Gohmert et al v. Pence

Filing 9

NOTICE by Timothy P Dowling (Dowling, Timothy)

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Case 6:20-cv-00660-JDK Document 9 Filed 12/29/20 Page 1 of 3 PageID #: 99 IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF TEXAS TYLER DIVISION Louie Gohmert, Tyler Bowyer, Nancy Cottle, Jake Hoffman, Anthony Kern, James R. Lamon, James Moorhead, Robert Montgomery, Loraine Pellegrino, Greg Safsten, Kelli Ward and Michael Ward Plaintiffs v. Civil Action No. 6:20-cv-00660 (Election Matter) The Honorable Michael R. Pence, Vice President of the United States, in his official capacity, Defendant Notice of Inability of Timothy P. Dowling to Attend December 31, 2020 hearing in person To the Honorable Jeremy D. Kernodle, United States District Court Judge: 1 Case 6:20-cv-00660-JDK Document 9 Filed 12/29/20 Page 2 of 3 PageID #: 100 Timothy P. Dowling (“Dowling”) hereby files notice of his inability to attend a hearing in person in this case on December 31, 2020, and regarding the same would show the Court the matters set forth below. 1. Plaintiffs filed a motion today (Document No. 7; the “Motion”) requesting that an expedited hearing be held in this case on the Motion in the afternoon on December 31, 2020 at a time to be determined. Dowling opposes the Motion and the relief sought by Plaintiffs in this case. 2. The last sentence of the proposed order submitted by Plaintiffs today regarding the Motion states “Counsel who cannot attend in person shall advise the Court in writing no later than ______ to make arrangements to attend by telephone or video conferencing.” By this pleading the Court and all parties are hereby advised that Dowling cannot feasibly attend a hearing on December 31, 2020 in person in Tyler, Texas, and that he will attend any hearing on that date in this case either by telephone or video conferencing as permitted by the Court. Dowling intends to file a motion to intervene in this case imminently. Respectfully submitted, 2 Case 6:20-cv-00660-JDK Document 9 Filed 12/29/20 Page 3 of 3 PageID #: 101 /s/ Timothy P. Dowling Pro se Texas State Bar No. 06083900 8017 Villefranche Dr. Corpus Christi, TX 78414 (361) 960-3135 Relampago@aol.com Certificate of service The undersigned hereby certifies that counsel for Plaintiffs were served by filing this motion with the Clerk of this Court, and such counsel were also served by email service on December 29, 2020 as follows: lsessions@sessionslaw.net William Sessions howard@kleinhendler.com Howard Kleinhendler ljoseph@larryjoseph.com Lawrence Joseph hallerjuilia@outlook.com Julia Haller brandoncjohnson6@aol.com Brandon Johnson /s/ Timothy P. Dowling 3

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