AlaFile E-Notice

To: RAGSDALE BARRY ALAN bragsdale@sirote.com

NOTICE OF ELECTRONIC FILING
IN THE CIRCUIT COURT OF MONTGOMERY COUNTY, ALABAMA

The following matter was FILED on 11/28/2012 1:39:55 PM C002 GOODE VIRGIN H JR C001 MCINNISH HUGH

TO APPEAR BY TELEPHONE [Filer: JOHNSON LAWRENCE DEAN] Notice Date: 11/28/2012 1:39:55 PM

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HUGH MCINNISH AND VIRGIN H GOODE JR VS. BETH CHAPMAN 03-CV-2012-001053.00

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03-CV-2012-001053.00 Judge: HON. EUGENE W. REESE FLORENCE CAUTHEN CIRCUIT COURT CLERK MONTGOMERY COUNTY, ALABAMA 251 S. LAWRENCE STREET MONTGOMERY, AL 36104 334-832-4950

STATE OF ALABAMA
Unified Judicial System

Revised 3/5/08

03-MONTGOMERY

District Court

Circuit Court

HUGH MCINNISH AND VIRGIN H GOODE JR VS. BETH CHAPMAN

CIVIL MOTION COVER SHEET
Name of Filing Party: C001 - MCINNISH HUGH C002 - GOODE VIRGIN H JR

ELECTRONICALLY FILED 11/28/2012 1:39 PM CV-2012-001053.00 CIRCUIT COURT OF CV201200105300 MONTGOMERY COUNTY, ALABAMA FLORENCE CAUTHEN, CLERK

Case No.

Name, Address, and Telephone No. of Attorney or Party. If Not Represented.

LAWRENCE DEAN JOHNSON 4030 BALMORAL DRIVE, SUITE B HUNTSVILLE, AL 35801
Attorney Bar No.: JOH046

TYPE OF MOTION
Motions Requiring Fee

Default Judgment ($50.00) Joinder in Other Party's Dispositive Motion (i.e. Summary Judgment, Judgment on the Pleadings, or other Dispositive Motion not pursuant to Rule 12(b)) ($50.00) Judgment on the Pleadings ($50.00) Motion to Dismiss, or in the Alternative Summary Judgment($50.00) Renewed Dispositive Motion(Summary Judgment, Judgment on the Pleadings, or other Dispositive Motion not pursuant to Rule 12(b)) ($50.00) Summary Judgment pursuant to Rule 56($50.00) Motion to Intervene ($297.00) Other pursuant to Rule

Add Party

Amend Change of Venue/Transfer Compel Consolidation Continue Deposition

*Motion fees are enumerated in §12-19-71(a). Fees pursuant to Local Act are not included. Please contact the Clerk of the Court regarding applicable local fees. Local Court Costs $

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Check here if you have filed or are filing contemoraneously with this motion an Affidavit of Substantial Hardship or if you are filing on behalf of an agency or department of the State, county, or municipal government. (Pursuant to §6-5-1 Code of Alabama (1975), governmental entities are exempt from prepayment of filing fees)

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In Limine Joinder ($50.00)

Designate a Mediator Judgment as a Matter of Law (during Trial) Disburse Funds Extension of Time

More Definite Statement Motion to Dismiss pursuant to Rule 12(b) New Trial Objection of Exemptions Claimed Pendente Lite Plaintiff's Motion to Dismiss Preliminary Injunction Protective Order Quash Release from Stay of Execution Sanctions Sever Special Practice in Alabama Stay Strike Supplement to Pending Motion Vacate or Modify Withdraw

To Appear by Telephone Other pursuant to Rule 77 (Subject to Filing Fee)
Signature of Attorney or Party:

11/28/2012 1:22:35 PM

*This Cover Sheet must be completed and submitted to the Clerk of Court upon the filing of any motion. Each motion should contain a separate Cover Sheet. **Motions titled 'Motion to Dismiss' that are not pursuant to Rule 12(b) and are in fact Motions for Summary Judgments are subject to filing fee.

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Oral Arguments Requested
Motions Not Requiring Fee
/s/ LAWRENCE DEAN JOHNSON

ELECTRONICALLY FILED 11/28/2012 1:39 PM CV-2012-001053.00 CIRCUIT COURT OF MONTGOMERY COUNTY, ALABAMA FLORENCE CAUTHEN, CLERK

IN THE CIRCUIT COURT OF MONTGOMERY COUNTY, ALABAMA

HUGH MCINNISH, et. al, Plaintiffs,
vs.

BETH CHAPMAN, Secretary of
Defendant.

State

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MOTION TO APPEAR BY TELEPHONE

counsel, hereby respectfully request that co-counsel Larry Klayman be permitted to appear by

in front of the Honorable Eugene W. Reese and as grounds therefor would show:

l.
2.

The hearing set for December 6,2012 at 9:30 a.m. is scheduled to last each side.

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Attorney Lany Klayman is currently located in Los Angeles, cA.

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telephone at the hearing for Defendant's Motion to Dismiss, currently set for December

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Plaintiffs Hugh Mclnnish and Virgil H. Goode, Jr. by and through their undersigned

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Civil Action No.: CV-2012-001053

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Larry Klayman is located in Los Angeles and granting leave for him to appear by

telephone would save considerable time and expense. This case is being litigated with

very limited financial resources.

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6,2012 for l5 minutes for

4- Plaintiffs'other 5.

attorney, L. Dean Johnson, will be present at the hearing in person.

WHEREFORE, Plaintiffs respectfully request that the motion be granted and that Mr.
Klayman be granted leave to appear at the hearing of December 6,2012 by telephone.

Dated: November 28. 2012

Respectfully submitted,

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Larry Klayman, Esq. Klayman Law Firm 2020 Pennsylvania Ave. NW, Suite 800 Washington, DC 20006 Tel: (310) 59s-0800 Email : leklayman@gmail.com Pro Hac Vice

/s/ L. Dean Johnson L. Dean Johnson (JOH046) L. Dean Johnson, P.C. 4030 Balmoral Dr., Suite B Huntsville, AL 35801 Tel: (256) 880-5177 Fax: (256) 880-5187 Email: Johnson dean@bellsouth.net

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No prejudice will result if the motion is granted.

CEBTTFTCATE OF SpRVTCE

following:

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L. Dea{r Joh4son Of Counsel
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Hon. Luther Strange Margaret L. Fleming James W. Davis Laura E. Howell Attorney General of Alabama 501 Washington Street Montgomery, Alabama 361 30

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I HEREBY CERTIFY that on the 28h day of November, 2012,I filed the forgoing with the Clerk of Court using the Alafile system, which will send notification of such filing tJthe

ELECTRONICALLY FILED 11/28/2012 1:39 PM CV-2012-001053.00 CIRCUIT COURT OF MONTGOMERY COUNTY, ALABAMA FLORENCE CAUTHEN, CLERK
IN THE CIRCUIT COURT OF MONTGOMERY COUNTY, ALABAMA

MCINNISH HUGH, GOODE VIRGIN H JR, Plaintiffs, V. CHAPMAN BETH, Defendant.

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APPEARANCE BY TELEPHONE

This cause having come before the Court, the same having been considered, it is hereby

ORDERED, ADJUDGED and DECREED that Attorney Larry Klayman shall be granted leave to appear by telephone at the hearing set for December 6, 2012 at 9:30 a.m.

DONE this[To be filled by the Judge].

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/s/[To be filled by the Judge] CIRCUIT JUDGE

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ORDER

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Case No.: CV-2012-001053.00

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