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 7:56:46 PM C002 GOODE VIRGIN H JR C001 MCINNISH HUGH MOTION FOR JOINDER

[Filer: JOHNSON LAWRENCE DEAN] Notice Date: 11/28/2012 7:56:46 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 7:56 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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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

Other pursuant to Rule

Date:

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)

11/28/2012 7:52:26 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

(Subject to Filing Fee)

Signature of Attorney or Party:

/s/ LAWRENCE DEAN JOHNSON

IN THE CIRCUIT COURT OF MONTGOMERY COUNTY, ALABAMA

ELECTRONICALLY FILED 11/28/2012 7:56 PM CV-2012-001053.00 CIRCUIT COURT OF MONTGOMERY COUNTY, ALABAMA FLORENCE CAUTHEN, CLERK

HUGH MCINNISH, et. al,

Plaintiffs,
VS.

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Defendant.

PLAINTIFFS' CONSENT TO NOTI.CE OF JOINDER

Plaintiffs Hugh Mclnnish and Virgil H. Goode, Jr. by and through their undersigned counsel,
hereby consent to the joinder of proposed intervenor Alabama Democratic Party on the condition that

in the Defendant Secretary of State's Renewed Motion to Dismiss no delay should result.

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Dated: November 28 " 2012

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their late intervention creates no delay in these proceedings. Since the Alabama Democratic Party joins

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Respectfully submitted,
/s/ Larrv Klavman Larry Klayman, Esq. Klayman Law Firm 2020 PennsylvaniaAve. NW Suite 800 Washington, DC 20006 Tel: (310) s9s-0800 Email: leklayman@gmail.com Pro Hac Vice

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BETH CHAPMAN, Secretary of

State

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Civil Action No.: CV-2012-001053

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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 : j ohnson_dean@bellsouth.net

I HEREBY CERIIFY that on the 28th day of November, 2012,I filed the foregoing with the Clerk of Court using the Alafile system, which will send notification of such filing to the following:
Hon. Luther Strange Margaret L. Fleming James W. Davis Laura E. Howell Attomey General of Alabama 501 Washington Street Montgomery Alabama 36 I 30

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/s/ L. Dean Johnson Of Counsel

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CERTTFTCATE

Or SERyIqp

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