Gohmert et al v. Pence

Filing 9

NOTICE by Timothy P Dowling (Dowling, Timothy)

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:

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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,

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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
[phone]
[e-mail]

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:
[e-mail]
William Sessions
[e-mail]
Howard Kleinhendler
[e-mail]
Lawrence Joseph
[e-mail]
Julia Haller
[e-mail]
Brandon Johnson
/s/ Timothy P. Dowling
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