AlaFile E-Notice

01-CV-2013-901119.00 Judge: JOSEPH L. BOOHAKER To: WILLIAM H. WEBSTER will@websterhenry.com

NOTICE OF ELECTRONIC FILING

IN THE CIRCUIT COURT OF JEFFERSON COUNTY, ALABAMA STATE BOARD OF HEALTH V. ALL WOMEN'S, INC. ET AL 01-CV-2013-901119.00 The following matter was FILED on 7/22/2013 7:07:17 PM ZF CHARISMATIC EPISCOPAL CHURCH FOR LIFE ZF LIFE LEGAL DEFENSE FOUNDATION ZF OPERATION RESCUE AMICI BRIEF [Filer: WEBSTER WILLIAM HOUSTON] Notice Date: 7/22/2013 7:07:17 PM

ANNE-MARIE ADAMS CIRCUIT COURT CLERK JEFFERSON COUNTY, ALABAMA JEFFERSON COUNTY, ALABAMA BIRMINGHAM, AL 35203 205-325-5355 anne-marie.adams@alacourt.gov

STATE OF ALABAMA
Unified Judicial System

Revised 3/5/08

01-JEFFERSON

District Court

Circuit Court

STATE BOARD OF HEALTH V. ALL WOMEN'S, INC. ET AL

CIVIL MOTION COVER SHEET

Name of Filing Party: ZF - Life Legal Defense Foundation

ELECTRONICALLY FILED 7/22/2013 7:07 PM 01-CV-2013-901119.00 CIRCUIT COURT OF CV201390111900 JEFFERSON COUNTY, ALABAMA ANNE-MARIE ADAMS, CLERK

Case No.

Name, Address, and Telephone No. of Attorney or Party. If Not Represented.

Oral Arguments Requested

WILLIAM H. WEBSTER 418 SCOTT STREET MONTGOMERY, AL 36104

Attorney Bar No.: WEB030

TYPE OF MOTION
Motions Requiring Fee Motions Not Requiring Fee

Default Judgment ($50.00) Joinder in Other Party's Dispositive Motion (i.e. Summary Judgment, Judgment on the Pleadings, or other Dispositive Motion not pursuant to Rule 12(b)) ($50.00) Judgment on the Pleadings ($50.00) Motion to Dismiss, or in the Alternative Summary Judgment($50.00) Renewed Dispositive Motion(Summary Judgment, Judgment on the Pleadings, or other Dispositive Motion not pursuant to Rule 12(b)) ($50.00) Summary Judgment pursuant to Rule 56($50.00) Motion to Intervene ($297.00) Other pursuant to Rule ($50.00)

Add Party Amend Change of Venue/Transfer Compel Consolidation Continue Deposition Designate a Mediator Judgment as a Matter of Law (during Trial) Disburse Funds Extension of Time In Limine Joinder More Definite Statement Motion to Dismiss pursuant to Rule 12(b) New Trial Objection of Exemptions Claimed Pendente Lite Plaintiff's Motion to Dismiss Preliminary Injunction Protective Order Quash Release from Stay of Execution Sanctions Sever Special Practice in Alabama Stay Strike Supplement to Pending Motion Vacate or Modify Withdraw Amici Brief Other pursuant to Rule 56 (Subject to Filing Fee)

*Motion fees are enumerated in 12-19-71(a). Fees pursuant to Local Act are not included. Please contact the Clerk of the Court regarding applicable local fees. Local Court Costs $

Check here if you have filed or are filing contemoraneously with this motion an Affidavit of Substantial Hardship or if you are filing on behalf of an agency or department of the State, county, or municipal government. (Pursuant to 6-5-1 Code of Alabama (1975), governmental entities are exempt from prepayment of filing fees)

Date:

Signature of Attorney or Party:

7/22/2013 6:58:22 PM

/s/ WILLIAM H. WEBSTER

*This Cover Sheet must be completed and submitted to the Clerk of Court upon the filing of any motion. Each motion should contain a separate Cover Sheet. **Motions titled 'Motion to Dismiss' that are not pursuant to Rule 12(b) and are in fact Motions for Summary Judgments are subject to filing fee.

ELECTRONICALLY FILED 7/22/2013 7:07 PM 01-CV-2013-901119.00 CIRCUIT COURT OF JEFFERSON COUNTY, ALABAMA ANNE-MARIE ADAMS, CLERK

ELECTRONICALLY FILED 7/22/2013 7:07 PM 01-CV-2013-901119.00 CIRCUIT COURT OF JEFFERSON COUNTY, ALABAMA ANNE-MARIE ADAMS, CLERK

ELECTRONICALLY FILED 7/22/2013 7:07 PM 01-CV-2013-901119.00 CIRCUIT COURT OF JEFFERSON COUNTY, ALABAMA ANNE-MARIE ADAMS, CLERK

ELECTRONICALLY FILED 7/22/2013 7:07 PM 01-CV-2013-901119.00 CIRCUIT COURT OF JEFFERSON COUNTY, ALABAMA ANNE-MARIE ADAMS, CLERK

ELECTRONICALLY FILED 7/22/2013 7:07 PM 01-CV-2013-901119.00 CIRCUIT COURT OF JEFFERSON COUNTY, ALABAMA ANNE-MARIE ADAMS, CLERK

IN THE CIRCUIT COURT OF JEFFERSON COUNTY, ALABAMA

STATE BOARD OF HEALTH, Plaintiff, vs. ALL WOMEN'S INC., d/b/a NEW WOMAN ALL WOMEN HEALTH CARE, DIPAT, L.L.C., DIANE W. DERZIS, PATRICK H. SMITH, and BRUCE E. NORMAN, M.D., Defendants.

) Case No.: 01-CV -2013-901119 JB ) ) DECLARATION OF MARY ANN VANN IN ) SUPPORT OF BRIEF OF AMICI CURIAE

) IN SUPPORT OF PLAINTIFF'S REQUEST ) FOR PERMANENT INJUNCTION ) ) )

______________________________)
DECLARATION OF MARY ANNVANN

I, Mary Ann Vann, hereby declare: 1. I am a citizen of the state of Alabama. 2. I am not a party to the above-captioned matter. 3. I am actively involved in the pro-life community in Birmingham, AL. 4. As part of my pro-life work, I gather public information about conduct and practices of abortion providers in the state of Alabama. My primary purpose in doing such is to inform and educate the public and lawmakers about the dangerous actions of abortion providers. 5. I personally gathered the information and materials included in Exhibits 1, 2, and 3 attached hereto.

6. I regularly stand outside the New Woman All Women abortion facility (hereafter "Facility"), located at 1001 I i
11

Street South Birmingham, AL 35205 and handout

life saving literature to the women entering the facility. 7. On January 21, 2012, I observed two women being taken away by ambulance from the Facility. I took photographs of the emergency vehicles and the women as the emergency personnel extricated them from the Facility. The photographs are attached hereto as Exhibits 1 and 2. 8. I am familiar with the person who owns and operates the Facility. I have seen her picture and seen her in person and know this person to be Diane Derzis. 9. On July 2, 2013, I photographed Diane Derzis entering the Facility. The photograph is attached hereto as Exhibit 3.
VERIFICATION

I know the contents of this declaration and declare under penalty of perjury under the laws of the United States of America that the foregoing is tfll and correct.

Dated: (

ir..( ,<, :2c 1 3 . 7

.:..J ..) I .t t~ A..,_

1/

Mary Ann Vann

ELECTRONICALLY FILED 7/22/2013 7:07 PM 01-CV-2013-901119.00 CIRCUIT COURT OF JEFFERSON COUNTY, ALABAMA ANNE-MARIE ADAMS, CLERK

ELECTRONICALLY FILED 7/22/2013 7:07 PM 01-CV-2013-901119.00 CIRCUIT COURT OF JEFFERSON COUNTY, ALABAMA ANNE-MARIE ADAMS, CLERK

ELECTRONICALLY FILED 7/22/2013 7:07 PM 01-CV-2013-901119.00 CIRCUIT COURT OF JEFFERSON COUNTY, ALABAMA ANNE-MARIE ADAMS, CLERK

ELECTRONICALLY FILED 7/22/2013 7:07 PM 01-CV-2013-901119.00 CIRCUIT COURT OF JEFFERSON COUNTY, ALABAMA ANNE-MARIE ADAMS, CLERK

ELECTRONICALLY FILED 7/22/2013 7:07 PM 01-CV-2013-901119.00 CIRCUIT COURT OF JEFFERSON COUNTY, ALABAMA ANNE-MARIE ADAMS, CLERK

Exhibit 1 Audio to be emailed separately.