ADAM L.

SCHORR, ESQUIRE
SCHORR & ASSOCIATES, P.C.
5 SPLIT ROCK DRIVE
CHERRY HILL, NEW JERSEY 08003
(856) 874-9090 FAX (856) 874-9080
e-mail: adamschorr@schorrlaw.com
Attorney for the Plaintiff
Atty ID# 125622014
ALEXANDER J. LAW,
Plaintiff,

SUPERIOR COURT OF NEW JERSEY

CHANCERY DIVISION
CAMDEN COUNTY
CHANCERY DIVISION - GENERAL
EQUITY

v.
JOSEPH RIPA, CAMDEN COUNTY
CLERK; CAMDEN COUNTY CLERKS
OFFICE; and JOHN DOES 110(fictitious names of entities
and/or individuals whose
identities are presently
unknown), individually,
jointly, severally and/or in
the alternative,

DOCKET NO.:
COMPLAINT

Defendant.
Plaintiff, ALEXANDER J. LAW, by way of Complaint against the
Defendants, JOSEPH RIPA, CAMDEN COUNTY CLERK; CAMDEN COUNTY
CLERKS OFFICE; and JOHN DOES 1-10 states as follows:
COUNT ONE - VIOLATION OF N.J.S.A. 19:49-2
1.

The Plaintiff, Alexander J. Law (Alex Law), intends to

enter his name in the Democratic Primary for the House of
Representatives representing the First Congressional
District of New Jersey.

2.

In preparing to submit his official declaration to run, Mr.

Law attempted to determine how ballot position is decided,
as ballot position plays an integral role in elections.

3.

According to N.J.S.A. 19:49-2, ...in those counties where

voting machines are used, the county clerk shall have the
authority to determine the specifications for, and the final
arrangement of, the official ballots.

4.

Consistent with the statute, Mr. Law met with

representatives from the County Clerks office in order to
better understand how the County Clerk arranges the ballot.

5.

The Clerks office refused to explain what procedure and

arrangement would be used to determine ballot placement,
referring Mr. Law to the language of the statute.

6.

Mr. Law, through counsel, sent a letter to Defendant Ripa on

February 3, 2016, again requesting specific information
regarding the procedure to be utilized by the Clerks office
to determine the specifications for and final arrangement of
the official ballots, consistent with the statute.

7.

Specifically, the letter requested information (1) regarding

the differences between bracketed and non-bracketed
candidates; (2) where Presidential candidates would be
placed on the ballot and how they would be bracketed; and
(3) the number of candidates that would sufficiently qualify
for a bracketed drawing if there was a separate drawing for
bracketed and non-bracketed candidates.

8.

In response to this letter, the Clerks office declined to

provide any procedures, merely reiterating that the Clerk
follows the statute.

9.

A follow up telephone call and letter again failed to

resolve the issue, as the Clerks office refused to provide
the requested necessary information.

10.

It is the Clerks position that it cannot decide upon a

ballot placement procedure until the Clerk receives the
ballot applications.

11.

The Clerks position is without merit.

The candidates need

to know the procedure before filing applications so that the

Clerk cannot create a procedure that favors certain
candidates and punishes other candidates.
12.

Because the statute indicates that the procedures are to be

set by the Clerks office, and the Clerks office indicates
that their procedures are consistent with the statute, Mr.
Law has no ability to determine what policies and procedures
will be followed, and therefore will be irreparably harmed.

13.

It is necessary for Mr. Law to understand the procedures

that will be used in determining placement, because Mr. Law
and other candidates can affect their placement on the
ballot by bracketing with county freeholder candidates.
Without knowing whether bracketed candidates will be treated
preferentially, it is impossible for Mr. Law and other
potential candidates to properly plan in a manner to gain
the best possible placement on the ballot.

14.

There is no fair or just reason why the Clerks office is

refusing to provide the requested information.

The

Plaintiff is greatly concerned that the Clerk is refusing to

set a ballot placement procedure so that the Clerk can
create a post hoc procedure to favor certain candidates and
punish others.
15.

In refusing to set a fair procedure for ballot placement,

the Defendants have violated N.J.S.A. 19:49-2.
COUNT TWO - VIOLATION OF THE NEW JERSEY CIVIL RIGHTS ACT,
N.J.S.A. 10:6-2

16.

Plaintiff repeats each and every allegation and paragraph in

the previous Count as if fully stated herein.

17.

By denying the Plaintiff a fair an even playing field by

refusing to provide rules for ballot placement, the
Defendants are denying the Plaintiff of Equal Protection of
the laws of New Jersey as required by the New Jersey
Constitution, Article 1, Paragraph 1.

18.

By forcing the Plaintiff to decide in advance whether he

will bracket with other candidates without knowing whether
such bracketing would be an advantage or disadvantage to
ballot placement, the Clerk has denied the Plaintiff
substantive due process and therefore has violated the New
Jersey Civil Rights Act, N.J.S.A. 10:6-2, et seq.
WHEREFORE, Plaintiff demands judgment:
(A) Ordering Defendants to provide their specification and
arrangement policies and procedures regarding candidate

placement on ballots by April 1, 2016;

(B) Directing Defendants to provide full and complete
answers to all questions posed in the February 3, 2016
letter by April 1, 2016;
(C) Directing Defendants to continue to make Plaintiff aware
of any changes to their specification and arrangement
policies and procedures regarding candidate placement on
ballots;
(D) Directing Defendants not to change their specification
and arrangement policies and procedures regarding candidate
placement on ballots once expounded;
(E) Directing the Defendants to pay Plaintiffs counsel fees
and costs pursuant to the New Jersey Civil Rights Act; and
(F) For such further relief as the Court may deem equitable
and just.
Schorr & Associates, P.C.
Attorneys for the Plaintiff

By:
Dated: March 14, 2016

Adam L. Schorr, Esquire

CERTIFICATION OF NO OTHER ACTIONS

Pursuant to Rule 4:5-1, it is stated that the matter in
controversy is not the subject of any other action pending in any
other court or of a pending arbitration proceeding to the best of
our knowledge or belief. Also, to the best of our belief, no
other action or arbitration proceeding is contemplated. Further,
other than the parties set forth in this pleading, we know of no
other parties that should be joined in the above action. In
addition, we recognize the continuing obligation of each party to
file and serve on all parties and the Court an amended

certification if there is a change in the facts stated in this

original certification.
NOTICE REGARDING NON-DESTRUCTION OF EVIDENCE
Please be advised and noticed that the Defendant(s) should
refrain from destroying, deleting, disposing, or altering any
potential evidence in its possession which could relate in any
way to this matter.
Please be advised and noticed that this includes any and all
hard-copy and electronic evidence. Electronic evidence includes,
but is not limited to the hard drives on any and all computers,
mobile devices, and/or servers. To that end:
A.

B.

C.

The Defendant(s) should not initiate any procedures which

would alter, modify, delete, or overwrite any active,
deleted, or fragmented files. Such procedures may include,
but are not limited to: saving new files to existing drives;
installing new software or operating systems; running data
compression and disk defragmentation (optimization)
routines; and/or the use of any program which permanently
deletes, overwrites, or modifies files or drives.
The Defendant(s) should remove from rotation and/or use any
software or electronic hardware, including backup drives and
servers, that may contain any relevant electronic
information.
The Defendant(s) should retain all electronic hardware that
would otherwise be destroyed or removed from the possession
of Defendant(s) due to failure, upgrade, and/or lease
expiration if such hardware may contain any relevant
electronic data.
Schorr & Associates, P.C.
Attorney for the Plaintiff

By:
Dated: March 14, 2016

Adam L. Schorr, Esquire