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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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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
ELECTRONICALLY FILED 11/28/2012 1:39 PM CV-2012-001053.00 CIRCUIT COURT OF CV201200105300 MONTGOMERY COUNTY, ALABAMA FLORENCE CAUTHEN, CLERK
Case No.
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
*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
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
State
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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:
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The hearing set for December 6,2012 at 9:30 a.m. is scheduled to last each side.
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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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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
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6,2012 for l5 minutes for
4- Plaintiffs'other 5.
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.
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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CEBTTFTCATE OF SpRVTCE
following:
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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
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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.
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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