US District Court
District of South Carolina
United States of America } Plaintiff } No. 05cv2734-hmh } Vs. } Special Appearance Robert Clarkson, individually } and dba The Patriot Network } Defendants }
Defendant Robert Clarkson dba The Patriot Network appears specially to object to the jurisdiction of the Court, based on the following reasons:
1. The United States filed its Complaint and Injunction Request on September 21, 2005 and served Defendant Robert Clarkson individually, on October 17. Robert Clarkson dba The Patriot Network was not served as the US Marshall only gave Clarkson one copy of said complaint.
2. Clarkson will accept service by mail for the Patriot Network. However, he is planning to resign his position as President of said political action group and to help elect a new president. The new head of said association then would need to be served personally.
3. This objection to jurisdiction will apply to all further pleadings filed by The Patriot Network and no filing shall be deemed to waive this special appearance.
4. The Network is a political association, not a business or “dba”. Unfortunately, it has never made a profit and for the last 26 years, no effort to make a profit existed. Both defendants object very strongly to the term “dba” or any label implying this purely political group is a business or operated for profit.
Certificate of Service : I do hereby certify that on this date I mailed properly a copy of this pleading to opposing counsel by regular U.S. mail.
___________________________ Date: 19 Nov 05
Robert Clarkson, dba The Patriot Network
515 Concord Ave, Anderson SC 29621