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KENNETH J. DOW
P.O. BOX 25 ! 31 KINDERHOOK STREET ! CHATHAM, NY 12037
(518)817-7394 (C) ! KENDOWLAW@HOTMAIL.COM
July 24, 2014
The form and content of the petitions, and the Petitioners’ qualifications, were in every respect
sufficient and proper to put these citizens on the primary ballot as candidates to be Delegates to
the Judicial Convention. These citizens did everything they were supposed to do under the
Election Law in order to get on the ballot.
The Court of Appeals has said repeatedly that boards of election have no power to deal with
questions involving matters not appearing upon the face of the petition.
In improperly, inexcusably, and baselessly invalidating the designating petition, Matthew Clyne
and Rachel Bledi committed not only gross, stunning, and outrageous malfeasance in the
execution of their duties; they committed a serious violation of these 23 citizens’ civil and
The Board of Elections has tried, thorough a convoluted and bizarre argument, to make this a
question about Margaret Walsh. It is not a question about Margaret Walsh. The issue is
unlawfully disenfranchising citizens who are qualified to be Delegates to the 3
Convention exercising their right to gather petition signatures to be candidates and, if successful
at the primary, to participate as delegates at the Judicial Convention.
Matthew Clyne and Rachel Bledi barred twenty-three citizens of Albany County from exercising
their right to seek election to serve as delegates to the Judicial Convention and participate in the
selection of the Justices of the Supreme Court of this State, for no other reason than because of
the views, values, preferences and points of view that those citizens might hold and espouse.
That is not allowed to occur in the United States of America.
As to the claim that Margaret Walsh cannot be nominated as a Supreme Court Justice candidate,
subdivision five of section 6-146 of the Election Law specifically authorizes a person who has
already been nominated to one office to later be nominated for a different one—exactly the
situation that the Board of Elections wrongly says isn’t allowed.
These Albany County citizens have had their fundamental rights to participate in democracy
stolen by this shocking and brazen act of malfeasance by Respondents Matthew Clyne and
Rachel Bledi. We are asking that the Court make right what those Commissioners have so
outrageously made wrong.