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2012-05-03 SOS Response in Opposition to Taitz Notice of Improper Remov

2012-05-03 SOS Response in Opposition to Taitz Notice of Improper Remov

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Published by Jack Ryan

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Categories:Types, Research, Law
Published by: Jack Ryan on May 03, 2012
Copyright:Attribution Non-commercial

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05/04/2012

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IN THE UNITED STATES DISTRICT COURTFOR THE SOUTHERN DISTRICT OF MISSISSIPPIJACKSON DIVISIONDR. ORLY TAITZ, ESQ., ET AL. PLAINTIFFSV. CIVIL ACTION NO. 3:12cv280-HTW-LRADEMOCRAT PARTY OF MISSISSIPPI, ET AL. DEFENDANTS ______________________________________________________________________________ MISSISSIPPI SECRETARY OF STATE’S RESPONSEIN OPPOSITION TO PLAINTIFFS’ “NOTICE OF AN IMPROPER ATTEMPT BY THE DEFENDANT TO REMOVE THE CASE TOFEDERAL COURT WHILE IT IS BEING CONSIDEREDBY THE SUPREME COURT OF MISSISSIPPI” ______________________________________________________________________________ 
Defendant Mississippi Secretary of State Delbert Hosemann files this Response inOpposition to Plaintiffs’ “Notice of an Improper Attempt by the Defendant to Remove the Caseto Federal Court while it is being Considered by the Supreme Court of Mississippi” [Docket No.10] and states:1.The Secretary of State submits that plaintiffs’ “Notice of an Improper Attempt bythe Defendant to Remove the Case to Federal Court while it is being Considered by the SupremeCourt of Mississippi,” if the Court treats the filing as a Motion or other request for affirmativerelief, should be denied for the reasons set forth in the Secretary of State’s separate Response inOpposition to Plaintiffs’ “Demand for Immediate Termination of Unlawful Proceedings inFederal Court and for Sanctions Against the Secretary of State and Defendants Attorney.”2.The Secretary of State hereby incorporates his Response in Opposition toPlaintiffs’ “Demand for Immediate Termination of Unlawful Proceedings in Federal Court andfor Sanctions Against the Secretary of State and Defendants Attorney” by reference and submits
Case 3:12-cv-00280-HTW-LRA Document 14 Filed 05/03/12 Page 1 of 3
 
2that plaintiffs’ request for relief, if any, should be denied for the reasons stated therein. [
See
Docket No. 13].FOR THESE REASONS, and those set forth in his separate Response to plaintiffs’“Demand for Immediate Termination of Unlawful Proceedings in Federal Court and for Sanctions Against the Secretary of State and Defendants Attorney” [Docket No. 13], theSecretary of State respectfully requests that the Court enter an order denying plaintiffs’ “Noticeof an Improper Attempt by the Defendant to Remove the Case to Federal Court while it is beingConsidered by the Supreme Court of Mississippi” [Docket No. 10].THIS the 3 day of May, 2012.
rd
Respectfully submitted,Delbert Hosemann, MississippiSecretary of StateBY:Jim Hood, Attorney GeneralState of MississippiBY:S/Justin L. MathenyHarold E. Pizzetta, III (Bar No. 99867)
hpizz@ago.state.ms.us
Justin L. Matheny (Bar No. 100754)
 jmath@ago.state.ms.us
Office of the Attorney General550 High Street, Suite 1200P.O. Box 220Jackson, MS 39205Telephone: (601) 359-3680Facsimile: (601) 359-2003
Case 3:12-cv-00280-HTW-LRA Document 14 Filed 05/03/12 Page 2 of 3

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