Professional Documents
Culture Documents
Case
No. 1,720465
COURT OF ALABAMA
IN THE SUPREME
HUGH
v.
BETH
cv
Appell-ants' Reply to
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L. L.
Dean Johnson
Larry
KLAYMAN
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Klayman
DEAN JOHNSON, P. C.
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Suite
800
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201,3_1053
B
pellee's Brief
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TABLE OF CONIENTS
TABLE OF AUTHORITIES
SUMMARY
ARGUMENT
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IL
STATUTE DOES NOT APPLY
TABLE OF CONTENTS
i
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OF THE
ARGUMENT
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I. rT.
CASE NOT
MOOT
A. .]URISDICTION STRIPPING
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B.
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DUTY
AUTHORITY. EXCUSE
III.
CHAPM
'S
SILENCE
CONCLUSION
OF
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CERTIFICATE OF SERVICE
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TABLE OF AUTEORTTIES
Cases
thority
peal
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Ala. Code S 1,7 -9-3: persons entitled to have names printed on ballots; failure to Secretary of State to certify nominations
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v. Pennsylvania Board of Probation and role, The C onweal-th Court of pennsylvania, No. 598 II, D. 2007, ,,an unr orted. single-judge,Memorandum inion,,,
Coady
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Chapman's
two
iq nrnh:l-rla !o vlvvqulE
r-^1- or.rnrrz Drle aha dvers 1 rz /-nnnr^vquEyvrJ aVe1. S tnaE. that orrr_y 6rn uongress- can act
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,,-f urrsr, l-^!u!
^n^ af.*,
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'll^*L^l appeJ-lantl
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terse form.
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barlots are arready printed it is too l-ate for correction even if an error is manifest.
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that
responsibirity whatsoever for interdicting the names of potential candidates who mav
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SinCe
categories: First, she argues that this court l_acks jurisdiction to hear the case and, second, she presents
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ARGI'MENT
is
moot.
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A.
OF
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r1-76-44. But as we have already explained, this statute is re]evant to the conduct of el_ect.ions, and
i n .nroqi_ i an has alreadv been conducted.
the election
we
are' on the contrary, asking chapman to take the extraordinarily simple step, of demandinq birth
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is sufficient to render a case nonmoot, and showing, further, that thj_s case meets, not iust the
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their original brief, showing that there are three exceptions to the mootness doctrine, any one of which
But this case is not moot. Mcrnnish and Goode have carefully explained the doctrine of nonmootness in
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f.
fn her brief
chapman first
certificates
Apperl-ants' original
brief,
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r-or.| i frz wr-rry anl v quarJ-rf arrrl.i -i eo vsrLrrv ^,-J candi-dates by decf aring that
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implication is crear: The lawmakers anticipated that office sought and these shoul-d be excruded. (AB, 30. rn the present case there is prentiful at least one of the presidential unqualified.
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Al_a
. Code S I1-g-3 .
evidence that
was
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candidates
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inquiry.
official
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for the for the
)
The an
bel-ieve that president obama has not met a certifvinq of Maricopa County Arizona (and indisputably, official
empowered by the l-aw of the state),
'....that forgerv
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straf -i on
card,,
D)
sheriff Arpaio is undoubtedly an official_ source. rn addition, the Ful-l- Faith and credit cl_ause of the u.s.
"Ful.l- Faith and Credit
every other state. " The fact that sheriff Arpaior ds a public official_, the pubric in investigating
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the public Acts, Records, and judicial- proceedings of Arpaio is in sherif f Arizona, and not in Al-abama, is irrer-evant.
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Constitution,
Article
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(AB, Appendix
the quarifications
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President
Obama and
his
the united states, and, furl faith and credit shoutd Fortunately for justice it is not too
findings-
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an
of
r_ate
to correct
and this
Court has
needed to do so.
C. Chapman alleges that only Congress has the authority to judge the qualifications candidates after an election. qualifications
of nre.sidential
rt is true that
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constitutional- qualifications
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D. Finally,
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Afthouqh this
note:
First,
aS haS been
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a
since
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sites stating that votes for the bogus candidate woufd not be counted. Second, this chronofogical pi_cture
q.lranrr-l rz -Lcrrrrorces, rai nnrn^d rurvrrvry
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-i ^ a stark r-n
exa
f e here
repetition rrr -
chapman's brief
silence.
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A. No word is offered in arguing that the birth certificates submitted by obama are genuine. Atl her arguments are aimed at suppressing the truth by
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discover it.
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unqualified presidential candidates on the ballots. fn 1968 Eldridoe Cl earzer wes refused ball_ot
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B. chapman's sirence regarding the two carifornia situations where the secret.ari-es of State would not
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a irrdrrmenjd, uI J Ljlrgrltgl.t L nf
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and
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in this
the printed ballot, but the effect of an erroneousrvprinted ballot, e.g., posting signs at the votins
Al-abama
Conclusion
rt may be helpful at this point to step back, take a deep breath, and look at the overal-l- scene from a
we see:
We see
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distance, to l-ook at the forest, unobscured by close-up trees and undergrowth, to l-ook at the ful_l_ picture, not
And when we do here
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certificate has been a controversy that has existed for severa] years. A11 those invol_ved have been examinino the controversy up cl_ose in great detail_.
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' See : http : hawaii . govlheal_thlvital_-records,/vital_ records/viLar records.html- for a form to obtain a birth certifi-cate from the Hawali Department of Hearth. The form
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see literal1y
documenc
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is
what
waged
the media.
And what is at the core of the issue?
birth certifi-cate.
A birth certificate,
just tike
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teenager needs to obtain a l_earner's permit and iust Iike a man needs to join the armv.
excepr
for the circumstances of the one whose birth certi-ficate is sought, namely that of Barack obama. He happens to be president of the United States, but that
i nf 'l rran^a rnA mnnnt' rr-trruerlceT ^ avoid doing so. dlr..rl\Jrrey .lLU
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in itseff does not change the simpricity at base. obama, for reasons unstated, refuses to produce
and has used his power,
when this
a required fee of $1O.OO. The DoH explains that vital- documents wil-l- be j-ssued only to persons who "have a direct and tangibl-e interest in the record." rn li_strng examples of those whom they consider to have the requisite rnterest, the first listed is "the registrant (the person whom the record is concerned with. ) " rn this case the l-atter is Barack Obama.
shows
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nonsensical- picture,
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It is
a a
in
outweigh the cost and by how much. one can imaqine his astonishment. "Prima facie-" hc min\f Sdy, "the answer
is visibl-e.
The benefits are monumental, and the costs The benefi_ts-cost ratio,
are infinit.esimal .
mo1-nrlnIt
This court has both the right and the power to su arily end this untoward controversy. By requiring the secretary of state to certificate from
demand
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Obama and
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Huntsvill_e, AL
L. Dear{Johnson \
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(JoH04
6
880-5177
BB0-5187
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therefore,
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Suite 800 Washington, DC 20006 Tel-: (310) 595-0800 Email-: l-ekl-a anGqmail-. com Pro Hac Vice
CERTIFICATE OF SERVICE
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Hon. Luther strange, Attorney Generar of Alabama Andrew L. Brasher, Deputy Solicitor General_ Margaret L. Fleming James W. Davis Laura E. Howel_1 Office of the Attorney General_ of Alabama 501 Washington Street
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r HEREBY cERTrFy that on the 14 day of May 2013, T el-ectronically filed the foregoing with the clerk of the supreme court of Al-abama using the ACrs filing system, which will- send notification of such filinq to the following:
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NW,