IN THE CIRCUIT COURT : BARBARA OSBORN KREAMER,

FOR : PETITIONER

ANNE ARUNDEL COUNTY, : V.

MARYLAND : MARYLAND STATE BOARD

: OF ELECTIONS,

: RESPONDENT

: Case No: C-02-CV-18-000629

* * * * * * * * * * * *

PETITION FOR PRELIMINARY INJUNCTION , INJUNCTION

AND PRELIMINARY RESTRAINING ORDER

NOW COMES Barbara Osborn Kreamer, the Petitioner, to pray that This Honorable Court
issue a preliminary injuNction, a permanent injunction and a preliminary restraining order
against the Maryland State Board of Elections, the Respondent, to prevent the candidacy of
Mary-Dulany James from going forward and from appearing on the ballot in the 2018
Gubernatorial Elections as a Democratic or any other party candidate for office of Maryland
Senate for District 34, Harford County and state as reasons therefore:

1. A person who files to be a candidate for the Maryland General Assembly is required to be
a registered voter in the of the district for which the person files for six months.
2. A registered voter is required to be domiciled in the district of Maryland in which he or
she registers for thirty days prior to registration.
3. Petitioner is a registered voter of Aberdeen, Harford County, MD and a former Delegate
representing the 34th District, a domiciliary of 701 Beards Hill Road since 1976.
4. Mary-Dulany James is a former Delegate representing District 34, then Harford and Cecil
Counties.
5. Both Petitioner and Mary-Dulany James have filed to be Democratic candidates for
Senate for District 34.
6. Petitioner is bringing this action before this Honorable Court to challenge the residency
of Mary-Dulany James.
7.
Mary-Dulany James was a candidate for Senate for District 34 in 2014. Her opponent,
former District 34 Senator Arthur H. Helton, Jr., claimed that she was not a resident of
Harford County but rather was a resident of Baltimore. However, he did not file a
complaint in court because he was not a resident of District 34, either, being domiciled at
3067 Harmony Church Road in Darlington, which is in District 35.
8. Mary-Dulany James did not file a challenge to former Senator Arthur H. Helton’s
candidacy apparently because her own residency was questionable at the time.
9. The Gubernatorial election of 2014 played out, and neither Democratic candidate became
the Senator from District 34.
10. Before 2014 Mary-Dulany James divorced her husband Brian B. Feeney in an action in
the Circuit Court for Harford County.
11. Their marital home had been at 550 Old Bay Lane in Havre de Grace.
12. Brian Feeney continued to reside at 550 Old Bay Lane with his and Mary-Dulany James’
minor children.
13. Mary-Dulany James moved in with her fiancée, John H. Zink, III before the 2014
election.
14. John H. Zink, III currently resides at 13 Devon Hill Road, Unit 5, Baltimore in District
11.
15. Mary-Dulany James and John H. Zink, III were engaged and were law partners in James
and Zink sharing office space with Joseph Snee, Esq. in Bel Air, Maryland since before
2014and up until the present day.
16. Petitioner filed her candidacy for MD Senate on or about February 16, 2018.
17. On or about February 20, 2018 the MD Senate President told Petitioner that one of the
attributes of Mary-Dulany James is that she is a wife.
18. On or about February 22, 2018 Mary-Dulany James filed her candidacy for MD Senate.
19. Petitioner asked Mary-Dulany James about her marital status; she replied that she had
married about three years ago. Petitioner asked if the marriage records were in the Circuit
Court for Harford County. Mary-Dulany James replied that she had gotten married
elsewhere. Petitioner asked her to send a copy of her marriage license to her since it
would bear on her residency. Mary-Dulany James has not done so to date.
20. In the matter of the late Senator Blount, a challenge to his residency by former Delegate
Frank Boston failed because Senator Blount had not abandoned his longtime domiciliary
when his wife joined many City residents in moving from Baltimore City to Baltimore
County although he resided most of the time in Baltimore County.
21. A question here is whether a person who divorces one spouse and leaves him in the
marital home and marries another spouse and moves in with him in another district can
maintain her domicile in what is the domicile of her now ex-spouse.
22. A question here is the subterfuge of remaining registered to vote at the old domicile while
residing at a new location outside the electoral district sufficient contact with District 34
to sustain a candidacy?
23. Questions here are did Mary-Dulany James marry after her divorce from Brian Feeney,
whom did she marry, and where does she live?
24. It would irreparably harm the public confidence in the administration of election laws if
an interloper is allowed to file and run for office on the basis of a false claim of
residency.
WHEREFORE, Petitioner prays this Honorable Court to grant her the following relief:

A. Issue a preliminary injunction to the Maryland State Board of Elections staying Mary-
Dulany James’ registration at 550 Old Bay Lane pending the inquiry in the Court;
B. Issue a Temporary Restraining Order to the Maryland State Board of Elections
suspending the candidacy of Mary-Dulany James for Senate District 34 and preventing it
from appearing on the ballot in 2018 pending resolution of this complaint;
C. Schedule a hearing on this matter;
D. Issue a Permanent Injunction to the Maryland State Board of Elections prohibiting the
candidacy of Mary-Dulany James for Senate District 34; and
E. For such other and further relief as the nature of this cause may require.

Respectfully submitted

________________________________________
BARBARA OSBORN KREAMER
Petitioner Pro Se
701 Beards Hill Road
Aberdeen, Maryland 21001-1756
(410) 272-3831

AFFIDAVIT

I HEREBY CERTIFY that the matters and facts set forth herein are true and correct to
the best of my knowledge, information and belief.

____________________________________
BARBARA OSBORN KREAMER

CERTIFICATE OF SERVICE

I HERBY CERTIFY that on March 8, 2018 I mailed, postage prepaid, or delivered a

copy of the foregoing Petition to the Respondent:

Jared Demarinis, Administrator Campaign Finance and Elections

Maryland State Board of Elections
151 West St., Suite 200
Annapolis, MD 21401

_________________________________
BARBARA OSBORN KREAMER