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MICHAEL C. VOELTZ, Circuit Case No.: 2012CA00467 Appellant, vs. BARACK HUSSEIN OBAMA, et. al.
Appellees. ____________________________________________ /
REPLY IN SUPPORT OF MOTION FOR WRITTEN OPINION PURSUANT TO FLORIDA RULE OF APPELLATE PROCEDURE 9.330(a)
Appellant Michael Voeltz hereby files his reply in support of his Motion for Written Opinion. Appellant's motion was timely. Rule 2.514(b), Fla. R. Jud. Admin. provides for a 5 day period after any service by mail or email. It does not exclude orders from the court, nor can Appellees point to where there is an exception to the rule. The court's order of February 8, 2013 was served via email and/or a written copy of the order and the deadline for filing the motion is thus extended by the 5 days provided. If Appellant misread the rule, which he does not believe he did, then Appellant respectfully moves for leave of court to file the Motion for Written Opinion. Neither party has been or will be prejudiced by the motion, and in the interest of justice it would be beneficial to both Appellant and Appellees to have a written opinion issued.
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For the forgoing reasons, Appellant respectfully requests that this Court issue a written opinion in the above styled case.
Respectfully submitted,
/s/ Larry Klayman Larry Klayman, Esq. Florida Bar No. 246220 2020 Pennsylvania Ave. NW, Suite 800 Washington, DC 20006 Tel: (310) 595-0800 Email: leklayman@gmail.com
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CERTIFICATE OF SERVICE I CERTIFY that a copy of the foregoing Reply in Support of Motion for Written Opinion has been filed electronically and thus served via email this 11th day of march, 2013 to the following: Daniel Nordy Ashley E. Davis Florida Department of State R.A. Gray Building 500 South Bronough Street Tallahassee, FL 32399 Mark Herron Joseph Brennan Donnelly Robert J. Telfer, III Messer, Caparello & Self, P.A. Post Office Box 15579 Tallahassee, FL 32317
Stephen F. Rosenthal Podhurst Orseck, P.A. 25 West Flagler Street, Suite 800 Miami, FL 33130-1720
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Richard B. Rosenthal The Law Offices of Richard B. Rosenthal, P.A. 169 East Flagler Street, Suite 1422 Miami, FL 33131 James A. Peters Office of the Attorney General FL-01, The Capital
Tallahassee, FL 32399-105
Respectfully submitted,
/s/ Larry Klayman Larry Klayman, Esq. Florida Bar No. 246220 2020 Pennsylvania Ave. NW, Suite 800 Washington, DC 20006 Tel: (310) 595-0800 Email: leklayman@gmail.com
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