had been submitted by Ms.

Campos and nonetheless, she did make a determination

based on the facts in front of her by applying the law

as it exists today, that the residency requirement had

Page 37

not been submitted.

I understand the arguments that are being

made with regard to which date governs, but most

respectfully, if the statute meant to govern the

general election, it would have simply said the general

election.

excuse me, that the change of residency in September

would have had to have been before the June 8th, 2021

primary qualifier.

And so it would appear that the June --

And the fact that there seems to -- not seems

to have been, there has been an incident where Ms.

Campos voted in the 2020 election from a different

address.

you look at it -- I don't mean you, Judge.

either way a person were to look at it, I don't think

that the candidate has complied with the law and I

think that the Clerk's decision is -- is supported by

the facts that were placed before her and that it was

governed by the law as it exists.

I think that poses a problem.

So either way I mean

And for those reasons, and unless Your Honor

has any additional questions, we would submit based on

the papers submitted.

THE COURT:

very much.

perspective.

Mr. Cam -- Mr. Castano, thank you

I do have one question from a substantive Mr. Ferreira and Ms. Campos rely

Page 38

significantly in their written submission on Callaway

versus Samson, which is, this Court will note, a

District Court opinion from 2002 that was issued by

Judge Orlofsky.

It is found at 193 F.Supp. 2d 783.

The Court is aware that this decision has

been made and essentially represents the only decision

that has examined the statutory provision that Judge

Orlofsky ultimately concluded, among others, and that

is N.J.S.A. 40A:9-1.1, 1.2, and 1.3, as rendered,

unconstitutional.

is with regard to the holding and the import of this

particular case on this controversy.

And I wondered what your perspective

MR. CASTANO:

Thank you, Judge.

As we

pointed out in our letter brief, certainly, the judge

is a -- that judge is a well-respected jurist, but

regardless of that fact, there's two important things

-- at least two important things, or three important

things to note.

binding on this Court in any way; it's just a United

States District Court decision, so it has literally

zero precedential value.

judge's decision, but it's not precedential on this

Court, and I think that's a better way to say it,

number one.

First of all, it's certainly not

I didn't want to degrade the

Number two, the -- the decision itself

Page 39

specifically limit it -- limited it to the facts of

that particular case.

Court's decision.

That was noted early on in the

And I think perhaps most importantly, number

three is the fact that despite that decision, the --

the statute is still good law.

that the Town Clerk in this case or a Town Clerk in any

other case has a choice other than to follow that law,

unless and until the Legislature changes it or some

I mean, I don't think

court were to find it wholly unconstitutional.

Obviously, Your Honor, as the jur -- the --

may view things differently and -- and, you know, can

make rulings as the Court sees fit, but with regard to

what the Town Clerk was obligated to do, I would most

respectfully submit that she had no choice but to

follow that law.

She doesn't have a discretion.

The statute -- the statute doesn't vest her

with discretion.

-- it's interesting, the way it's written, at least I

found it interesting in the way it's written.

Something along the lines of -- I don't have it in

front of me, but she must first pass upon the objection

-- and she -- it doesn't say she has discretion to do

research or make determinations.

I think it's words to the effect of

But, you know, certainly we're aware of that

Page 40

decision, but I'd be repeating myself if I go any

further.

think that it might not be applicable in this case.

I've given I think the three reasons why I

THE COURT:

Mr. Castano, thank you very much.

Mr. Ferreira, what I'm going to ask you to do is --

anything that you -- of course, you want to tell me,

I'll be hear you.

nomenclature that I had used with Mr. Castano, you may

not be familiar with.

And -- but some of the -- the

And again, it's not my intention

to be pedantic and please let me know if you're aware

of this.

The -- if you had to put in air quotes the

law, the law that controls the decisions of courts is

not only made by the Legislature and signed by the

governor; that is, our statutes, but it is also a

component part of that, what the courts have said as to

the constitutionality of a particular issue.

And when Mr. Castano uses the term

precedential, he is advising me that -- and what he is

saying is that the -- the Court, this Court, cannot

rely on the Callaway decision because it is non-

precedential.

that no either unpublished cases or those that are

outside of our jurisdiction can be relied upon as

precedent for a deser -- a determination that is made.

We have a court rule, 1:36-2, which says

Page 41

Now, that doesn't -- and there's a

distinction that's made between precedential and

binding and -- versus what is only persuasive.

Callaway decision would only be persuasive.

always my intention to make sure that parties who may

not have formal legal training certainly understand

what is being said because I think -- I feel that

that's the only way to balance the -- the -- the

playing field, as it were.

So the

So it's

So again, Mr. Ferreira, if you're aware of

this, please -- please let me know that.

But I would

be asking you this question as to how you believe that

Callaway is important to this litigation, and then I'd

be happy to hear you with re -- anything else that you

want to tell me.

Ferreira?

Mr. Ferreira, are you there?

MR. FERREIRA:

THE COURT:

I'm sorry.

That's okay.

Mr.

I had it on mute. I -- and sorry,

because I've been, like -- I've been reading and --

and, you know, doing the campaign.

know, I have a lot of information that I have right

now.

and what I'm trying to say is that, you know, the local

unit should not be the individual ward itself, because

the -- the -- the ward -- because each council member

So it's -- you

But it's -- so it defines a local unit.

And --

Page 42

votes on town-wide issues, so we should not limit the

local unit to the individual ward.

local unit here, local, when I heard the word local,

any time someone says local, I think municipality.

Everything thinks -- I'd be very -- you know, a ward is

simply, you know, an electoral district.

unit, local government, is your municipal government.

We don't have a ward government.

thing.

It should be -- the

But a local

There's no such

You know, Ms. Campos, if she becomes, or Mr.

Konopka holds onto his seat on the Second Ward, they do

not govern the Second Ward.

decisions based on the entire Town.

we -- where else are we saying that -- that Ms. Campos

can run?

-- where -- where can she run to represent her Town?

Because that's what she's doing as a council member.

She is more so representing the Second Ward, yes, she's

bringing the issues of the Second Ward forth, but she

is representing the Town as a whole because she listens

to town-wide issues and she would be voting on town-

wide issues.

They -- they make So where else are

If she cannot run where she lives, then where

So that's what we are arguing about the local

unit.

If we -- if we want to get specific, the local

unit should consist of the Town itself, not the

Page 43

individual ward.

THE COURT:

Thank you, Mr. Ferreira.

there anything else that you'd like to bring to my

attention?

MR. FERREIRA:

No.

I -- I also just wanted

to note that -- unfortunately, Ms. Campos is not aware

of the total number of petitions because I submitted

some on her behalf as well.

not sure about -- I'm pretty sure on her specifically,

but I did submit one for everyone, you know, that I had

gathered -- that we had gathered together but that I

was holding.

mixed in my pile.

that were procured from, but -- but I still had in my

possession.

aware of -- of the -- of the number.

I submitted some on -- I'm

You know what I mean?

I -- I had some

So I did hand in some that were --

So -- so that's why she may not be fully

THE COURT:

Okay.

So is it -- is it

substantially more than the 50 that Ms. Campos has

verified, or -- or --

MR. FERREIRA:

No.

I don't -- I don't think

so, but I don't want it to be held against her if it is

THE COURT:

No, no, no.

MR. FERREIRA:

THE COURT:

-- less than 50 or --

No, no, no.

Page 44

1 2 3

MR. FERREIRA:

-- more than 50.

what I mean? THE COURT:

No, no, no.

That -- that was not

my intention.

something like that, that would be --

I mean, if -- if the issue were 500 or

MR. FERREIRA:

THE COURT:

MR. FERREIRA:

THE COURT:

Right.

-- very different -No, no, no.

-- than -- than 50 versus the 25

that is the minimum required.

for the question.

anything further, Sir?

Yeah.

MR. FERREIRA:

THE COURT:

MR. FERREIRA:

THE COURT:

17 18

You know

That was the only reason

Okay.

No.

Mr. -- Mr. Ferreira,

Not at this time.

Thank you, Mr. Ferreira. Thanks, Your Honor.

Ms. Campos, anything further?

I'll give you the last word, Ma'am. MS. CAMPOS:

The only other thing I wanted to

say was it is my understanding that the last day to

I can participate as a voter, I don't see why I can't

participate as possibly a council member.

what Mr. Ferreira was saying before was just simply --

I mean, again, he did submit a few petitions on my

behalf, so I wasn't sure of the exact number, so I

And if

And what --

Page 45

apologize for that.

THE COURT:

MS. CAMPOS:

THE COURT:

I should have had that -No.

That's -- that's --

-- before you.

I did not.

-- okay, Ms. Campos.

Don't --

please.

for specifics, it is -- it is not something that is

dispositive.

8 9

It -- it was not -- even though I had asked

Sorry to interrupt.

MS. CAMPOS:

Okay.

And my last thing is just

very simply that I was accepted as a council member.

was accepted as a participation (sic) in this -- in

this election, until that objection took place.

that objection not been logged, there wouldn't have

been any issue here.

So had

So I just wanted to bring that forth as well

because I was accepted.

ballot and now, as a result, what we're fighting for is

for me -- for me to be named.

objection not been logged at all by Mr. Santos, and I

use Mr. Santos, not Mayor Santos, because he used it in

a different power, this -- this would have never been

an issue.

wanted to bring that to your attention as well, Your

Honor.

24 25

I was supposed to be on this

So had this not --

It would never have been a thing.

THE COURT:

So I just

Ms. Campos, thank you very much.

I've already placed the procedural history of this

Page 46

matter on the record.

Complaint, the plaintiff, who is the -- the one for

whom this Court will give the most scrutiny, and that

is Ms. Campos, submitted a verified and executed

petition to be considered as a candidate for Town

council from the Second Ward in Kearny, New Jersey.

The primary is scheduled for June 8th, 2021.

8 9

Now, according to the Verified

From the Verified Complaint, I take these facts as well.

On April 9th, 2021, the next day, the

defendant, Alberto Santos, filed an objection to the

petitioners, noting that one, she was not a registered

voter in the Second Ward in Kearny and two, did not

meet the eligibility requirements that she be a

resident of that local unit for at least one year

before the date on which the election for office would

be held.

A number of days later, on April 16, 2021,

Patricia Carpenter, who is the Town Clerk of the Town

of Kearny, rejected the petition of Ms. Campos.

Campos seeks emergent relief in this action, ordering

and adjudging that the defendant, Ms. Carpenter, erred

in her rejection of the plaintiffs' peti -- petition

and ordering and adjudging that Ms. Carpenter and E.

Junior Maldonado, the Hudson County compatriot, be

required to place Ms. Campos' name on the ballot for

Ms.

Page 47

the primary election on June 8th, 2021 as a candidate

for council in the Second Ward in the Town of Kearny.

Ms. Carpenter, in response, provides a

certification.

she notes that she is the registered Municipal Clerk

and has served the Town of Kearny since I believe it

was 2010.

last day for the filing of the petitions for the 2021

primary election was April 5th, 2021, with the primary

And according to that certification,

She notes that under N.J.S.A. 19:23-14, the

scheduled for June 8th.

On February -- pardon me, on Friday, April 9,

2021, at 4:57 p.m., the Regular Democratic Organization

of Kearny filed objections to the petition filed by

Alexis Campos for the Democratic nomination for the

Town Council in the Second Ward.

12:17 p.m., Ms. Campos sent -- pardon me, Ms. Carpenter

sent an email to Ms. Campos with a copy of Ms.

Carpenter's objection and requesting Ms. Campos'

response to it a number of hours later, Ms. Campos says

about three and a half hours on the same day which, by

my math, would be exactly the -- that same time frame.

On April 13, 2021 at

Apparently, Ms. Carpenter believed that her

obligation under N.J.S.A. 19:13-11 was to determine the

validity of objections on or before the 9th day after

the last day for the filing of the petitions.

That

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date would have been April 14, 2021.

Ms. Carpenter also avers that she reviewed

the voter registration sheets from the November 2020

general election and the N.J.S.V.R.S. online

registration system and those records indicated that

Ms. Campos' address was 9 Stevenson Place in Kearny.

That is located in District 5 of Ward 3.

noted to be an unaffiliated voter in Ward 3 as of

November of the 2020 general election.

She was also

Ms. Carpenter

therefore concluded that based on N.J.S.A. 40:A:19-1.13

(sic) that Ms. Campos was not eligible to run as a

candidate in the Second Ward.

After emailing Ms. Campos about this fact,

Ms. Campos advised that she had recently moved to 266

Hickory Street, located in the Town of Kearny, which

would be in Ward number 2.

Joseph T. Negron, who was copied on the

email, also advised that -- Ms. Campos advised, excuse

me, Ms. Carpenter that Ms. Campos had timely filed --

pardon me, had timely registered to vote and updated

her address as of March 9, 2021, but the record not --

had not yet been processed because of other pending

matters.

indicates that the starting date of her residency in

the Second Ward was as of September 1st, 2020.

Ms. Campos does provide a lease that

Page 49

In support of their application, that this

Court received as part of their filing on April 19,

2021, the plaintiff notes in summary that the one-year

residency requirement applies to state-run general

elections in November and since the primaries in June,

they're noted, are party-run contests, par -- bound by

the rules and the regulations set forth by the

respective political party, not the State, that

essentially the -- the statutes that govern the

residency requirements and the durational residency

restrictions that are really the issue in this matter

should not apply.

However, no support is provided for that --

that assertion, other than the argument that is made;

no case is cited and no statute is cited.

therefore cannot rely on that particular argument to

essentially say that the election law -- laws that are

under scrutiny here do not apply just because it is a

primary.

This Court

Factually, Ms. Campos argues that if Ms.

Campos wins the pro -- the primary and that she is

placed on the ballot for the November 2021 election,

she will have met the residency requirement by that

date.

not speak in terms of eventual probability of

Similarly, the Court notes that the statute does

Page 50

residency, it speaks in -- instead of the residency in

retrospect, that the primary requires, or the

eligibility requires a one-year residency before a

person is placed on the ballot.

The plaintiff also argues that the local

unit, as that term is defined, is the entire town and

is not the local ward for which Ms. Campos specifically

seeks election.

argue that there are a number of conflict of interests

-- conflicts of interest, excuse me, resulting from the

actions that were taken by the defendant.

those purported conflicts of interest in their oral

argument now.

And also, Mr. Ferreira and Ms. Campos

They assert

This application was opposed and the Town

addresses each of the arguments that were set forth by

the individuals.

to place me on mute, or your phones on mute, the

background noise will clutter the record and I want to

make sure that the record is clear.

while you place your phones on mute, please?

Thank you very much.

Folks, if I could ask you please just

So I'll just pause Okay.

In summary, the defendants, in opposition,

contend that the defendants' arguments as to the --

pardon me, the plaintiffs' arguments as to the

conflicts of interest, the issues addressed under

Page 51

Callaway versus Samson, 193 F.Supp. 2d 783 of the

District of New Jersey in 2002, and the alleged -- what

is purported to be by the plaintiffs a coordinated

effort, as they term it to be, by the Town of Kearny to

hinder a campaign and that they have been the victim of

a subversion of democracy and a coordinated effort of

conspiracy by the -- the named defendants lack merit.

That is a summary of the defendants' arguments.

The defendant also notes and brings to the

Court additional considerations, as they characterize

them to be, and set forth including that Mr. Ferreira

lacks standing in this matter; that Mr. Santos, Albert

-- Mayor Alberto Santos, named individually, should be

dismissed since the Complaint should have been filed

against the Regular Democratic Organization of Kearny

by statute N.J.S.A. 19:5-2.

As I had noted in the -- previously, there

has been no certification that has been provided by the

plaintiffs in this matter.

more procedural aspects, Ms. Campos did testify before

this Court under oath and I am considering her

statements that are made as a certification.

not something in writing, certainly, I have been able

to listen to what Ms. Campos has told me.

find that much of what she said is evidential.

However, not to rely on

Although

And I do

Page 52

Ms. Campos has been a resident of the state

of New Jersey for her entire life and has indicated for

the last 36 years, has been a resident of the Town of

Kearny.

in the Third Ward but has recently moved to the Second

Ward, where she has established her residency.

She's indicated for the most part, she's lived

There is some question of fact as to whether

that residency began as of the date of the lease that

was provided by the defendants, which was presumably

provided by the plaintiffs to the defendants to

substantiate the residency requirement that began on

September 1st, 2020.

acknowledgment, although this Court cannot impose

anything other than a recognition that it may be

problematic that if Ms. Campos is voting outside of the

ward as part of the general election in November of

2020, that that is a distinction without a difference.

There is, however, a -- a question,

And there's also an

therefore, factually as to whether the September 1st

date is the residency require -- is the beginning of

the residency, or is it of November.

essentially be November 20th because that would be the

only specific date that would otherwise have been

prevented -- presented as a benchmark as to when Ms.

Campos' ward residency, either in the Second Ward or in

It would

Page 53

1 2

the Third Ward, was triggered. So -- and it becomes a question because if

the -- if the plaintiffs' position is that the

residency at the time of the general election, if Ms.

Campos was successful as part of the primary, and

assumes the responsibility of -- as the representative

of ward number two, that it's possible that during that

-- that time -- pardon me, not possible during that

time, but that she would be a valid resident and meet

the residency requirements.

That calculation of time

is I think going to be factually-based as to whether it

was the November -- in the November election or -- or

from -- from September, as of September 1st, when the

effective date of the lease is.

acknowledge that because that is a factual concern that

this -- that this Court has.

And -- and I just

The first thing that this Court wants to say

is I very much appreciate the statements that are made

by Mr. Ferreira and Ms. Campos as to the responsibility

of good citizens to participate in their government.

-- I don't -- I wish more individuals would take an

active interest in any decision-making opportunities or

represent -- or -- or stand in a representative

capacity to other individuals, constituents, as they

were, on matters of public concern.

Page 54

I think that -- and I -- and I don't mean to

step on a soapbox here, but I will just note

parenthetically and editorially that that is something

that may be missing within our society today, and that

is the ability of people to step forward and have their

voices be heard with regard to this -- about any

issues, public -- pardon me; any issues of public

concern.

And so to that point, I want to congratulate

Mr. Ferreira and Mr. -- and Ms. Campos for stepping

forward to participate in the electoral process and the

democratic process and the election process that is --

is under scrutiny here.

Our election law is found in Title 19 of our

statutes, our Revised Statutes, characterized as

N.J.S.A. New Jersey Statutes, Annotated.

N.J.S.A. 19:13-12, it reads in pertinent part that any

judge of the Superior Court shall hear any application

in which any "invasion or threatened invasion" of that

person's rights under their petition of nomination 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 the Complaint.

According to

There are some temporal concerns that this --

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that this Court has, specifically as to the in -- Ms.

Campos being informed as to the objection, the lodging

of the objection and the reason why it took

approximately four days for her to be informed of this.

The Court notes with curiosity that the application or

the -- the objection was filed, notwithstanding timely,

but three day -- three minutes until the conclusion of

that period on the 9th.

It was then, based upon what I read in Ms.

Carpenter's certification on the advice of counsel,

that she, meaning Ms. Carpenter, immediately informed

Ms. Campos, I think the term was used forthwith in the

certification, and provide Ms. Campos with an

opportunity to be heard with regard to the objections.

Ms. Campos, notwithstanding the personal

inconvenience that she may have had with regard to the

filing of her response, did file a response, and what I

might characterize as a substantive response.

not a two-letter -- a two-line, two-sentence

notification to the plaintiff, but it was some --

pardon me, to the defendants, but it was something that

had -- based on thought and reason and circumspect and

seemed to meet the requirements.

required, she provided more.

It was

Although less was

Ms. Carpenter then made the decision, as she

Page 56

believed that it was necessary to, and although I have

recited N.J.S.A. 19:13-12, to decide this matter as a

Superior Court judge in a summary way, Ms. Carpenter

also had the responsibility under the statutes to

decide the matter in a summary way as well.

Mr. Castano notes I think persuasively in his

oral argument and his oral presentation that Ms.

Carpenter didn't essentially have the discretion to do

research as to what was being presented to her.

If I

might be glib again, it was not her job, as Mr. Castano

has indicated in his oral presentation, as to what Ms.

Carpenter's responsibility was.

rely upon what the statutes said and therefore operate

as to the stat -- as to what the statutes required.

Ms. Carpenter had to

What is at issue in this particular

litigation is N.J.S.A. 40A:9-1.13.

That statute is

titled Eligibility for Candidacy or Appointment to

Become a Local Elec -- or to a Local Elective Office.

It reads in pertinent part and by way of summary that

no person shall be eligible to become a candidate for

any local elective office unless that person is

registered to vote in the local unit to which the

office pertains and has been a resident of that local

unit for at least one year immediately prior to the

date upon which the election for the office is to be

Page 57

held.

The statute refers to a local unit.

particular statute does not define local unit, but the

local unit is defined in N.J.S.A. 40A:9-1.11.

According to that statute, a local unit is in a county

or municipality and whether a -- an office is required

to be filled by election from a district, ward, or

other subdivision means the district, ward, or

subdivision to which the office pertains.

That

This Court therefore must follow what the

statute says.

durational residency restriction that would be required

to be followed by Ms. Campos.

and does not disagree with the fact that she does not

at the present time in which she is sought -- for which

her candidacy is sought is to -- has met the -- the

durational residency requirements.

simply, lived in the Second Ward for the year prior to

the -- the date upon which the relection -- the

election for office is to be held.

And the statute does provide a

Ms. Campos factually,

She has not, quite

And the election for the office, I -- I

understand what the -- the plaintiffs are arguing, is

that the controlling date should be the -- should be

the general election and looking past from -- looking

behind that.

However, the -- nothing has been

Page 58

presented to me, nor am I at liberty to speculate as to

what the Legislature meant.

principle that when the Legislator speaks -- the

Legislature speaks in the creation of our statutes,

that the plain language, as is set forth here, is to be

binding upon the Court.

A -- there is an oft-cited

I have not been presented with any

information to suggest that the date on which a elected

office is to be sought is only for the general election

and would therefore have to conclude that a primary

election being the scrutiny of any electoral process or

the decision being made by the voters, which would

include the primary for which Ms. Campos now seeks to

be -- to be noted as the -- as the candidate, would

control.

Therefore, the June 8th, 2021 date, this

Court finds, is the operative date.

Ms. Campos has

only been a resident of Ward 2 in Kearny for a short

period of time, giving her the benefit of the doubt

that it was on September 1st, 2020 that she became a

resident based on the submission that she has provided

by way of the lease to suggest that that one-year time

frame would have had to run as of September -- would

have -- she would have had to live within that ward at

least of June 8th of 2020 in order to be eligible for

Page 59

the primary consideration on June 8th of 2021, pursuant

to the -- the statute.

Now, substantial reliance, this Court notes,

is placed by both parties on -- for different reasons

on Callaway versus Samson, which is 193 F.Supp. 2d 783

(2002), which is a District Court matter that was

issued in 2002 by Judge Orlofsky, a trial court judge

in the District of New Jersey.

Now, on the facts that were presented in that

matter, Judge Orlofsky very clearly decided that

N.J.S.A. 40A:9-1.1, 1.12, and 1.13 are

unconstitutional.

were as applied to Mr. Callaway in that particular

matter.

However, he also noted that they

The Court has had an opportunity to review

Callaway versus Samson and will note preliminarily that

which is argued by the plaintiff (sic).

out-of-jurisdiction case, so it is not binding on this

-- on this Court.

decision that was made in 2002 and has not been

reviewed by the Third Circuit.

-- what might be considered a higher court reviews a

lower court decision or a trial court decision.

24 25

One, it is an

Two, it was a trial court judge

There is an import if a

But that fact notwithstanding, it has only been -- the constitutionality has only been scrutinized

Page 60

in the District Court of New Jersey and that does not

necessarily translate into a state court decision that

would be binding upon this Court.

the Appellate Division has not ruled on the

constitutional -- constitutionality of 40A:9-1.1, 1.2,

and 1.3 and this Court, as I noted at the beginning, ha

-- searched the -- and researched how Callaway may or

may not arisen within the context of other cases.

was only able to find one.

Or said differently,

And one of them was -- and

that was from the Supreme Court of New Jersey in what

is noted to be the In re Contest of November 8th, 2011,

which is found at 210 N.J. 29.

Now, the Supreme Court in that matter, in a

decision that was authored -- excuse me, pardon me for

one second, in 2012 did only make reference to Callaway

versus Samson.

the decision that Callaway made and is only

parenthetically referenced twice in that decision.

However, those parenthetical references do have some

import.

It did not focus specifically on the --

Constitutionally, this action that I know

that the plaintiffs have not argued, but might be

considered something that has to be examined under the

intermediate scrutiny basis and it would be required,

therefore, to show that as noted by the Supreme Court

Page 61

in the In re Contest of November 8th, 2021 (sic) that

the State would have significant interests as to any

durational residency requirements that were imposed

upon candidates for public office.

I note that the Supreme Court had indicated

on page 56 of that decision that these durational

requirements ensure that voters have the time to

develop a familiarity with the candidate, that they

ensure that the candidate can become familiar with the

constituency and the issues that are facing the people

to be represented, and that they operate as a curb on

carpetbagging.

Now, the facts and the circumstances that

raised the scrutiny of the Supreme Court to the parties

in in -- pardon me, in In re Contest of November 8,

2021 (sic) are admittedly different than are here and

the facts seem to be more ab -- consistent with that

which was considered in Callaway.

does fear -- does find, as the Supreme Court had noted,

that a one-year residency requirement does establish a

fair and not unduly-burdensome period for a new

residential candidate to become familiar with the

people and the issues of the district and conversely,

for the people to become familiar with a new resident

in the district.

This Court, however,

Page 62

Now, this Court will note with interest that

argument made by both Ms. Campos and Mr. Ferreira that

this is the Town of Kearny, a relatively small

municipality in the larger scheme of other urban areas.

This fact notwithstanding, and despite the fact that

Mr. Ferreira argues, again without support, that issues

that are voted upon by the Town Council are not

specific to the ward, the ward arrangement and

organization still remains in place in Kearny.

And based on the interpretation and -- and

the clear reading of the statute, since it is a ward

organization, the representatives of that ward would

have the responsibility to demonstrate that the

constituency within the ward are being heard.

although they may be voting generally on issues of Town

concern and importance, they would still have the

responsibility, under the ward organization, to

represent their constituents.

that's the way that the -- that the -- the

municipality, Kearny in this matter, has been arranged.

And

Rightly, or wrongly,

So although I appreciate the arguments that

are made by Mr. Ferreira and also note with -- with

interest and with some level of admiration to Ms.

Campos and to Mr. Ferreira that they were able to have

at least a small portion of the residents of Ward 2 to

Page 63

speak as to their preference of a candidate by way of

signing a petition.

not an overwhelming number of petitions that were --

that would otherwise reflect the overwhelming belief

that members of a constituency, that is, Ward 2,

essentially wanted Ms. Campos as their candidate.

This Court will note that it is

Now, this is more of a factual observation

than one to be legal -- than a legal conclusion, but it

certainly does focus on the fact that, notwithstanding

there's been a move of approximately 10 blocks, that

the need for Ms. Campos to become a inculpated or

involved member of what is in Ward 2 certainly has a

marginal impact on this Court's decision with regard to

this.

This Court will also note that this matter

comes before the Court on an application for an Order

to Show Cause.

order to obtain the emergent relief that is requested

for the plaintiffs to show by clear and convincing

evidence that there is an irreparable harm of -- that

they would be victimized by irreparable harm if I

didn't grant the relief that is requested, that there

is a reasonable probability of success on the merits of

the Complaint, that there is no factual dispute, and

finally, that the equities on balance and a weighing of

An Order to Show Cause is required in

Page 64

the hardships weighs in favor of their position as

opposed to the defendants.

This Court cannot find, under that calculus,

that the plaintiffs have met this significantly high

burden.

there is a factual issue, as I have noted, with regard

to the residency requirements.

doesn't, based on my review of the clear verbiage of

the statute and the clear mandate of the statute; that

Specifically with regard to factual issues,

Secondly, there

is, under 4A (sic):9-1.11, 2, and 3 that there is --

pardon me.

three, that there would be any reasonable probability

of success on the merits.

Excuse me.

Yeah.

Yes.

One, two, and

And although, as I have indicated -- and I

will circle back to this acknowledgment.

appreciate the circumstances that led to Mr. Ferreira's

assertions before this Court and Ms. Campos' presence

and involvement with the electoral process and her

appearance and presence and participation in this

litigation, the Court, however, only finds that the

equities are balanced.

Although I do

The -- the plaintiffs certainly have

established their interest in running for -- to be in a

representative capacity for their fellow citizens.

at the same time, the State has the responsibility,

And

Page 65

through the -- the Town of Kearny, to assert that which

is being required by our Legislature, and that is for

these -- well, one year durational residency

requirement.

will be denied.

And for those reasons, the application

Mr. Ferreira, what I will do is I will

provide you with a written order and you can take

whatever steps that you believe are necessary after

that.

I expect to have this written order to you by

three o'clock today.

Castano, is there anything further, Sir?

Looking first to you, Mr.

MR. CASTANO:

No, Judge.

Thank you.

-- Judge, I guess there is just one question.

apologize.

in its entirety by way of a summary proceeding?

Judge I

Will the Court's order dispose of the case

THE COURT:

It will not be a summary

proceeding, but the matter only asks for this Court to

make a determination as to whether Ms. Carpenter has

erred as a result of the actions that she took on the

16th of -- of April.

resolved as a result of this -- this application and I

don't believe that any further proceedings are

necessary, going forward.

That matter has I think been

MR. CASTANO:

THE COURT:

Thank you, Judge.

Mr. Ferreira, is there anything

Page 66

further, Sir?

MR. FERREIRA:

THE COURT:

MR. FERREIRA:

THE COURT:

I --

Mr. Ferreira? So --

Mr. -- go ahead, Sir.

No.

ahead, Sir.

MR. FERREIRA:

So -- so what we're -- so what

we're saying is that she is not qualified to be on the

ballot?

She can still run, but you -- but the Court

has stated that -- you know, the -- the objection has

gone forth and she cannot be added to the ballot?

THE COURT:

You've said a couple of different

things there.

application that the plaintiff has brought forth

seeking to have Ms. Campos placed on the ballot for the

primary election from the Second Ward in the Town of

Kearny Democratic primary scheduled for June 8th.

Okay?

objection.

Campos, is there anything that you'd like to say?

Anything further, Ma'am?

Let me just be clear.

I am denying the

And I -- I know -- I know that that's over your That's -- that's completely okay.

MS. CAMPOS:

No.

Ms.

I just want -- I want to

thank you for your time and I understand where

(indiscernible) coming from.

unfortunate, certainly.

It's a state law.

It's

Page 67

THE COURT:

MS. CAMPOS:

THE COURT:

MS. CAMPOS: I'm not sure.

Ms. -But I do want to ask you -Go ahead. Maybe you can or cannot answer

this.

to run in, or in what capacity would I be --

THE COURT:

MS. CAMPOS:

THE COURT:

In what ward would I be eligible

Yeah. -- during a recent move? That's a -- that's a difficult

question for me to answer, Ms. Campos, and -- and

although I appreciate you asking the question, I -- I

-- it would be inappropriate for me to answer it

because it would be me giving --

MS. CAMPOS:

I understand that entirely.

-- I didn't think you'd be able to, to be honest with

you.

THE COURT:

MS. CAMPOS:

THE COURT:

Yeah.

No.

I -- I got you.

I just -You -- you're -- you're -- yup.

You're asking a rhetorical question.

understand that.

record is clear, I -- it would be inappropriate for me

to give you any -- any advice, and that's really what

you would be asking me to do.

I -- and I

And I just want to make sure that the

MS. CAMPOS:

Okay?

I understand, Judge.

Thank you

Page 68

very much for your time.

THE COURT:

I appreciate it.

Thank you all very much.

And Mr.

Ferreira, I know that we have your email address

because you have -- you have communicated with the

Court.

Castano, I think your email is on your papers and we'll

copy you as well.

We will return your order that way.

MR. CASTANO:

THE COURT:

10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25

And Mr.

Thank you, Judge.

Thank you all very much.

we'll go off the record. MR. FERREIRA:

And

Cat, thank you very much. Thank you.

(Proceedings concluded at 2:52 p.m.)

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1 2

CERTIFICATION I, Sarah Fetz, the assigned transcriber, do hereby

certify the foregoing transcript of proceedings on

CourtSmart, Index No. from 1:33:10 p.m. to 2:52:07

p.m., is prepared to the best of my ability and in full

compliance with the current Transcript Format for

Judicial Proceedings and is a true and accurate

compressed transcript of the proceedings, as recorded.

9 10 11

/s/ Sarah Fetz

Sarah Fetz

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RedDoor Legal Services, LLC Agency

AD/T 626 AOC Number 04/23/2021 Date

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ago 12:8 agree 33:16 agreed 28:1 agrees 27:3 ahead 8:23,23 23:23 66:5,6 67:3 air 40:12 Albert 51:12 Alberto 1:8 4:5 7:14 46:10 51:13 Alexis 1:4 2:3 4:5 4:21 12:4 27:17 47:14 alleged 51:2 allow 11:11 25:1 allowed 32:17 allowing 13:14 alternatives 23:12 amount 14:2 ancillary 27:9 Annotated 54:16 answer 67:4,10,12 AOC 69:12 apologize 45:1 65:14 APP 1:3 Apparently 47:22 appear 22:2 37:6 appearance 64:19 APPEARANCES 1:18 2:1 Appellate 60:4 applicable 40:3 application 4:20,24 5:4,11,24 6:25 11:6,19 22:10 27:10,11 49:1 50:14 54:18,24 55:5 63:16 65:4 65:21 66:14 applied 59:13 applies 49:4 apply 13:5,6 49:12 49:18 applying 36:24 Appointment 56:17 appreciate 10:13 53:18 62:21 64:16 67:11 68:1 approximately 55:4 63:10 April 1:15 4:24 5:7 5:17 18:1,23 32:4 32:4 46:9,17 47:9 47:11,15 48:1 49:2 65:20 areas 62:4 argue 13:4 50:9 argued 59:17 60:22 argues 49:20 50:5

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