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Eugene Martin LaVergne

Democratic-Republican for United States Senate 543 Cedar Avenue West Long Branch, New Jersey 07764 Telephone: (732) 272-1776

October 10, 2013

Honorable Mary C. Jacobson, A.J.S.C. Superior Court of New Jersey Law Division Civil Part Mercer County Court House Trenton, New Jersey 08625 RE: LaVergne v. Lonegan Docket No. MER-L-2013-13 Dear Judge Jacobson: In furtherance of the Courts Oral Order on the record from the bench at the motion for reconsideration hearing on Tuesday October 8, 2013, since the Court has now indeed without question substantively ruled in my favor in this declaratory judgment action claim by the Court finding as fact and law that State Election Law was violated by the State and County Official defendants - but the Court declined both on October 3, 2013 and on October 8, 2013 to Order any actual remedy for the clear violation of State Election Laws due to claimed time constraints - the Court ruled that there is no question that I have prevailed within the meaning of New Jersey Court Rules and otherwise under New Jersey law, thereby entitling me to an Order directing that the collective defendants pay and reimburse the costs incurred by me and my Senate Campaign in the above litigation. To this end, enclosed please find my Certification of Costs and a proposed form of Order which I am submitting under the so called Five Day Rule. I would ask that the Court sign and file the Order with the Clerk of the Court after 5 days unless any party files written substantive objection within the 5 day period, in which case the Court must then schedule and hold a hearing to settle the form of Order and otherwise fix the quantum of costs. I also note that in this case there were 30 parties (23 named party defendants and 7 interested parties) located throughout the State of New


Jersey literally in all 21 Counties, all who were specifically required by this Court to be personally served with the voluminous documents and papers in an expedited manner and all by September 20, 2013 - all within 4 days of the entry of the Order to Show Cause on September 16, 2013 - that the costs ultimately incurred, including the motion for reconsideration, come to a little over only $225.00 per party. This is noted from the onset as - in the event that there is some bad faith and factually baseless challenge to the quantum of costs incurred necessitating a hearing the Court should be cognizant of the fact that any challenge will cost the taxpayers in each County more than $225.00 per billable hour for their respective County Counsel to even file an objection and / or to appear (even by telephone) at any hearing to settle the form of order, all of which surely will take much more than 1 hour. Respectfully submitted,

Eugene Martin LaVergne, Pro Se Democratic-Republican for United States Senate cc: Donna Kelly, D.A.G. All County Counsel