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AL 2012-11-27 - McInnish Goode v Chapman - Plaintiffs Motion to Appear by Telephone1

AL 2012-11-27 - McInnish Goode v Chapman - Plaintiffs Motion to Appear by Telephone1

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Published by: Jack Ryan on Nov 28, 2012
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12/04/2012

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 AlaFileE-Notice
To:RAGSDALEBARRYALANbragsdale@sirote.com
03-CV-2012-001053.00
Judge:HON.EUGENEW.REESE
NOTICEOFELECTRONICFILING
INTHECIRCUITCOURTOFMONTGOMERYCOUNTY,ALABAMA
ThefollowingmatterwasFILEDon11/28/20121:39:55PM
HUGHMCINNISHANDVIRGINHGOODEJRVS.BETHCHAPMAN03-CV-2012-001053.00TOAPPEARBYTELEPHONE
NoticeDate:11/28/20121:39:55PM[Filer:JOHNSONLAWRENCEDEAN]
FLORENCECAUTHENCIRCUITCOURTCLERK
MONTGOMERYCOUNTY,ALABAMA251S.LAWRENCESTREETMONTGOMERY,AL36104334-832-4950
C002 GOODE VIRGIN H JRC001 MCINNISH HUGH
 
/s/ LAWRENCE DEAN JOHNSON
Signature of Attorney or Party:Date:Check here if you have filed or are filingcontemoraneously with this motion an Affidavit of Substantial Hardship or if you are filing on behalf of anagency or department of the State, county, or municipalgovernment. (Pursuant to §6-5-1 Code of Alabama(1975), governmental entities are exempt fromprepayment of filing fees)
Case No.
STATE OF ALABAMA
Unified Judicial System
03-MONTGOMERY
District CourtCircuit Court
Revised 3/5/08
HUGH MCINNISH AND VIRGIN H GOODE JR VS.BETH CHAPMAN
CIVIL MOTION COVER SHEET
Name of Filing Party: Name, Address, and Telephone No. of Attorney or Party. If Not Represented.Attorney Bar No.: 
LAWRENCE DEAN JOHNSON4030 BALMORAL DRIVE, SUITE BHUNTSVILLE, AL 35801JOH046
TYPE OF MOTION
Motions Requiring FeeMotions Not Reuirin Fee
Default Judgment ($50.00)Joinder in Other Party's Dispositive Motion (i.e.Summary Judgment, Judgment on the Pleadings, or other Dispositive Motion not pursuant to Rule 12(b))($50.00)Summary Judgment pursuant to Rule 56($50.00)Renewed Dispositive Motion(Summary Judgment,Judgment on the Pleadings, or other DispositiveMotion not pursuant to Rule 12(b)) ($50.00)Judgment on the Pleadings ($50.00)Motion to Dismiss, or in the Alternative SummaryJudgment($50.00)Other  Add Party AmendChange of Venue/Transfer CompelConsolidationContinueDepositionDesignate a Mediator Judgment as a Matter of Law (during Trial)Disburse FundsExtension of TimeIn LimineJoinder More Definite StatementMotion to Dismiss pursuant to Rule 12(b)New TrialObjection of Exemptions ClaimedPlaintiff's Motion to DismissPreliminary InjunctionProtective Order QuashRelease from Stay of ExecutionSanctionsSever Special Practice in AlabamaStayStrikeSupplement to Pending MotionVacate or ModifyWithdrawOther To Appear by Telephonepursuant to Rule
77
(Subject to Filing Fee)pursuant to Rule($50.00)
*This Cover Sheet must be completed and submitted to the Clerk of Court upon the filing of any motion. Each motion should contain a separate Cover Sheet.**Motions titled 'Motion to Dismiss' that are not pursuant to Rule 12(b) and are in fact Motions for Summary Judgments are subject to filing fee.
*Motion fees are enumerated in §12-19-71(a). Feespursuant to Local Act are not included. Please contact theClerk of the Court regarding applicable local fees.Local Court Costs $
C001 - MCINNISH HUGHC002 - GOODE VIRGIN H JR
11/28/2012 1:22:35 PMCV201200105300
Pendente LiteOral Arguments RequestedMotion to Intervene ($297.00)
 
ELECTRONICALLY FILED11/28/2012 1:39 PMCV-2012-001053.00CIRCUIT COURT OFMONTGOMERY COUNTY, ALABAMAFLORENCE CAUTHEN, CLERK
 
HUGH
MCINNISH,
et.
al,
Plaintiffs,
vs.
IN
THE
CIRCUIT
COURT
OF
MONTGOMERYCOUNTY,
ALABAMA
))
)
)
)
)
Civil
Action
No.:
CV-2012-001053
BETH
CHAPMAN,
Secretary
of
State
I
)
Defendant.
MOTION
TO
APPEAR
BYTELEPHONE
Plaintiffs
Hugh
Mclnnish
and
Virgil
H.
Goode,
Jr.
by
and
through
their
undersigned
counsel,
hereby
respectfully
request
thatco-counsel
LarryKlayman
be
permittedto
appear
by
telephoneat
thehearing
for
Defendant's
Motionto
Dismiss,
currently
set
for
December
6,2012
infrontof
theHonorable
Eugene
W.
Reese
and
as
grounds
thereforwould
show:
l.
Attorney
Lany
Klayman
is
currently
located
in
LosAngeles,
cA.
2.
The
hearing
set
for
December
6,2012
at
9:30a.m.is
scheduled
to
last
for
l5
minutes
for
each
side.
3'
LarryKlayman
islocated
in
LosAngeles
and
granting
leave
for
himto
appear
by
telephone
would
save
considerable
time
and
expense.
This
case
isbeing
litigated
with
very
limited
financial
resources.
ELECTRONICALLY FILED11/28/2012 1:39 PMCV-2012-001053.00CIRCUIT COURT OFMONTGOMERY COUNTY, ALABAMAFLORENCE CAUTHEN, CLERK

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