The following is the Motion to Intervene granted by the Federal Court. If it prevails it will halt the ACLU's ability to help fund itself through attorney fees awarded by the courts and hold them accountable for violating the Tennessee Constitution.

---In the United States District Court for the Middle District of Tennessee : Civil Action No. 3:09CV0446

Keila Franks and Plaintiffs, v. Metropolitan Board of Public Education and Defendants

Counter Complaint to Complaint for Declaratory and Injunctive Relief

Comes Citizen, United States and Tennessee Taxpayer June Griffin in the designation as and hereafter referred to as "Intervener" in the above-styled case submitting her Counter Complaint to plaintiffs' request for relief.

Intervener considers this Complaint as inflammatory of good reason and a frivolous means of gaining tax dollars for legal fees. The very nature of the suit, claiming so-called 'equality' is a mere infraction of the County's God-given Right to follow the moral consciences and law established under the Tenth Article to the Bill of Rights. It further assaults the permanency of the Tennessee Declaration of Rights. This Declaration can never be abrogated.

Section 16. The declaration of rights hereto prefixed is declared to be a part of the Constitution of the state, and shall never be violated on any pretense whatever. And to guard against transgression of the high powers we have delegated, we declare that everything in the bill of rights contained, is excepted out of the general powers of the government, and shall forever remain inviolate.

Article 1, Section 2, which declares "That government being instituted for the common benefit, the doctrine of nonresistance against arbitrary power and oppression is absurd, slavish, and destructive of the good and happiness of mankind."

The use of so-called "Equal access" to introduce unclean and abnormal practices into the minds of youth is certainly a violation of the Tennessee Declaration of Rights, subscribed in the Year of our Lord, indicating the Sovereignty of the God of the Bible, which Rights were exercised by Intervener in the  Campbell v. Sundquist case.

Intervener asserts that United States Code, Title 18, Section 241, Conspiracy against rights,  is applicable to determine the Conspiracy of the special-interests attorneys like the ACLU against the God-fearing persons of Tennessee.

Title 18 Sec. 241. Conspiracy against rights

"If two or more persons conspire to injure, oppress, threaten, or intimidate any inhabitant of any State, Territory, or District in the free exercise or enjoyment of any right or privilege secured to him by the Constitution or laws of the United States or because of his having so exercised the same, …They shall be fined not more than $10,000 or imprisoned not more than ten years, or both…."

And while such lawyers may lay claim to provisions under Title 42 USC 1988 for their legal fees, yet this outrageous provisional law collides clearly with Title 18 Sec. 241, as well as the Tenth Article to the Bill of Rights and the Tennessee Declaration of Rights, upon which elected officials take a sacred oath on the Holy Bible.

Eighty-five of the 95 Tennessee Counties, through their duly-elected County Commissioners concurred in the Ten Commandments Resolution which reads: "We, the below-signed sitting Commission of ____County, in consideration of our great Biblical history of Tennessee, both in our Tennessee Constitution and devotional activities in our heritage, hereby acknowledge the importance of the Ten Commandments of Almighty God and wish to go on record in support of this Magnificent Document and state that we will defend our right to its display to the limit of our ability, against all enemies, domestic, and foreign, public and private.

In the enacting of this Resolution, we hereby petition the God of Heaven to preserve the peace which He has so graciously extended to us by our ancient acknowledgement of the Ten Commandments and beg His continued protection and alleviation of ills which come to those who forget Him and His Law."

The above Resolution was presented to 91 Tennessee Counties - four had already taken their stand for this Right at its inception in 1997 -  and the remaining 10 Counties would have joined in this basic Right had it not been for fear of a lawsuit from the ACLU or other like-minded, special-interest attorneys.

The intimidation exercised by said attorneys like the ACLU through their history of Conspiracy to not only take away basic and ancient liberties, but to force the Taxpayer to fund their 'causes' amounts to a clear violation of Title 18, Section 241.

That the people of Tennessee by this overwhelming support of God's Law wished to exercise their Right is proven clearly. The Law of God and definition of sin which is written in the Ten Commandments is the underpinning of our Rights, given by Almighty God Jehovah. Without such underpinning there would be no building and the people of Tennessee shouted a loud "hallelujah" by their response to the Resolution.  Fear of the ACLU and like-minded, special interest attorneys have set the entire governing bodies of Tennessee and across the United States in fear of being sued need not be entered since it is common knowledge that the Courts are a fearful place for those who stand on the deeds and exercises which have been in place from the beginning of our nation and State.

As well, 42 USC 1988 further collides with 42 USC 1983 which reads as follows: "Every person who, under color of any statute, ordinance regulation, custom or usage, of any State or Territory, subjects, or causes to be subjected, any citizen of the United States, or other person within the jurisdiction thereof to the deprivation of any rights, privileges, or immunities secured by the Constitution and laws, shall be liable to the party injured in an action of law, suit in equity, or other proper proceeding for redress."

The Conspiracy to "injure, oppress, threaten, or intimidate" said inhabitants of this nation are so extensive that, finally,  the American Legion in its 2004 Convention in Nashville, Tennessee, adopted the framework and Resolution for relief to this Conspiracy that resulted in the Public Expression of Religion Act (H.R. 725). This was introduced as a means of avoiding the continued harassment and intimidation of the ACLU and other like-minded, special-interest attorneys.

The booklet, "In the Footsteps of the Founders," a copy of which is included with this Counter-Complaint (Exhibit A), contains this notable injection by Senator Sam Brownbeck and is here inserted for emphasis.

"The Public Expression of Religion Protection Act continued to gain support on Capitol Hill and across America. Americans are tired of special interest groups like the ACLU profiting from their efforts to purge religion from the public square. PERA would bar the recovery of attorney's fees in Establishment Clauses cases, an important step in protecting local cities and towns from frivolous lawsuits. The support of the American Legion has been integral to advancing this important piece of legislation. We must stand together to protect the freedom of religious expression central to our nation's founding."

The extent to which the rights of the God-fearing Taxpayer have been ruined or relegated to the virtual past is further demonstrated by the necessity for relief in the Tennessee Legislature's passage of the "Sovereignty Resolution" Exhibit B is an editorial by Mr. Lee Anderson, Associate Publisher and Editor of the Chattanooga Free Press. Mr. Anderson's editorial demonstrates the frustration which citizens have experienced.  For the Legislature of Tennessee and other States to have to entertain such a demand for liberty from the  demands and extortions via mandate defies expression and underscores the need for redress from such unreasonable demands! Government funding doesn't constitute power to dictate policy. That the plaintiffs would wish to introduce the youth of Knox and Davidson Counties to the shameful conduct displayed over pornographic web sites "pushes the envelope," as the common vernacular states it.

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