E-Filed 08/07/2013 @ 12:15:19 PM Honorable Julia Jordan Weller Clerk Of The Court

C a s e No.

1120465

IN

THE SUPREME COURT OF A L A B A M A

HUGH M C I N N I S H ,

eta l . ,

Appellants, v. BETH CHAPMAN, i n h e r c a p a c i t y Appellee. as S e c r e t a r y of State,

ON A P P E A L FROM THE C I R C U I T COURT OF MONTGOMERY COUNTY, ALABAMA CV 2013-1053

AMICUS B R I E F Leave granted brief to

OF THE ALABAMMA R E P U B L I C A N A S S E M B L Y file this amicus court, brief having been

by t h i s

honorable

this

i s t h e memorandum a grassroots and the

o f t h e Alabama of

Republican

Assembly, Alabama

movement

conservatives

across Party

"conscience" by the President Republican

of the Republican Reagan. Party ARA

("ARA") a s

stated back

i s dedicated and

to taking

f o r the vast

disenfranchised believe

majority in small

o f i t s members: Reagan

c o n s e r v a t i v e s , who

government, lower t a x e s , f r e e market c a p i t a l i s m , a to l i f e , and a decent America.

strong

defense, the right

ARA

has

an

inherent of each

and

strong on

interest the

in insuring

the the

legitimacy more so in

candidate of the

Alabama b a l l o t , chief

the

case motion such and

country's filed a

executive App. to

officer. P. 29, and the

This as

i s being both

u n d e r A l a . R. for leave

i t is the leave

request curiae to

file

amicus filed ARA

amicus be

itself do.

which

w o u l d be

should strongly

granted that the

believes Court further

decision is

of

the

Montgomery C o u n t y C i r c u i t to Alabama will law. ARA

in this

matter that the

contrary erroneous of

believes and

decision

deprive the right and

i t s membership

citizens are

Alabama w i t h States

to ensure t h a t candidates the qualifications for

United as

citizens

meet law.

office

s e t o u t by

applicable ARA

i s appalled

at

the taken of

thought to

that

simple

and

reasonable of of the

steps

c a n n o t be The

insure

the

sanctity capacity and the the the

ballot.

Secretary

State, has

i n her the

Chief

Elections to of and make the

Officer, reasonable candidates do

power into of in

responsibility qualifications United States,

inquiries for

President especially

should

so,

instant that

case

where

she has

i n hand

credible

evidence

something In

i s amiss. v. Chapman the appellants Chapman to are merely from

McInnish that

asking the

the court

require fide birth

secure

c a n d i d a t e s a bona a legal

certificate. that

There i s

scarcely required, life, school, job. to

citizen

i n the state of a

has not been every-day to start for a birth

i n the simple pursuit produce a his birth Cub by the that Scout the

normal -

certificate troop, Court to to

to join If

qualify demand

ordered from

certificates excuse staff" moniker is to

candidates, she "has

the no

Secretary's investigative of the

for inaction cannot stand,

f o r nothing

deserving

"investigation" letter

i s required. A l l that

i s needed each

an o f f i c i a l send

t o each

candidate requiring

her a b i r t h

certificate,

one o f c o u r s e w h i c h i s that no funds

genuine. are

And i n response

t o t h e argument a thing,

i n t h e budget be t h e c o s t ARA joins

f o r such of mailing McInnish, plea

the only

expense

would

the l e t t e r . et a l . i n asking o f mandamus that the directed

with

Court

grant

their

f o r a writ

to

the Secretary action.

of State

requiring

her to effect

this

simple

/s/ Jim Z-eigi^
A t t o r n e y f o r the Alabama Republican Assembly OF COUNSEL: Jim Zeigler 1301 A z a l e a Rd, M o b i l e , A l a b a m a 36693 251-660-2060 ZeiglerElderCare@yahoo.com ASB 7 6 8 4 - I 7 2 J

CERTIFICATE OF

SERVICE

I h e r e w i t h c e r t i f y t h a t o n A u g u s t 7, 2 0 1 3 I s e r v e d t h i s a m i c u s memorandum b r i e f t o t h e C l e r k o f t h e A l a b a m a Supreme C o u r t as w e l l as t o a l l c o u n s e l i n t h i s c a s e , as l i s t e d b e l o w . L . Dean J o h n s o n L Dean J o h n s o n , P. C. 4030 B a l m o r a l D r . S u i t e H u n t s v i l l e , AL 38801 L a r r y Klayman K l a y m a n Law F i r m 2020 P e n n s y l v a n i a A v e . , S u i t e 800 W a s h i n g t o n , DC 2 0 0 0 6

B

N.W.

Hon L u t h e r S t r a n g e Margaret L. Fleming J a m e s W. D a v i s Laura E. Howell A t t o r n e y General o f Alabama 501 W a s h i n g t o n S t . Montgomery, AL 36130

/s/

Jim Z-eigLcr

Jim Z e i g l e r 1301 A z a l e a Rd, M o b i l e , A l a b a m a 36693