OFFICE OF STATE ADMINISTRATIVE HEARINGS STATE OF GEORGIA DAVID P. WELDEN Plaintiff v.

BARACK OBAMA Defendant

PLAINTIFF'S MOTION TO ADMIT ATTORNEY VAN R. IRION PRO HAC VICE

Pursuant to this Court's Rule 616-1-2-.34 Plaintiff 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 616-1-2.34, is qualified to represent the Plaintiff, and will facilitate efficient adjudication of the instant matter.

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

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Rule 616 1 2 .34 Qualifications

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Docket Number: OSAH-SECSTATE-CE1215137-60-MALIHI 1

Kevin We stray. LeaAssistant '

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 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, and the U.S. Bankruptcy Court for the Middle District of Tennessee. 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.

Mr. Irion is well qualified to represent the Plaintiff in the instant matter because Mr. Irion has continuously litigated Constitutional matters in numerous Federal and state courts since

January 2006. Mr. Irion has dedicated several thousand hours to such litigation. Also, Mr. Irion was a Republican candidate for Tennessee 's 3 rd Congressional District seat in 2010, and therefore has intimate knowledge of the election process and political party's 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 36,000 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

Due to his qualifications the Plaintiff desires to have Mr. Irion represent him in the

instant matter. The Plaintiff currently resides at 5530 Wright Road, Powder Springs, GA, 30127.

The Plaintiffs phone number is 770.943.2025. The Plaintiffs e-mail address is

dpwelden@gmail.com .

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

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CERTIFICATE OF SERVICE Pursuant to the Order entered in this matter regarding electronic service, I certify that I have served the opposing party in this matter with a copy of Plaintiff's Motion to Admit Attorney Van R. Irion Pro Hac Vice by sending a copy via e-mail addressed to: Michael Jablonski Michael. jablonski@comcast.net This the 19th day of December, 2011.

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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.com

Attorney for Plaintiff

Van R. Irion Liberty Legal Foundation 9040 Executive Park Dr., Ste. 200 Knoxville, TN 37923 (423) 208-9953
van@libertylegalfoundation.com

Attorney for Plaintiff