I'm not an attorney, but IIRC under the Federal Rules of Evidence no witness is needed to introduce a “self-authenticating document” such as a United States state vital record that is properly certified with a seal and signed.
Such a certified record is presumed to be prima facie (on its face) valid...but can be contested if sufficient cause is presented to the judge.
See:
http://www.law.cornell.edu/rules/fre/rule_902
“Rule 902. Evidence That Is Self-Authenticating
“The following items of evidence are self-authenticating; they require no extrinsic evidence of authenticity in order to be admitted:
“(1) Domestic Public Documents That Are Sealed and Signed. A document that bears:
“(A) a seal purporting to be that of the United States; any state, district, commonwealth, territory, or insular possession of the United States; the former Panama Canal Zone; the Trust Territory of the Pacific Islands; a political subdivision of any of these entities; or a department, agency, or officer of any entity named above; and
“(B) a signature purporting to be an execution or attestation.”
Orly keeps trying to do this but doesn't seem to know how. At times she seems to think she is in criminal court where the defendant is entitled to a much higher threshold of proof than preponderance of the evidence that you have in a civil proceeding.
“... but can be contested if sufficient cause is presented to the judge.”
In Georgia administrative hearings, the rules of evidence as applied in the trial of non-jury civil actions shall be followed, subject to special statutory rules or agency rules as authorized by law.
Judges in a non-jury trial may review all proffered materials while excluding from consideration any evidence that they determine to be inadmissible under the law.
In a non-jury civil suit, a jury won’t be prejudiced by evidence entered on a provisional basis. Consequently, Orly can make her case with a copy of the long form posted on the WH website and articulate her argument there are anomalies between the long form, signature and attestation of witnesses, and the COLB, attestation of witnesses withdrawn. And the PDF has too many layers.