Posted on 10/10/2008 1:29:21 AM PDT by Lancey Howard
Attached is Philip J. Berg's Opposition to Defendants, the DNC and Obama's Motion for Protective Order Staying Discovery pending Decision on their Motion to Dismiss. If the Protective Order were granted, discovery could not occur until the standing issue has been resolved and only if it is in favor of the plaintiff.
Following is an excerpt from the response:
PLAINTIFF’S RESPONSE IN OPPOSITION TO DEFENDANTS BARACK H. OBAMA AND THE DEMOCRATIC NATIONAL COMMITTEE’S MOTION FOR A PROTECTIVE ORDER STAYING DISCOVERY PENDING DECISION ON DISPOSITVE MOTION Plaintiff, Philip J. Berg, Esquire [hereinafter “Plaintiff”] files the within Response in Opposition to Defendants, Barack H. Obama [hereinafter “Obama”] and the Democratic National Committee [hereinafter “DNC’] Motion for Protective Order Staying Discovery Pending Decision on Defendants Dispositive Motion on the following grounds: 1. Defendants’ pending Motion to Dismiss does not entitle them to a Protective Order under Federal Rule of Civil Procedure 26(c) [hereinafter F.R.C.P. 26(c]; 2. Defendants have failed to show “good cause” and are therefore not entitled to a protective order under F.R.C.P. 26(c); 3. Defendants have not pointed to any legitimate privacy concerns. Defendants have failed to point out any substantiated specific examples demonstrating that disclosure will cause a defined and serious injury;
4. Plaintiff does not seek access to the requested information for any improper purpose; 5. Defendants have not shown any risk that particularly serious embarrassment will result from the requested documents; 6. The requested information is extremely important for public safety; and “Good Cause” requires a particular need for the protection sought; 7. The sharing of information will promote fairness and efficiency so as not to delay this action; 8. Barack Obama, as U.S. Senator of Illinois and the Democratic Nominee for President of the United States, is a public person, and his citizenship status is a matter of significant public concern and is subject to legitimate public scrutiny. The Democratic National Committee is a public entity and is also subject to public scrutiny; and 9. The public interest in access to the requested information under the Freedom of Information Act 5 U.S.C. § 552 is a strong factor in favor of not granting a protective order which would prevent disclosure of such information.
Since his mother was an American citizen, doesn’t that make him one automatically, no matter where he was born?
seeing how the court hasnt ruled on the Motion to Dismiss yet, and now another motion has been filed, i am pessimistic that the COLB issues will be resolved prior to November 4.
It would take an extraordinary chain of events for that to happen.
Could it be this is a distraction? It puts the question of eligibility out there, and no matter what the court decides, it won’t matter because the COLB is in someone’s hands.
NO. He has to be a "NATURAL BORN," which he is NOT, and can NEVER be!!!
INDEED.
AMEN! AMEN!
They will become ashes at the feet of all who Love God.
—in His time.
THANKS THANKS.
The proven altered doc using his Sister’s I think.
here’s my question...WHO exactly vets these candidates? Is it the Secret Service? DOJ? FBI?
= = =
The GPTB
[Globalist Powers That Be].
And their political parties . . . sort of . . . see 2 lines above.
We shall see.
I don’t see a lot of likelihood that it’s a wonderful risk for Obumma.
True.
I was speaking of the worst possible time from THEIR, THE TRAITOR’S PERSPECTIVE.
There are so many things this phony one has and doesn't have, there is not enough space here to go into.
What’s the definition of ‘natural born’?
I’m wondering about this because our local Dallas conservative talk show host, Mark Davis, has totally poo-pooed this issue because B.O.’s mother was a citizen.
He’s already told us he’s a citizen of the world. To me, that’s enough proof of divided loyalties.
Calling Dan Rather...
You CANNOT have allegiance to more than ONE Master, in this case the United States of America. If you have or have HAD dual citizenship, which NoBama Muhammed has had, possible born in Kenya fathered by a Kenyan, and definitely being adopted by Lolo Soetoro he has been or is still an Indonesian citizen, all are grounds for disqualification according to our Constitution back to the framers!!!
The name of the doctor who delivered me is on my BC. Is it ever on HI’s?
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