IN THE CHANCERY COURT OF TENNESSEE FOR THE FIFTEENTH JUDICIAL DISTRICT, AT LEBANON MAYOR LINDA ELAM, Plaintiff, Case No. / [20/9 v Chancellor C.K. Smith CITY OF MT. JULIET, Defendant. LINDA ELAM’S MOTION FOR JUDGMENT SoA MC ON THE STIPULATED FACTS : Pursuant to the Tennessee Constitution and well-established Tennessee law, Mayor Linda Elam respectfully moves the Court for entry of a declaratory judgment that the amendment to the City of Mt. Juliet Charter reflected in Ordinance 2010-40 (the “Charter Amendment”) does not prohibit her from fulfilling the remaining approximate two-year period of her term as Mayor of ithe City of Mt. Juliet (“the City”) while simultancously serving as a member of Tennessee's House of Representatives. As grounds for this motion, Elam would show the Court as follows:3. Accordingly, Elam is entitled to a declaratory judgment that the Charter Amendment does not prohibit her from fulfilling the remaining approximate two-year period of her term as Mayor of the City while simultaneously serving as a member of Tennessee's House of Representatives. In further support of this motion, Mayor Elam relies on her memorandum in support, which has been filed contemporancously herewith. Respectfully submitted, ‘ =f I. Malone (#22904) Andrew J. Ross (#28350) Walker, Tipps & Malone, PLC 2300 One Nashville Place 150 Fourth Avenue North Nashville, TN 37219 (615) 313-6000 Attorneys for Plaintiff Linda Elam