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UNITED STATES COURT OF APPEALS FOR THE EIGHTH CIRCUIT |
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Case No. 03-2824
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John S. La Tour, CPA,
Appellant,
vs.
City of Fayetteville, Arkansas,
W. Brant Warrick, and
Perry Michael McKimmey
Appellees.
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APPELLANT’S MOTION FOR ORAL ARGUMENTS
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APPEAL FROM THE
UNITED STATES DISTRICT COURT
FOR THE WESTERN DISTRICT OF ARKANSAS
Case Number 02-5001
John S. La Tour, CPA
112 West Center Street
Suite 560
Fayetteville, AR 72701
(479) 443-7878 Appellant Appearing Pro Se
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John S. La Tour, the Pro Se Appellant, comes now for the purpose of making a motion in support of oral arguments before this Court. I believe I am prepared to make this presentation before the Court and in support of this motion, I note the following:
1. I am a practicing Certified Public Accountant and have been in the profession for the last 22 years.
2. I hold an MBA from the University of Arkansas.
3. I have completed over half the course work in a course of legal study that will qualify me to sit for the California bar exam.
4. My staff and I have researched applicable jurisprudence in the areas of content regulation, equal protection, immunity, and punitive damages under U.S.C. §1983. Our research has prepared me to engage in meaningful debate on these issues as born out in the briefs already filed in this case.
5. The determination of the issues raised by this case will have a most significant impact on the protection of free speech and equal protection in the Eighth Circuit and, indeed, around the country.
6. The authorities indicate that Pro Se litigants have, in the past, been allowed to present oral arguments at the Circuit Court of Appeals level. Rhodes v. Meyer, 334 F.2d 709 (8th Cir.); Ginger v. Cohn, 426 F.2d 1385 (6th Cir.); Keyse v. California Texas Oil Corp., 590 F.2d 45 at 48 (2nd Cir.)
7. When a citizen is prosecuted and convicted of criminal activity for engaging in expressive activity, surely some line is crossed. Oral arguments are necessary to ensure the establishment of bright-line definitions with regard to a public official’s ability to shield himself from civil liability when he crosses the line of constitutional protection.
For all of these reasons, I respectfully move that oral arguments be allowed in this case. Further, I repeat my request for thirty minutes to present my arguments and answer any questions this Court may ask.
Respectfully Submitted
JOHN S. LA TOUR
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John S. La Tour, CPA
112 Center Street, Suite 560
Fayetteville, AR 72701
(479) 443-7878
Appellant Pro Se
I, John S. La Tour, do hereby certify that on the ____ day of ____________, _______ I caused a true and correct photocopy of the within and foregoing document, with exhibits, to be served on those persons shown below via U.S. First Class Mail, to wit:
Mr. Woody Bassett
Bassett Law Firm
P.O. Box 3618
Fayetteville, AR 72702
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John S. La Tour, CPA