SUPERIOR COURT OF GEORGIA FOR THE COUNTY OF FULTON DAVID P. WELDEN Petitioner v.

BARACK OBAMA Respondent : : : : : : : : : : : :

PETITIONERS MOTION TO ADMIT ATTORNEY VAN R. IRION PRO HAC VICE

David Welden respectfully introduces attorney Van R. Irion and submits this motion for admission pro hac vice. Grounds for this motion, as set forth below are that Mr. Irion fulfills the requirements set forth in Rule 4.4, is qualified to represent the Petitioner, represented the Petitioner in the OSAH proceeding to which this petition requests review, and will facilitate efficient adjudication of the instant matter.

in the State of Tennessee. He was admitted to practice law in Tennessee in October 2005 and has

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been practicing continuously since. He is a resident of Monroe County Tennessee and maintains an office at 9040 Executive Park Drive, Suite 200, Knoxville, Tennessee, 37923. His phone number is (423) 208-9953. His e-mail address is van@libertylegalfoundation.org.

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Attorney Irion is licensed to practice law and is a member of in good standing of the bar

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Pursuant to the Uniform Rules for the Superior Courts of Georgia, Rule 4.4, Petitioner

Rule 4.4 Qualifications

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Superior Court Docket Number: OSAH Docket Number: OSAH-SECSTATE-CE1215137-60-MALIHI

Mr. Irion agrees to behave in accordance with the Georgia standards of professional conduct and the duties imposed upon attorneys by O.C.G.A. 15-19-4.

Mr. Irion is also currently admitted to practice before the United States Supreme Court, the U.S. Court of Appeals for the Sixth Circuit, the U.S. District Court for the Eastern District of Tennessee, and the U.S. Patent and Trademark Office. He was admitted to practice before the

U.S. Supreme Court April 30, 2009. The Supreme Court can be reached at (202) 479-3011, One 1st Street N.E., Washington, DC 20543. He was admitted to practice before the U.S. District

Court for the Eastern District of Tennessee on April 20, 2007. The Eastern District of Tennessee can be reached at (865) 545-4228, 800 Market Street, Suite 130, Knoxville, TN 37902. He was admitted to practice before the Sixth Circuit on July 28, 2006. The Sixth Circuit can be reached at (513) 564-7000, 540 Potter Stewart U.S. Courthouse, 100 E. Fifth Street, Cincinnati, Ohio 45202-3988. He was admitted to practice before the U.S. Patent and Trademark Office on December 10, 2007. The USPTO can be reached at (571) 272-1000, Alexandria, 401 Dulany Street, VA 22313. He has also appeared pro hac vice before the U.S. District Court for the Eastern District of Virginia, the U.S. District Court for the District of Arizona, U.S. District Court for the Northern District of Texas, the U.S. Bankruptcy Court for the Middle District of Tennessee, and the Georgia of State Administrative Hearings. No court has denied Mr. Irion admission pro hac vice nor revoked admission. Mr. Irion has never been sanctioned, reprimanded, or held in contempt by any court or bar. No authority has ever brought disciplinary

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action against Mr. Irion. Attorney Mark Hatfield has agreed to sponsor Mr. Irions pro hac vice application. Mr.

Hatfield is currently an active member in good standing of the bar of the State of Georgia. His

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bar number is 337509. Mr. Hatfields office address is 201 Albany Avenue, Waycross, GA 31501-3504. Mr. Hatfields phone number is (912) 283-3820.

Mr. Irion previously applied for pro hac vice admission with the Georgia Office of

Administrative Hearings on December 19, 2011 in the action Welden v. Obama, docket number OSAH-SECSTATE-CE-1215137-60-MALIHI. Mr. Irions application was granted on December 20, 2011. The Georgia Office of Administrative Hearings can be reached at (404) 657-2800, and is located at 230 Peachtree Street NW, Suite 850, Atlanta, GA 30303.

Pursuant to 4.4(D)(3) Mr. Irion hereby certifies that he will not charge the Petitioner an attorney fee and that Mr. Irion is associated with a non-profit legal services organization.

Mr. Irion is well qualified to represent the Petitioner in the instant matter because Mr.

Irion has continuously litigated Constitutional matters in numerous Federal and state courts since January 2006, and because Mr. Irion represented the Petitioner in the matter under review in the Georgia Office of State Administrative Hearings. Mr. Irion has dedicated several thousand hours

Congressional District seat in 2010, and therefore has intimate knowledge of the election process and political partys interaction with state officials. Mr. Irion is the Lead Counsel for Liberty Legal Foundation, a non-profit organization dedicated to restoring original meaning to U.S. Constitutional precedent. Liberty Legal Foundation has over 32,000 members in all 50 states and overseas. Liberty Legal Foundation is

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Federal Court.

currently litigating challenges similar to the instant matter in Tennessee State Court and Arizona

the instant matter. The Petitioner currently resides at 5530 Wright Road, Powder Springs, GA,

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Due to Mr. Irions qualifications, the Petitioner desires to have Mr. Irion represent him in

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to Constitutional litigation. Also, Mr. Irion was a Republican candidate for Tennessees 3 rd

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30127. The Petitioners phone number is 770.943.2025. The Petitioners e-mail address is dpwelden@gmail.com.

For the reasons set forth herein, the Petitioner respectfully requests that this Court grant his motion to admit attorney Van R. Irion pro hac vice.

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CERTIFICATE OF SERVICE I certify that I have served the opposing party in this matter with a copy of Petitioners Motion to Admit Attorney Van R. Irion Pro Hac Vice by sending a copy via first class U.S. mail to attorney Michael Jablonski at 260 Brighton Rd. NE, Atlanta, GA 30309. A copy was also sent via e-mail addressed to: Michael Jablonski Michael.jablonski@comcast.net This the 14th day of February, 2012.

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Conclusion _________________________ Van R. Irion Liberty Legal Foundation 9040 Executive Park Dr., Ste. 200 Knoxville, TN 37923 (423) 208-9953 van@libertylegalfoundation.org Attorney for Petitioner _________________________ Van R. Irion Liberty Legal Foundation 9040 Executive Park Dr., Ste. 200 Knoxville, TN 37923 (423) 208-9953 van@libertylegalfoundation.org Attorney for Petitioner