scoal - mcinnish|goode v chapman - rille amicus brief

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  • 8/22/2019 SCOAL - McInnish|Goode v Chapman - Rille Amicus Brief

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    M tS etttireme

    Court #f!9Iabattm

    CASE NO. 1120465 rH U G H McINNISH, et al..

    Appellants,

    V.

    BE T H CH A P MA N , in her capacity as Secretary ofState,

    Appellee.

    ON APPEAL FROM THE CIRCUIT COURT OF

    MONTGOMERY COUNTY, A L A B A M A

    C V 2012-1053

    MOTION FORLEAVE TO FILE

    BRIEF OF AMICUS CURIAE

    In support of the Plaintiffs/Appellants, the Constitution of Alabama, the

    Constitution of the United States ofAmerica, the Rule of Law, the Citizens and

    Residents of the State of Alabama, the American People, and Priceless LIBERTY.

    By Scott RiWe, Amicus curiae

    Natural-bom American Citizen

    May 20, 2013

    COVER SHEET

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    CASE NO. 1120465

    H U G H McINNISH, et al..

    Appellants,

    V.

    BE T H CH A P MA N , in hercapacity as Secretary ofState,

    Appellee.

    ON APPEAL FROM THE CIRCUIT COURT OF

    MONTGOMERY COUNTY, A L A B A M A

    C V 2012-1053

    MOTION FORLEAVE TO FILE

    BRIEF OF AMICUS CURIAE

    In support of the Plaintiffs/Appellants, the Constitution of Alabama, the

    Constitution of the United States ofAmerica, the Rule of Law, the Citizens and

    Residents of the State of Alabama, the American People, and Priceless LIBERTY.

    By Scott Rille, Amicus curiae

    Natural-bom American Citizen

    May 20, 2013

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    MOTION FORLEAVE TO FILE BRIEF OF AMICUS CUIUAE

    Movant, Scott Rille, in reference toRule 1.190, Florida Rules ofCivil Procedure

    and pursuant to Alabama Rules ofAppellate Procedure, hereby moves this Court to

    grant leave to Scott Rille to file his Brief ofAmicus Curiae and states:

    1. Rule 1.190, "Leave ofcourt shall be given freely when justice so requires."

    Movant sincerely believes Justice requires this Honorable Court grant his

    motion to allow him to present a crucial Constitutional question of law, to assist

    the Court to come to a just decision in this matterin the interest ofJustice, and if

    this Court fails to grant Movant's motion Justice will not be served and the

    citizens and residents of the State of Alabama and the American people will suffer

    monumental loss thereby.

    2. THE PARTICULARISSUE TO BE ADDRESSED: Constitutional Question of

    Law. Where does the Constitution of the United States specifically require the

    President of the United States must be born in the United States ofAmerica?

    3. HOW M O V A N T C A N ASSIST THE COURT IN THE DISPOSITION

    OF THE CASE: Movant sincerely believes the Court's willingness to

    entertain and to rendera Constitutionally defensible answerto his Constitutional

    Question ofLaw is absolutely crucial and foundational to reaching a

    Constitutionally defensible and just ruling in this weighty matterbefore the Court.

    In reference to Rules ofthe Supreme Court ofthe United States, Rule 37(1),

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    Movant sincerely believes that he is bringing "to the attention of the Court

    relevant matternot already brought to its attention by the parties and should be of

    considerable help to the Court"

    4. Amicus curiae believes the Court created the Rules of Appellate Procedure and

    that this Honorable Court possesses the wisdom, discretionary power and

    authority to set aside any, orall, ofthe Rules, as necessary, in order to entertain

    this weighty matteraffecting the safety, well-being and LIB ERT Y of every

    Alabama citizen and resident, and of every American, in support of the

    Constitution ofAlabama, the Constitution of the United States ofAmerica, the

    Rule of Law, and in the interest ofJustice. Amicus curiae believes this Honorable

    Court should have a compelling interest in settling this Constitutional Question of

    Law for all time.

    WHEREFORE, Movant, Scott Rille, respectfully requests that this Court grant

    his Motion.

    Respectfiilly submitted this 20th day of May, 2013.

    Scott Rille, Amicus curiae

    139 East Tulare Avenue, 325

    Tulare, C A 93274

    559-688-0357

    [email protected]

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    mailto:[email protected]:[email protected]
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    CERTIFICATE OF SERVICE

    I H E RE BY CERTIFY that a true copy of the following document, MOTION FOR

    L E A V E TO FILE BRIEF OF AMICUS CURIAE, has been furnished by U.S. mail

    this 20* day of May, 2013to

    the following parties:

    H U G H McINNISH, et al. through theirattorney:

    Larry Klayman, Esq.

    Klayman Law Firm

    2020 Pennsylvania Avenue, NW

    Suite 800

    Washington, D.C. 20006

    Counselfor Appellants

    BE T H C H A P M A N , Alabama Secretary ofState through herattorneys:

    Honorable Attorney General ofAlabama LutherStrange

    and the Honorable Assistant Attorney General Margaret L. Fleming

    Office of the Attorney General ofAlabama

    501 Washington Street

    Montgomery, Alabama 36130

    CounselforAppellee

    Dated: May 20, 2013

    Is/Scott Rille

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