Don Hurley Files Motion to Intervene in Levy Recall Case
Atlantic City, NJ-
"There are so many lies being told, there is so much deception being perpetrated by Rosemary Adams and others in AC Government to deprive the citizens of their fundamental constitutional rights", said Don Hurley, as he filed the motion to intervene in the Mayor Bob Levy Recall Case in NJ Superior Court today.
 
"In order to give our committee, and more importantly the citizens of Atlantic City, the justice they deserve, we have to intervene and join in this case",said Don Hurley, a spokesman for the Committee to Recall Bob Levy, and the applicant in the Motion to Intervene in the matter.


Don P. Hurley and/or the Committee to

Recall Bob Levy From the Office of

Mayor of Atlantic City, NJ

XX XXX X

Atlantic City, NJ 08404

Telephone No. (609) XXX-XXXX

Pro Se

__________________________         SUPERIOR COURT OF NEW JERSEY

In the Matter of

Charles B. Turner                                                LAW DIVISION

                                                                             ATLANTIC COUNTY

                                                                         DOCKET NO. ATL-L-932-07

      

                  Plaintiff                                     Motion to Intervene

 

                       Vs.                                            

Rosemary Adams, City Clerk

City of Atlantic City, John Doe 1-6

 

In accordance with Rule 4:33-1, Don P. Hurley and/or The Committee to Recall Bob Levy From the Office of Mayor of Atlantic City, seeks to intervene and join in the above captioned matter.

 

Don P. Hurley, and/or the members of The Committee to Recall Bob Levy From the Office of Mayor of Atlantic City are impacted by the outcome of this matter, and as such, have a stake and standing to intervene in this matter.

 

Don P. Hurley asserts further standing in this matter, as an original member of The Committee and the individual  who drafted several of the relevant documents in this matter, including but not limited to, the Letter of Intent and the Petition to Recall Bob Levy From the Office of Mayor of Atlantic City.

 

The delay of this matter by Defendants Rosemary Adams and others within the government of Atlantic City highlights the need to intervene and join in this above captioned matter to fully preserve the rights of the Plaintiff, the Committee and the applicant requesting to intervene.

 

Further, this intentionally caused delay by Defendants Clerk Rosemary Adams and the City of Atlantic City has required a Case Management Conference to be held before Atlantic County Superior Court Judge Valerie Armstrong on July 2, 2007. 

 

 

Wherefore, Applicant respectfully requests judgment in his favor in an ORDER:

 

    1. That Don P. Hurley, and/or The Committee to Recall Bob Levy From the Office of Mayor of Atlantic City be permitted to intervene and join in the matter of Charles B. Turner vs. City Clerk Rosemary Adams and the City of Atlantic City, NJ, on or before July 2, 2007, which is the date scheduled for a case management conference before Atlantic County Superior Court Judge Valerie Armstrong.

 

    1. In order that all statutory obligations and burdens may be met by the plaintiff, and Don P. Hurley and/or The Committee to Recall Bob Levy From the Office of Mayor of Atlantic City; the applicant shall be permitted to intervene, so that the Citizens Committee can be fully authorized to legally circulate an approved Petition in their pursuit to Recall Bob Levy From the Office of Mayor of Atlantic City in accordance with Title 19:27A and Title 40:69A-168, 40:69A-169, and 40:69A-170 of the Laws of the State of New Jersey.

 

    1. Any relief that may be deemed just and proper by the court to preserve the citizens committee rights of the plaintiff and the rights of all interested parties in this matter, who have a right to completely fulfill their obligations.

 

                                                                                 

                                                                                   Respectfully Submitted,

 

             

                                                                               __________________________

                                                                               Don P. Hurley, PRO SE

 

CERTIFICATION OF VERIFICATION

 

 

            I, Don P. Hurley, being of full age, hereby certify as follows;

 

  1. I am a citizen, and original member of The Committee, and either have first hand knowledge of the facts herein or upon information and belief.

 

  1. I have read the foregoing Motion and the facts contained therein are true to the best of my knowledge.

 

  1. I hereby certify that the foregoing statements made by me are true. I am aware that if any of the foregoing statements made by me are willfully false, I am subject to punishment.

 

 

                                                                                                   

                                                               _______________________________________

                                                                    Don P. Hurley

 

Dated:  June 27, 2007

 

 

Don P. Hurley and/or the Committee to

Recall Bob Levy From the Office of

Mayor of Atlantic City, NJ

XX XXX X

Atlantic City, NJ 08404

Telephone No. (609) XXX-XXXX

Pro Se

__________________________         SUPERIOR COURT OF NEW JERSEY

In the Matter of

Charles B. Turner                                                LAW DIVISION

                                                                             ATLANTIC COUNTY

                                                                         DOCKET NO. ATL-L-932-07

      

                  Plaintiff                                     Motion to Intervene

 

                       Vs.                                            

Rosemary Adams, City Clerk

City of Atlantic City, John Doe 1-6

 

In accordance with Rule 4:33-1, Don P. Hurley and/or The Committee to Recall Bob Levy From the Office of Mayor of Atlantic City, seeks to intervene and join in the above captioned matter.

 

Don P. Hurley, and/or the members of The Committee to Recall Bob Levy From the Office of Mayor of Atlantic City are impacted by the outcome of this matter, and as such, have a stake and standing to intervene in this matter.

 

Don P. Hurley asserts further standing in this matter, as an original member of The Committee and the individual  who drafted several of the relevant documents in this matter, including but not limited to, the Letter of Intent and the Petition to Recall Bob Levy From the Office of Mayor of Atlantic City.

 

The delay of this matter by Defendants Rosemary Adams and others within the government of Atlantic City highlights the need to intervene and join in this above captioned matter to fully preserve the rights of the Plaintiff, the Committee and the applicant requesting to intervene.

 

Further, this intentionally caused delay by Defendants Clerk Rosemary Adams and the City of Atlantic City has required a Case Management Conference to be held before Atlantic County Superior Court Judge Valerie Armstrong on July 2, 2007. 

 

 

Wherefore, Applicant respectfully requests judgment in his favor in an ORDER:

 

    1. That Don P. Hurley, and/or The Committee to Recall Bob Levy From the Office of Mayor of Atlantic City be permitted to intervene and join in the matter of Charles B. Turner vs. City Clerk Rosemary Adams and the City of Atlantic City, NJ, on or before July 2, 2007, which is the date scheduled for a case management conference before Atlantic County Superior Court Judge Valerie Armstrong.

 

    1. In order that all statutory obligations and burdens may be met by the plaintiff, and Don P. Hurley and/or The Committee to Recall Bob Levy From the Office of Mayor of Atlantic City; the applicant shall be permitted to intervene, so that the Citizens Committee can be fully authorized to legally circulate an approved Petition in their pursuit to Recall Bob Levy From the Office of Mayor of Atlantic City in accordance with Title 19:27A and Title 40:69A-168, 40:69A-169, and 40:69A-170 of the Laws of the State of New Jersey.

 

    1. Any relief that may be deemed just and proper by the court to preserve the citizens committee rights of the plaintiff and the rights of all interested parties in this matter, who have a right to completely fulfill their obligations.

 

                                                                                 

                                                                                   Respectfully Submitted,

 

             

                                                                               __________________________

                                                                               Don P. Hurley, PRO SE

 

CERTIFICATION OF VERIFICATION

 

 

            I, Don P. Hurley, being of full age, hereby certify as follows;

 

  1. I am a citizen, and original member of The Committee, and either have first hand knowledge of the facts herein or upon information and belief.

 

  1. I have read the foregoing Motion and the facts contained therein are true to the best of my knowledge.

 

  1. I hereby certify that the foregoing statements made by me are true. I am aware that if any of the foregoing statements made by me are willfully false, I am subject to punishment.

 

 

                                                                                                   

                                                               _______________________________________

                                                                    Don P. Hurley

 

Dated:  June 27, 2007