Case: 12-6082

Document: 006111434649

Filed: 09/16/2012

Page: 1

UNITED STATES COURT OF APPEALS FOR THE SIXTH CIRCUIT CIVIL APPEAL STATEMENT OF PARTIES AND ISSUES Case No: 12-6082 Case Manager:

Case Name: Liberty Legal Foundation et al. v. National Democratic Party et al. Is this case a cross appeal? Yes No Has this case or a related one been before this court previously? If yes, state: Case Name: Citation: Was that case mediated through the courts program? Yes

Yes

No

Please Identify the Parties Against Whom this Appeal is Being Taken and the Specific Issues You Propose to Raise:

This is to certify that a copy of this statement was served on opposing counsel of record this 16th day of
September , 2012

nd s

of

Fr

ie

6CA-53 Rev. 6/08

Th e
.

Specifically, as grounds for its order the District Court ruled that appellants' complaint did not contain certain factual allegations that said complaint did contain. Also, the District Court's order cited grounds for sanctions that the defendants never asserted as grounds for sanctions and that the District Court never asserted prior to the order, thereby denying appellants' attorney any opportunity to respond after notice of said grounds. The District Court also denied appellants' attorney's request for a hearing. Also, the District Court sanctioned appellants' attorney for arguing an issue of first impression, despite well established precedent prohibiting such sanctions for arguing an issue of first impression.

Fo
s/Van R. Irion

The Order entered by the District Court sanctioning the plaintiff/appellants' attorney contained material factual errors, applied the wrong legal standard, misapplied the legal standard, and violated the appellants' attorney's due process rights.

Name of Counsel for Appellant

gb

This Appeal is being taken against the Democratic National Committee, the Tennessee Democratic Party, Debbie Wasserman Schultz, and Chip Forrester.

ow

No

.c o