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TN - 2012-06-18 - Defendants Motion to File Reply & Reply

TN - 2012-06-18 - Defendants Motion to File Reply & Reply

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Published by Jack Ryan
06/18/2012
30
MOTION for Leave to File Reply in Support of Motion for Sanctions and Motion for Leave to Exceed Page Limitation by Chip Forrester, Tennessee Democratic Party. (Attachments: # 1 Exhibit A - Defendants' Reply in Support of Motion for Sanctions)(Stranch, J.) (Entered: 06/18/2012)
06/18/2012
30
MOTION for Leave to File Reply in Support of Motion for Sanctions and Motion for Leave to Exceed Page Limitation by Chip Forrester, Tennessee Democratic Party. (Attachments: # 1 Exhibit A - Defendants' Reply in Support of Motion for Sanctions)(Stranch, J.) (Entered: 06/18/2012)

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Published by: Jack Ryan on Jun 19, 2012
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06/21/2012

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IN THE UNITED STATES DISTRICT COURTFOR THE WESTERN DISTRICT OF TENNESSEELIBERTY LEGAL FOUNDATION,JOHN DUMMETT, LEONARDVOLODARSKY, CREG MARONEY,Plaintiffs,vs.NATIONAL DEMOCRATIC PARTY OFTHE USA, INC., DEMOCRATICNATIONAL COMMITTEE, TENNESSEEDEMOCRATIC PARTY, DEBBIEWASSERMAN SCHULTZ, and CHIPFORRESTER,Defendants.))))))))))))))))Case No. 2:12-cv-02143-cgcRemoval of Case No. CH-11-1757-3 FromChancery Court for the State of Tennesseein Shelby County
DEFENDANTS’ MOTION FOR LEAVE TO FILE AREPLY IN SUPPORT OF MOTION FOR SANCTIONS ANDMOTION FOR LEAVE TO EXCEED PAGE LIMITATION
Defendants , the Tennessee Democratic Party (“TNDP”), and Chip Forrester (collectivelythe “TNDP Defendants”), hereby request leave of this Court to file a Reply in Support of Motionfor Sanctions (Dkt. No. 25) addressing issues raised in Plaintiffs’ Response in Opposition toDefendants’ Motion for Sanctions (Dkt. No 29). A copy of the Reply is attached hereto asExhibit A.To fully address the issues raised in Plaintiffs’ Response in Opposition to Defendants’Motion for Sanctions, the TNDP Defendants further request leave to file a Reply Memorandumnot exceeding 15 pages.
Case 2:12-cv-02143-STA-cgc Document 30 Filed 06/18/12 Page 1 of 2 PageID 453
 
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Dated: June 18, 2012 By: /s/ J. Gerard Stranch, IVJ. Gerard Stranch, IV (BPR#023045)Benjamin A. Gastel (BPR#028699)BRANSTETTER, STRANCH& JENNINGS, PLLC227 Second Avenue North, 4th FloorNashville, TN 37201-1631Telephone: 615/254-8801Facsimile: 615/255-5419gerards@branstetterlaw.combeng@branstetterlaw.com
Counsel for the Tennessee Democratic Partyand Chip Forrester 
CERTIFICATE OF SERVICE
I hereby certify that the foregoing was served via the Court’s CM/ECF system, on June18, 2012, upon:Van IrionLiberty Legal Foundation9040 Executive Park Dr., Ste. 200Knoxville, TN 37923 /s/ J. Gerard Stranch, IVJ. Gerard Stranch, IV
Case 2:12-cv-02143-STA-cgc Document 30 Filed 06/18/12 Page 2 of 2 PageID 454
 
 
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IN THE UNITED STATES DISTRICT COURTFOR THE WESTERN DISTRICT OF TENNESSEELIBERTY LEGAL FOUNDATION,JOHN DUMMETT, LEONARDVOLODARSKY, CREG MARONEY,Plaintiffs,vs.NATIONAL DEMOCRATIC PARTY OFTHE USA, INC., DEMOCRATICNATIONAL COMMITTEE, TENNESSEEDEMOCRATIC PARTY, DEBBIEWASSERMAN SCHULTZ, and CHIPFORRESTER,Defendants.))))))))))))))))Case No. 2:12-cv-02143-cgcRemoval of Case No. CH-11-1757-3 FromChancery Court for the State of Tennesseein Shelby County
DEFENDANTS’ REPLY IN SUPPORT OF MOTION FOR SANCTIONS
On May 25, 2012, Defendants, the Tennessee Democratic Party (“TNDP”), and ChipForrester (collectively the “TNDP Defendants”), filed a Consolidated Motion and Memorandumin Support of Sanctions requesting this Court impose sanctions against Plaintiffs Liberty LegalFoundation, John Dummett, Leonard Volodarsky and Creg Maroney (collectively the“Plaintiffs”) and Plaintiffs’ counsel for violations of Rule 11 and 28 U.S.C. § 1927 (Dkt. No. 25,the “Motion for Sanctions”). On June 8, 2012, the Plaintiffs filed its Opposition to the Motionfor Sanctions (Dkt. No. 29, the “Opposition”). The TNDP Defendants now file this Reply inSupport of their Motion for Sanctions.
INTRODUCTION
This lawsuit has no basis in fact and law. Rather than attack this central point of theMotion for Sanctions, Plaintiffs instead lead with the bald and unfounded allegation that counsel
Case 2:12-cv-02143-STA-cgc Document 30-1 Filed 06/18/12 Page 1 of 14 PageID 455

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