Preview
IN THE COURT OF COMMON PLEAs OF DELAWARE COUNTY PENNSYLVANIA
COVER SHEET NOTICE OF FILING OF MOTION OR PETITION UNDER
LOCAL RULES OF CIVIL PROCEDURE /
CASE CAPTION h) TE Mam Md}! W WMWIL CASE NO av 20 Z t 073035
MF‘LCO LM T VATS a5 6L DamoMn-hp [M [W
gr WWW
NATURE OF MATTER Fl
vaf D
Kama
(please Che ne) Cmmm I
.Petition Pursuant to Rule 206 l DResponse to Petition DMotion for Judgment on the
Pleadings Pursuant to Rule 1034(a)
DMotion Pursuant to Rule 208 1 DResponse to Motion DSummary Judgment
Pursuant to Rule 1035 2
|:|Family Law Petition/Motion Pursuant to Rule 206 8
FILING PARTY IS RESPONSIBLE FOR SERVICE OF THE RULE RETURNABLE
DATE OR HEARING DATE UPON ALL PARTIES
A motion or petition was filed in the above captioned matter on the day of , which
DRequires you, Respondent, to file an Answei within twenty (20) days of the above date to this notice, or risk
the entry of an Order in favor of the Petitioner Answers must be filed and time stamped by the Office of
Judicial Support by 4 30 PM on the following date
DRequires all parties, to appear at a hearing/conference on the day of , ,
at in Courtroom , Delaware County Courthouse, Media, Pennsylvania At this hearing/conference
you must be prepared to present all testimony and/or argument, and must ensure that your witnesses will be
present
DWas timely answered, thus requiring the scheduling of the following hearing in the above captioned matter
on , at 10 00 AM in Courtroom
At this hearing, all parties must be prepared to present all testimony and/or argument and must ensure that
their witnesses will be present
DQualifies as an Uncontested Motion or Petition, and as such requires neither an answer from the Respondent
nor the scheduling of a hearing in this matter
DHas been assigned to Judge
FOR OFFICE USE ONLY
Mailing date Processed by
IN THE COURT OF COMMON PLEAS OF DELAWARE COUNTY PENNSYLVANIA
In re Nomination Petition of
MALCOLM J YATES as a
Democratic candidate for
Marcus Hook Borough Council No CV 2021
Objection of Mary LaVallee
O RDE R
AND NOW, this day of 2021, upon consideration
of the Petition of Mary LaVallee to Set Aside the Nomination Petition filed by Malcolm
J Yates as a Democratlc candidate for Marcus Hook Borough Council, and any response
thereto it 1s hereby ORDERED and DECREED that said Petitlon is GRANTED and
Respondent shall not appear as a candidate for Marcus Hook Borough Council on the
Democratic ballot for the Municipal Primary Election on May 18, 2021
BY THE COURT
J
John P McBlain, Esquire L IL L T
Attorney I D No 65287
Swartz Campbell LLC Luz} WAR I6 PH 1 05
115 North Jackson Street
Media, PA 19063 Attorney for Petitigner/ijector
g610)5.66 9222 13mm AL ED UPE.‘.
UCLAW,‘
Jmcblam@swartzcampbell com
In the Court of Common Pleas of
In re Nomination Petition of Delaware County, Pennsylvania
MALCOLM J YATES as a
Democratic candidate for
Marcus Hook Borough Council No CV 2021 (3 O 2 (0 g(
Objection of Mary LaVallee
PETITION TO SET ASIDE NOMINATION PETITION OF
MALCOLM J YATES AS A DEMOCRATIC CANDIDATE FOR
MARCUS HOOK BOROUGH COUNCIL
Petitioner, Mary LaVallee, through her undersigned counsel, hereby objects pursuant to
the provisions of 25 P S §2937 to the nomination petition filed by Respondent, Malcolm J
Yates, in Respondent s attempt to appear on the ballot for the May 18, 2021 Municipal Primary
election as a Democratic candidate for Marcus Hook Borough Council, and states as follows
COUNT ONE FAILURE TO TIMELY FILE
STATEMENT OF FINANCIAL INTERESTS
1 Respondent is purported to be a resident of Marcus Hook Borough, residing at
1048 Yates Avenue, Marcus Hook, PA 19061
2 Pet1tioner, Mary LaVallee IS a resident of Marcus Hook Borough, residing at 21
West 2nd Street, Marcus Hook, PA 19061 Petitioner is a registered and enrolled elector 1n
Marcus Hook Borough and a reglstered and enrolled member of the Democratic Party
3 On or before March 9, 2021, Respondent filed a nomination petitlon seeking to
appear as a Democratic candidate for Marcus Hook Borough Council on the ballot for the May
18, 2021 Municipal Primary election A true and correct copy of Respondent’s nominatlon
petition is attached hereto as Exh1bit“A”
4 Respondent failed to file a Pennsylvania Ethics Commission Statement of
Flnan01al Interests with the governing authority of the Borough of Marcus Hook prior to March
9, 2021, the last day for fillng a nomination petition to appear on the May 18, 2021 Municipal
Primary ballot
5 Pursuant to the Pennsylvania Public Official and Employee Ethics Act (the
Ethics Act ) at 65 Pa C S §1104(b)(2) a cand1date for local office must file a Statement of
Financial Interests for the preceding calendar year with the governing authority of the political
subd1v1si0n of his candidacy before the last day for filing a petltion to appear on the ballot
6 The Ethics Act at 65 PaC S §1104(b)(3) provides that Failure to file the
statement [of financial interests] in accordance with the provisions of this chapter shall, in
addition to any other penalties provided, be a fatal defect to a petition to appear on the ballot”
7 Although respondent appended a copy of the Statement of Financial Interests to
the nomination petition filed With the Delaware County Board of Elections, such filing does not
satisfy the requirements of the Ethlcs Act
The Ethics Act clearly requlres a candidate for local office to file a statement of
financial interests for the preceding calendar year with the governing authority of the
political subdivision in which [s]he is a candidate on or before the last day for filing a
petitlon to appear on the ballot for election This is the first filing required by the
statute Attachmg to a candidate’s nomination petition is the WM required
by Section 1104(b)(2) [of the Ethics Act] As such this Court is constrained to follow
the clear directive of the Ethics Act
In re Bah, 215 A 3d at 1033 (Pa melth 2019), cztzng In re Nomination Petitlon of Pros erino,
972 A 2d 92 at 96 (Pa melth 2009) (emphasis in original)
8 A court must strike a candidate’s name from the ballot when statutorily compelled
to do so In re Bah 215 A 3d 1029 1032 (Pa melth 2019)
9 Respondent’s fa11ure to file a Statement of Financial Interests with the Borough of
Marcus Hook on or before March 9, 2021 is a fatal defect to his nomination petition pursuant to
the statutory terms of the Ethics Act, and Pennsylvania’s cases and decisions thereunder, and
therefore the Respondent IS not eligible to appear on the ballot for the May 18,2021 Municipal
Primary election as a Democratic candidate for Marcus Hook Borough Council
WHEREFORE, Petitioner respectfully requests that this Honorable Court strike
Respondent’s name from the Democratic ballot for the May 18, 2021 Mumcipal Primary
election
Respectfully submitted
D 3111213094 WP Wu,
John P McBlam, Esquire
Attorney for Petitioner/ObJ ector,
Mary LaVellee
EXhlbit “A”
Signatures must be procured withm the legal period for scumbag same and this Penman must be filed in the office of the
County Boat d of Electons on on befon e the last day prescribed by law
EACH SIGNER MAY SIGN PETITIONS FOR AS MANY CANDIDATES FOR EACH OFFICE AS HE OR SHE CAN VOTE FOR, AND NO MORE
CGE/EMONWEALTH (PF PENNSYLVANIA
BEWARE
WY mOr {-1an I mas
?ETITION 393%” allot
Te have name mt Candmdate Pmnted upon the Officn’
for the mncnpall Primary 2921 MAR Ll [2) L1. 0b
We, the undersigned, Whom are qualified el tors of CL LA) 61. County and
/ Q (L Q0 3 I id) k and are registered and
(merom 13mm [N CH m5 nonmamou iaECI‘ION IS TO BE mama)
enrolled members of the ‘ 7L Party or Policy, hereby
petition the County Board of Elections of I I (.0 County
/
to have the name of t G— 0 V 3 a 6
(TYPEWRI'I‘E mum OR PLAINLYTHEABO NMEASYéU H ITTOAPPEAR ONTHE OFFICIAL BALLOT)
whose Profession, Business or Occupahon is 0V K; + ‘('I (3 Place of
Residence is 04 8 OGLES AVQ a L) / 40
(mm mm NUMBER (WHERE POSSIBLE) AND ZIP CODE)
a/
printed upon the Official Ballot of the aforesaid Party in the send District, for the Munimpal Primary for the year 20
as a candidate forthe Office of ,1)OYLDLQ g LII €00 M Q! I L7! ?QQICJ
mm OFFICE) cram 01:0 ICE)
. _"_____ _GN'ERSSI CAUTMED AVOID THE USE 0 DITTO MARKS
DATE op
MW , , Cam. c ”Cub “'MWWQ
mm LoA £6; ’0 L £35 mm Gus me
”mmmmmslal
WWW
mmmmlM—M
WW W \ I was we
EWMEWWMWW‘ "
ammsz mum
W bouficL G'CJQ N mamma- Mm: . (3K
lm?— I1! EC AW Harmy alt
WHWWM Me 2 1
_fl-——-
—__——-
_——_—_
——___—
_—-_—_
_—_-__
—__—_-
DELCO BOE 2021 01 15 Page I of A
STATEMENTF cmcm.mR
COMNIO TH PENNSYLVANIA } SS
COUNTY OF e0 0 “R
I state that I am a qualified elector of the Commonwealth; that I am duly registeted and enrolled WM in this Nomination Petition;
that my residence IS as set forth below, that the signers to the foregoing Nomination Petition signed the same with full knowledge of the contents thereof, that thelr respective
residences are correctly stated therein, that each signed on the date set opposite his or her name, and that to the best of my knowledge and belief, the signers are qualified electors, duly
registered and enrolled members of the political party and of the political district designated in this pet1t10n, and that they are residents of the county specified below (Underlined
portion not applicable to a circulator for the office of Magisterial District Judge )
Further, I state that the information set forth herein is true and correct to the best of my knowledge, information, and belief, and that this statement is made subject to the
penalties of 18 Pa C 5
§ 4904 (relating to unswom falsification to authorities)
NOTE The Statement ofC'Ln-ulatm must he exeguted after alifignaturm have}:
en obtained
f i 2 gig warm
(COUNTY TITION SIGNERS RESIDENCE)
Mam4: m(PRINTED
3 [0% r'
AME OF CIRCULATOR)
M GO 42$ /
SIG A 0F CIRCULATOR) STREET ADDRESS I (POST OFFICE)
in
l
I (”W (3M4 £30m!
(CITY BOROUGH OR TOWNSHIP)
2mm AFmeWT
COMlVlO TH OF PENNSYLVANIA } SS
COUNTY OF a 004%-
Before me, the undexsigned 1n and for said State and County, personally appeared the undersigned, who being duly sworn according to law, did depose and say that his or her
residence is as set forth below, that his or hefiwtion district is as set forth below; that the name of the ofiice for which he or she consents to be a candidate is
M (TITLE OF OHICE) (TERM OF OFFICE)
that he or she is eligible for said office, that he or she will not knowingly violate any election law, or any law regulating and limiting nomination and election expenses, and prohibiting
corrupt practices in connection therewith, that he or she is aware ofthe provisxons of Section 1626 ofThe Pennsylvania Election Codie requiring pre-electaon and post
election reporting ofcampaign contnbutzons and expenditures, and that he or she is not a candidate for an office which he or she already holds, the term of which is not set to
expire in the same year as the office subject to the affidavit
M(Undeflined portion is not applicable to Candidates for the offices of School Director or Magisterial District Judge )
Any candidate for local office shall file a statement of fixmncinl interests for the preceding calendar year With the governing authority of the political
subdivision in which he or she is a candidate on or before the East day for filing a petition to appear on the ballot for election
A COPY OF THE STATEMENT OF FINANICAL INTERESTS SHALLALSO BE APP ED TO THIS PETITION
Sworn to and subscribed before me
this I day of
I
[I ‘ l / 20 g I 5/ gem RE OF CANDIDATE)
Q / /14 P 5 1’ Fm3°
I I my?" fies Ate
(SIGNA r OF N} AR; 9 - NAME OF CANDIDATE)
(OFFICIALTITLE) ‘ (STREETADDfiss); (1’0er OFFICE)
{ 2: 2%; 3L.
ri \g3 [(1315 Lfll‘OQ La
My Commission expires Ew— (CITY BOROUGH OR TO sat?)
mnsy vania
f “MEI! t I a Notary Seal (1,;
W. tavern... mo Notary Public AW ( 0
0;. la
3, Co qty (CANDIDATE CONFACI‘ PHONE/EMAIL)
; M ”W” G Xvi es A40 30, 2023 Election District ofCandidate 72
Wm“ . ‘ ..t n i momma mm
1W
WM OF MEN ACCCOUNT REP©RT31NG AFFIDAVIT
COMMONWEALTH OF PENNSYLVANIA ii SS
COUNTY OF
Before me, the undersigned authority in and for said State and County, personally appeared the undersigned, who, being duly sworn according t9 law, did dispose and say
that as a candidate, he or she does not intend to form a political committee or to receive contributions or make expenditures in excess of Two Hundred and Fifty Dollars ($250) (1“!ng
any reporting period, that, as a candidate, he or she will keep records of contributions and expenditures as required by law, as a candidate, he or she will file reports as required by law if
contributions or expenditures exceed Two Hundred and Fifty Dollars ($250)
(Act No1980 127)
Sworn to and subscribed before me I ///f /
this 8 dayof Edi 20 (51/ / ID TE)
SI NATURE OF
9“‘ A f,4? J I
(SIGN 01f OT Y) ‘ P NAMED CANDIDATE)
(OFFICIAL TITLE) (S ADDREfS) $0M OFFICE)
emit» ’ 0° K} bto e
My Commission expires M (CITY BOROUGH OR TO SHIP)
fegggaigeweano ems}: var“;o ary ea
FAQ "H KRYST‘NA KINC
Notary Public
‘ Oelawa CO 1t),- (CANDIDATE CONTACT PHONE/EMAIL)
MY Cam “Mic“ Expires Mg 30’ 2023 Election District of Candidate
PR6 N4 3
’ 1W“ NUW53 ,th m“0“...“
Each person filing any nommation petition shall pay, for each petition at the time of filing, a filing fee, and no nomination petition shall be accepted or filed, unless and until such filing fee 13 paid by a
certified check or money order or also by cash when filed with the countyboard. Whenever a petition is to be filed with the countyboard the person filing the same shall pay the filing fee in cash or by certified check or
money order to the county board. All moneys paid on account of filing fees shall be transmitted by the countyboard to the County Treasurer and shall become part of the General Fund Certified checks or money orders
in payment of filing fees shall be made payable to the county and shall be transmitted to the County Treasurer, and shall become part of the General Fund.
DELCO EOE 2021 01 15 Page L of 7/
VERIFICATION
I, Mary LaVallee, verify that the facts set forth in the foregoing Petition to Set
Aside Nommation Petition are true and correct to the best of my knowledge, information
and belief
Dateéz/shwz 4g!(iié(/4
Ma
W
LaVGe
a 0) 0 [a L1g
John P McBlain, Esquire
Attorney I D No 65287
Swartz Campbell LLC
115 North Jackson Street
Media, PA 19063 Attorney for Petitioner/Objector
(610) 566 9222
jmcblain@swartzcampbell com
In the Court of Common Pleas of
In re Nomination Petition of Delaware County, Pennsylvania
MALCOLM J YATES as a
Democratic candidate for
Marcus Hook Borough Council No CV 2021
Objection of Mary LaVallee
CERTIFICATE OF SERVICE
I, John P McBlain, Esquire hereby certify that on the léfl 9‘1 day of March
2021, the foregoing Petition to Set Aside Nominatlon Petition was served on the
following V1a hand delivery
Andrew Weldon, Bureau of Elections
Borough Secretary / Manager Delaware County Courthouse
Marcus Hook Borough Front Street
Delaware County, Pennsylvania Media, PA 19063
John P McBIam, Esquire
Preview
IN THE COURT OF COMMON PLEAs OF DELAWARE COUNTY PENNSYLVANIA COVER SHEET NOTICE OF FILING OF MOTION OR PETITION UNDER LOCAL RULES OF CIVIL PROCEDURE / CASE CAPTION h) TE Mam Md}! W WMWIL CASE NO av 20 Z t 073035 MF‘LCO LM T VATS a5 6L DamoMn-hp [M [W gr WWW NATURE OF MATTER Fl vaf D Kama (please Che ne) Cmmm I .Petition Pursuant to Rule 206 l DResponse to Petition DMotion for Judgment on the Pleadings Pursuant to Rule 1034(a) DMotion Pursuant to Rule 208 1 DResponse to Motion DSummary Judgment Pursuant to Rule 1035 2 |:|Family Law Petition/Motion Pursuant to Rule 206 8 FILING PARTY IS RESPONSIBLE FOR SERVICE OF THE RULE RETURNABLE DATE OR HEARING DATE UPON ALL PARTIES A motion or petition was filed in the above captioned matter on the day of , which DRequires you, Respondent, to file an Answei within twenty (20) days of the above date to this notice, or risk the entry of an Order in favor of the Petitioner Answers must be filed and time stamped by the Office of Judicial Support by 4 30 PM on the following date DRequires all parties, to appear at a hearing/conference on the day of , , at in Courtroom , Delaware County Courthouse, Media, Pennsylvania At this hearing/conference you must be prepared to present all testimony and/or argument, and must ensure that your witnesses will be present DWas timely answered, thus requiring the scheduling of the following hearing in the above captioned matter on , at 10 00 AM in Courtroom At this hearing, all parties must be prepared to present all testimony and/or argument and must ensure that their witnesses will be present DQualifies as an Uncontested Motion or Petition, and as such requires neither an answer from the Respondent nor the scheduling of a hearing in this matter DHas been assigned to Judge FOR OFFICE USE ONLY Mailing date Processed by IN THE COURT OF COMMON PLEAS OF DELAWARE COUNTY PENNSYLVANIA In re Nomination Petition of MALCOLM J YATES as a Democratic candidate for Marcus Hook Borough Council No CV 2021 Objection of Mary LaVallee O RDE R AND NOW, this day of 2021, upon consideration of the Petition of Mary LaVallee to Set Aside the Nomination Petition filed by Malcolm J Yates as a Democratlc candidate for Marcus Hook Borough Council, and any response thereto it 1s hereby ORDERED and DECREED that said Petitlon is GRANTED and Respondent shall not appear as a candidate for Marcus Hook Borough Council on the Democratic ballot for the Municipal Primary Election on May 18, 2021 BY THE COURT J John P McBlain, Esquire L IL L T Attorney I D No 65287 Swartz Campbell LLC Luz} WAR I6 PH 1 05 115 North Jackson Street Media, PA 19063 Attorney for Petitigner/ijector g610)5.66 9222 13mm AL ED UPE.‘. UCLAW,‘ Jmcblam@swartzcampbell com In the Court of Common Pleas of In re Nomination Petition of Delaware County, Pennsylvania MALCOLM J YATES as a Democratic candidate for Marcus Hook Borough Council No CV 2021 (3 O 2 (0 g( Objection of Mary LaVallee PETITION TO SET ASIDE NOMINATION PETITION OF MALCOLM J YATES AS A DEMOCRATIC CANDIDATE FOR MARCUS HOOK BOROUGH COUNCIL Petitioner, Mary LaVallee, through her undersigned counsel, hereby objects pursuant to the provisions of 25 P S §2937 to the nomination petition filed by Respondent, Malcolm J Yates, in Respondent s attempt to appear on the ballot for the May 18, 2021 Municipal Primary election as a Democratic candidate for Marcus Hook Borough Council, and states as follows COUNT ONE FAILURE TO TIMELY FILE STATEMENT OF FINANCIAL INTERESTS 1 Respondent is purported to be a resident of Marcus Hook Borough, residing at 1048 Yates Avenue, Marcus Hook, PA 19061 2 Pet1tioner, Mary LaVallee IS a resident of Marcus Hook Borough, residing at 21 West 2nd Street, Marcus Hook, PA 19061 Petitioner is a registered and enrolled elector 1n Marcus Hook Borough and a reglstered and enrolled member of the Democratic Party 3 On or before March 9, 2021, Respondent filed a nomination petitlon seeking to appear as a Democratic candidate for Marcus Hook Borough Council on the ballot for the May 18, 2021 Municipal Primary election A true and correct copy of Respondent’s nominatlon petition is attached hereto as Exh1bit“A” 4 Respondent failed to file a Pennsylvania Ethics Commission Statement of Flnan01al Interests with the governing authority of the Borough of Marcus Hook prior to March 9, 2021, the last day for fillng a nomination petition to appear on the May 18, 2021 Municipal Primary ballot 5 Pursuant to the Pennsylvania Public Official and Employee Ethics Act (the Ethics Act ) at 65 Pa C S §1104(b)(2) a cand1date for local office must file a Statement of Financial Interests for the preceding calendar year with the governing authority of the political subd1v1si0n of his candidacy before the last day for filing a petltion to appear on the ballot 6 The Ethics Act at 65 PaC S §1104(b)(3) provides that Failure to file the statement [of financial interests] in accordance with the provisions of this chapter shall, in addition to any other penalties provided, be a fatal defect to a petition to appear on the ballot” 7 Although respondent appended a copy of the Statement of Financial Interests to the nomination petition filed With the Delaware County Board of Elections, such filing does not satisfy the requirements of the Ethlcs Act The Ethics Act clearly requlres a candidate for local office to file a statement of financial interests for the preceding calendar year with the governing authority of the political subdivision in which [s]he is a candidate on or before the last day for filing a petitlon to appear on the ballot for election This is the first filing required by the statute Attachmg to a candidate’s nomination petition is the WM required by Section 1104(b)(2) [of the Ethics Act] As such this Court is constrained to follow the clear directive of the Ethics Act In re Bah, 215 A 3d at 1033 (Pa melth 2019), cztzng In re Nomination Petitlon of Pros erino, 972 A 2d 92 at 96 (Pa melth 2009) (emphasis in original) 8 A court must strike a candidate’s name from the ballot when statutorily compelled to do so In re Bah 215 A 3d 1029 1032 (Pa melth 2019) 9 Respondent’s fa11ure to file a Statement of Financial Interests with the Borough of Marcus Hook on or before March 9, 2021 is a fatal defect to his nomination petition pursuant to the statutory terms of the Ethics Act, and Pennsylvania’s cases and decisions thereunder, and therefore the Respondent IS not eligible to appear on the ballot for the May 18,2021 Municipal Primary election as a Democratic candidate for Marcus Hook Borough Council WHEREFORE, Petitioner respectfully requests that this Honorable Court strike Respondent’s name from the Democratic ballot for the May 18, 2021 Mumcipal Primary election Respectfully submitted D 3111213094 WP Wu, John P McBlam, Esquire Attorney for Petitioner/ObJ ector, Mary LaVellee EXhlbit “A” Signatures must be procured withm the legal period for scumbag same and this Penman must be filed in the office of the County Boat d of Electons on on befon e the last day prescribed by law EACH SIGNER MAY SIGN PETITIONS FOR AS MANY CANDIDATES FOR EACH OFFICE AS HE OR SHE CAN VOTE FOR, AND NO MORE CGE/EMONWEALTH (PF PENNSYLVANIA BEWARE WY mOr {-1an I mas ?ETITION 393%” allot Te have name mt Candmdate Pmnted upon the Officn’ for the mncnpall Primary 2921 MAR Ll [2) L1. 0b We, the undersigned, Whom are qualified el tors of CL LA) 61. County and / Q (L Q0 3 I id) k and are registered and (merom 13mm [N CH m5 nonmamou iaECI‘ION IS TO BE mama) enrolled members of the ‘ 7L Party or Policy, hereby petition the County Board of Elections of I I (.0 County / to have the name of t G— 0 V 3 a 6 (TYPEWRI'I‘E mum OR PLAINLYTHEABO NMEASYéU H ITTOAPPEAR ONTHE OFFICIAL BALLOT) whose Profession, Business or Occupahon is 0V K; + ‘('I (3 Place of Residence is 04 8 OGLES AVQ a L) / 40 (mm mm NUMBER (WHERE POSSIBLE) AND ZIP CODE) a/ printed upon the Official Ballot of the aforesaid Party in the send District, for the Munimpal Primary for the year 20 as a candidate forthe Office of ,1)OYLDLQ g LII €00 M Q! I L7! ?QQICJ mm OFFICE) cram 01:0 ICE) . _"_____ _GN'ERSSI CAUTMED AVOID THE USE 0 DITTO MARKS DATE op MW , , Cam. c ”Cub “'MWWQ mm LoA £6; ’0 L £35 mm Gus me ”mmmmmslal WWW mmmmlM—M WW W \ I was we EWMEWWMWW‘ " ammsz mum W bouficL G'CJQ N mamma- Mm: . (3K lm?— I1! EC AW Harmy alt WHWWM Me 2 1 _fl-——- —__——- _——_—_ ——___— _—-_—_ _—_-__ —__—_- DELCO BOE 2021 01 15 Page I of A STATEMENTF cmcm.mR COMNIO TH PENNSYLVANIA } SS COUNTY OF e0 0 “R I state that I am a qualified elector of the Commonwealth; that I am duly registeted and enrolled WM in this Nomination Petition; that my residence IS as set forth below, that the signers to the foregoing Nomination Petition signed the same with full knowledge of the contents thereof, that thelr respective residences are correctly stated therein, that each signed on the date set opposite his or her name, and that to the best of my knowledge and belief, the signers are qualified electors, duly registered and enrolled members of the political party and of the political district designated in this pet1t10n, and that they are residents of the county specified below (Underlined portion not applicable to a circulator for the office of Magisterial District Judge ) Further, I state that the information set forth herein is true and correct to the best of my knowledge, information, and belief, and that this statement is made subject to the penalties of 18 Pa C 5 § 4904 (relating to unswom falsification to authorities) NOTE The Statement ofC'Ln-ulatm must he exeguted after alifignaturm have}: en obtained f i 2 gig warm (COUNTY TITION SIGNERS RESIDENCE) Mam4: m(PRINTED 3 [0% r' AME OF CIRCULATOR) M GO 42$ / SIG A 0F CIRCULATOR) STREET ADDRESS I (POST OFFICE) in l I (”W (3M4 £30m! (CITY BOROUGH OR TOWNSHIP) 2mm AFmeWT COMlVlO TH OF PENNSYLVANIA } SS COUNTY OF a 004%- Before me, the undexsigned 1n and for said State and County, personally appeared the undersigned, who being duly sworn according to law, did depose and say that his or her residence is as set forth below, that his or hefiwtion district is as set forth below; that the name of the ofiice for which he or she consents to be a candidate is M (TITLE OF OHICE) (TERM OF OFFICE) that he or she is eligible for said office, that he or she will not knowingly violate any election law, or any law regulating and limiting nomination and election expenses, and prohibiting corrupt practices in connection therewith, that he or she is aware ofthe provisxons of Section 1626 ofThe Pennsylvania Election Codie requiring pre-electaon and post election reporting ofcampaign contnbutzons and expenditures, and that he or she is not a candidate for an office which he or she already holds, the term of which is not set to expire in the same year as the office subject to the affidavit M(Undeflined portion is not applicable to Candidates for the offices of School Director or Magisterial District Judge ) Any candidate for local office shall file a statement of fixmncinl interests for the preceding calendar year With the governing authority of the political subdivision in which he or she is a candidate on or before the East day for filing a petition to appear on the ballot for election A COPY OF THE STATEMENT OF FINANICAL INTERESTS SHALLALSO BE APP ED TO THIS PETITION Sworn to and subscribed before me this I day of I [I ‘ l / 20 g I 5/ gem RE OF CANDIDATE) Q / /14 P 5 1’ Fm3° I I my?" fies Ate (SIGNA r OF N} AR; 9 - NAME OF CANDIDATE) (OFFICIALTITLE) ‘ (STREETADDfiss); (1’0er OFFICE) { 2: 2%; 3L. ri \g3 [(1315 Lfll‘OQ La My Commission expires Ew— (CITY BOROUGH OR TO sat?) mnsy vania f “MEI! t I a Notary Seal (1,; W. tavern... mo Notary Public AW ( 0 0;. la 3, Co qty (CANDIDATE CONFACI‘ PHONE/EMAIL) ; M ”W” G Xvi es A40 30, 2023 Election District ofCandidate 72 Wm“ . ‘ ..t n i momma mm 1W WM OF MEN ACCCOUNT REP©RT31NG AFFIDAVIT COMMONWEALTH OF PENNSYLVANIA ii SS COUNTY OF Before me, the undersigned authority in and for said State and County, personally appeared the undersigned, who, being duly sworn according t9 law, did dispose and say that as a candidate, he or she does not intend to form a political committee or to receive contributions or make expenditures in excess of Two Hundred and Fifty Dollars ($250) (1“!ng any reporting period, that, as a candidate, he or she will keep records of contributions and expenditures as required by law, as a candidate, he or she will file reports as required by law if contributions or expenditures exceed Two Hundred and Fifty Dollars ($250) (Act No1980 127) Sworn to and subscribed before me I ///f / this 8 dayof Edi 20 (51/ / ID TE) SI NATURE OF 9“‘ A f,4? J I (SIGN 01f OT Y) ‘ P NAMED CANDIDATE) (OFFICIAL TITLE) (S ADDREfS) $0M OFFICE) emit» ’ 0° K} bto e My Commission expires M (CITY BOROUGH OR TO SHIP) fegggaigeweano ems}: var“;o ary ea FAQ "H KRYST‘NA KINC Notary Public ‘ Oelawa CO 1t),- (CANDIDATE CONTACT PHONE/EMAIL) MY Cam “Mic“ Expires Mg 30’ 2023 Election District of Candidate PR6 N4 3 ’ 1W“ NUW53 ,th m“0“...“ Each person filing any nommation petition shall pay, for each petition at the time of filing, a filing fee, and no nomination petition shall be accepted or filed, unless and until such filing fee 13 paid by a certified check or money order or also by cash when filed with the countyboard. Whenever a petition is to be filed with the countyboard the person filing the same shall pay the filing fee in cash or by certified check or money order to the county board. All moneys paid on account of filing fees shall be transmitted by the countyboard to the County Treasurer and shall become part of the General Fund Certified checks or money orders in payment of filing fees shall be made payable to the county and shall be transmitted to the County Treasurer, and shall become part of the General Fund. DELCO EOE 2021 01 15 Page L of 7/ VERIFICATION I, Mary LaVallee, verify that the facts set forth in the foregoing Petition to Set Aside Nommation Petition are true and correct to the best of my knowledge, information and belief Dateéz/shwz 4g!(iié(/4 Ma W LaVGe a 0) 0 [a L1g John P McBlain, Esquire Attorney I D No 65287 Swartz Campbell LLC 115 North Jackson Street Media, PA 19063 Attorney for Petitioner/Objector (610) 566 9222 jmcblain@swartzcampbell com In the Court of Common Pleas of In re Nomination Petition of Delaware County, Pennsylvania MALCOLM J YATES as a Democratic candidate for Marcus Hook Borough Council No CV 2021 Objection of Mary LaVallee CERTIFICATE OF SERVICE I, John P McBlain, Esquire hereby certify that on the léfl 9‘1 day of March 2021, the foregoing Petition to Set Aside Nominatlon Petition was served on the following V1a hand delivery Andrew Weldon, Bureau of Elections Borough Secretary / Manager Delaware County Courthouse Marcus Hook Borough Front Street Delaware County, Pennsylvania Media, PA 19063 John P McBIam, Esquire