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    When in doubt, put mail this certified to the clerk of the court where your case resides. Then challenge jurisdiction based whether the court has went through proper procedure of the suit/case/account that your are in-fact a corporation, and that you have actually committed a "crime" i.e. corporate delicti or damaged party complaining about you. If there is no one, motion discovery put the claimant under burdon of proof and they will default. After they default, write an affidavit of the facts, and motion to dismiss.

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    When in doubt, put mail this certified to the clerk of the court where your case resides. Then challenge jurisdiction based whether the court has went through proper procedure of the suit/case/account that your are in-fact a corporation, and that you have actually committed a "crime" i.e. corporate delicti or damaged party complaining about you. If there is no one, motion discovery put the claimant under burdon of proof and they will default. After they default, write an affidavit of the facts, and motion to dismiss.

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    When in doubt, put mail this certified to the clerk of the court where your case resides. Then challenge jurisdiction based whether the court has went through proper procedure of the suit/case/account that your are in-fact a corporation, and that you have actually committed a "crime" i.e. corporate delicti or damaged party complaining about you. If there is no one, motion discovery put the claimant under burdon of proof and they will default. After they default, write an affidavit of the facts, and motion to dismiss.

    Copyright:

    © All Rights Reserved
    Download as PDF, TXT or read online from Scribd
    Download as pdf or txt
    2K views2 pages

    Special Appearance

    Uploaded by

    blcksource
    When in doubt, put mail this certified to the clerk of the court where your case resides. Then challenge jurisdiction based whether the court has went through proper procedure of the suit/case/account that your are in-fact a corporation, and that you have actually committed a "crime" i.e. corporate delicti or damaged party complaining about you. If there is no one, motion discovery put the claimant under burdon of proof and they will default. After they default, write an affidavit of the facts, and motion to dismiss.

    Copyright:

    © All Rights Reserved
    Download as PDF, TXT or read online from Scribd
    Download as pdf or txt
    of 2

    UNITED STATES DISTRICT COURT

    EASTERN DISTRICT OF TENNESSEE


    KNOXVILLE DIVISION

    LINCOLN MEMORIAL UNIVERSITY )


    DUNCAN SCHOOL OF LAW, )
    )
    Plaintiff, )
    )
    v. ) Case No. 3:11-CV-608
    ) (Varlan/Shirley)
    THE AMERICAN BAR ASSOCIATION, )
    )
    Defendant. )

    NOTICE OF SPECIAL APPEARANCE

    On behalf of the Defendant, The American Bar Association, a special appearance to note

    the entry of counsel for the Defendant is hereby made, said appearance not waiving any issues

    with regard to any defenses whatsoever, including, but not limited to jurisdiction, service of

    process, failure to exhaust administrative remedies, or any provision of FEDERAL RULES OF CIVIL

    PROCEDURE 8, 9, and 12.

    Respectfully submitted, this 23rd day of December, 2011.

    s/ Howard H. Vogel
    HOWARD H. VOGEL, BPR NO. 1015
    JEFFREY R. THOMPSON, BPR NO. 20310
    P. ALEXANDER VOGEL, BPR NO. 23944
    O’NEIL, PARKER & WILLIAMSON, PLLC
    7610 Gleason Drive, Suite 200
    Knoxville, Tennessee 37919
    (865) 546-7190 (telephone)
    (865) 546-0789 (facsimile)
    hvogel@opw.com
    jthompson@opw.com
    avogel@opw.com

    Attorneys for the Defendant The American Bar


    Association
    CERTIFICATE OF SERVICE

    I hereby certify that on the 23rd Day of December, 2011, I caused to be filed
    electronically a copy of the foregoing pleading. The Court’s electronic filing system will send
    notice of this filing to all parties indicated on the electronic filing receipt. I will cause all other
    parties to be served by regular U.S. mail. Parties may access this filing through the Court’s
    electronic filing system.

    s/ Howard H. Vogel
    HOWARD H. VOGEL, BPR NO. 1015
    JEFFREY R. THOMPSON, BPR NO. 20310
    P. ALEXANDER VOGEL, BPR NO. 23944
    O’NEIL, PARKER & WILLIAMSON, PLLC
    7610 Gleason Drive, Suite 200
    Knoxville, Tennessee 37919
    (865) 546-7190 (telephone)
    (865) 546-0789 (facsimile)
    hvogel@opw.com
    jthompson@opw.com
    avogel@opw.com

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