IN THE CIRCUIT COURT FOR THE SECOND JUDICIAL CIRCUIT,

LEON COUNTY, FLORIDA, CIVIL DIVISION

ALBERT GORE JR., et al.,

Plaintiffs,

v. CASE NO. 00-2808

KATHERINE HARRIS, SECRETARY

OF THE STATE OF FLORIDA, et al.

Defendants.

__________________________________/

MOTION FOR EMERGENCY HEARING

JUDICIAL WATCH, INC., by counsel, respectfully request an emergency hearing on the Motion for Intervention by Judicial Watch, Inc. being filed herewith. As grounds therefor, Judicial Watch Inc. states the following:

1. Judicial Watch, Inc. is filing herewith a Motion for Intervention by Judicial Watch, Inc. pursuant to Rule 1.230 of the Florida Rules of Civil Procedure.

2. In its motion, Judicial Watch, Inc. asks the Court for permission to intervene in this action in order to continue its on-going review of certain disputed ballots cast in Palm Beach and Miami-Dade Counties during the November 7, 2000 election. Judicial Watch, Inc. began a review of ballots from Palm Beach County yesterday, November 28, 2000, and had been anticipating a review of ballots from Miami-Dade County, when this Court ordered the ballots be transferred to Tallahassee, Florida.

3. Judicial Watch, Inc. respectfully requests that this Court schedule an emergency hearing on its motion to intervene to ensure that Judicial Watch, Inc. is able to continue its timely review of the ballots, which was undertaken in the public interest to inform the American people of the underlying facts, free from the “political spin” of partisans.

4. Judicial Watch, Inc. also respectfully submits that the independent review of the disputed ballots that it and its experts are undertaking will likely be of substantial assistance to the Court in its adjudication of the issues raised by this election contest, and in particular its decision whether to conduct recounts. Judicial Watch, Inc. and its experts are non-partisan.

WHEREFORE, JUDICIAL WATCH, INC. respectfully requests that the Court enter an order permitting it to intervene in this action in order to continue its review of the ballots in question.

JUDICIAL WATCH, INC.

By: _____________________________

Larry Klayman, Esq.

Fla. Bar. No. 246220

501 School Street, S.W.

Suite 725

Washington, DC 20024

(202) 646-5172 (office)

(202) 646-5199 (facsimile)

Attorneys for Judicial Watch, Inc.

CERTIFICATE OF SERVICE

I hereby certify that on November 29, 2000 a true and correct copy of the foregoing MOTION FOR EMERGENCY HEARING was served, via facsimile and first class U.S. mail, postage prepaid, on the following:

Attorneys for Albert Gore Jr. and Joseph Lieberman:

Mitchell W. Berger, Esq.

John D.C. Newton, II, Esq.

BERGER, DAVIS & SINGERMAN

215 South Monroe Street, Suite 705

Tallahassee, FL 32301

Attorneys for George W. Bush and Richard Cheney:

Barry Richard, Esq.

Michael Carvin, Esq.

GREENBERG TRAURIG

101 East College Avenue

Tallahassee, FL 32301

Attorneys for Secretary Katherine Harris and the Florida Elections

Canvassing Board:

Joseph P. Klock, Esq.

Jonathan Sjostrom, Esq.

Donna E. Blanton, Esq.

STEEL HECTOR & DAVIS

215 South Monroe Street, Suite 601

Tallahassee, FL 32301

Deborah Kearney, Esq.

General Counsel

Florida Department of State

400 South Monroe Street, PL 012

Tallahassee, FL 32399

Attorneys for Miami-Dade County Canvassing Board:

Tucker Ronzetti, Esq.

Assistant County Attorney

111 N.W. 1st Street

Miami, FL 33130

Attorneys for the Palm Beach County Canvassing Board:

Andrew McMahon, Esq.

Palm Beach County Attorney’s Office

301 N. Olive Avenue, Suite 601

West Palm Beach, FL 33401-4705

Bruce S. Rogow, Esq.

BRUCE S. ROGOW, P.A.

500 East Broward Blvd., Suite 1930

Ft. Lauderdale, FL 33394

Attorneys for the Nassau County Canvassing Board:

Michael S. Mullin, Esq.

191 Nassau Place

Yulee, FL 32097

Attorneys for the Republican Party:

Ben Ginsburg, Esq.

STATE REPUBLICAN HEADQUARTERS

420 West Jefferson Street

Tallahassee, FL 32301

Attorneys for Matt Butler:

Terrell C. Madigan, Esq.

Harold R. Mardenborough, Jr., Esq.

McFARLAIN, WILEY, CASSEDY & JONES

215 South Monroe Street, Suite 600

Tallahassee, FL 32301

And:

Harold McLean, Senior Attorney

FLORIDA DEPARTMENT OF AGRICULTURAL

& CONSUMER SERVICES

515 Mayo Building

407 South Calhoun Street

Tallahassee, FL 32399

_____________________________

Paul J. Orfanedes