Here is the main part of Philip J Berg’s filing today, Tuesday, October 21, 2008. The complete filing will be available later:
“UNITED STATES DISTRICT COURT
FOR THE EASTERN DISTRICT OF PENNSYLVANIA
PHILIP J. BERG, ESQUIRE, ::
Plaintiff
:
vs.
: CIVIL ACTION NO. 2:08-cv-04083-
RBS
:
BARACK HUSSEIN OBAMA, a/k/a :
BARRY SOETORO, a/k/a :
BARRY OBAMA, a/k/a : JURY TRIAL DEMANDED
BARACK DUNHAM, a/k/a :
BARRY DUNHAM, THE :
DEMOCRATIC NATIONAL :
COMMITTEE, THE FEDERAL :
ELECTION COMMISSION AND :
DOES 1-50 INCLUSIVE, :
Defendants
:
PLAINTIFF’S MOTION REQUESTING AN IMMEDIATE ORDER DEEMING
PLAINTIFF’S REQUEST FOR ADMISSIONS TO DEFENDANTS, BARACK
HUSSEIN OBAMA and THE DEMOCRATIC NATIONAL COMMITTEE,
ADMITTED
NOW COMES
the Plaintiff, Philip J. Berg, Esquire [hereinafter “Plaintiff”] and
respectfully requests this Honorable Court to grant Plaintiff’s Motion and issue an
immediate Order deeming Plaintiff’s Requests for Admissions, served upon Defendants,
Barack Hussein Obama [hereinafter “Obama”] and The Democratic National Committee
[hereinafter “DNC”] on September 15, 2008 “Admitted” on the following Grounds:
1. Plaintiff filed this action on August 21, 2008 requesting Declaratory and
Injunctive Relief, as Obama does not meet the qualifications or eligibility to run
for and/or serve as the President of the United States.
2. On or about September 9, 2008, Plaintiff filed a Motion for Expedited
Discovery, Extensive Discovery and Depositions of Obama and Howard Dean,
Chairman of the DNC and the appointment of a Special Master. Defendants
never Responded to or Opposed said Motion. This Motion is still pending.
3. On September 15, 2008, Defendants, Obama and the DNC, were served
with discovery by Plaintiff for Request for Admissions and Request for
Production of Documents. Defendants’ responses were due within thirty [30]
days.
4. Defendants, Obama and the DNC did not Answer the Complaint, failed to
turn over proof of Obama’s citizenship status and instead filed a Motion to
Dismiss on September 24, 2008. Defendants claimed Plaintiff did not have
standing to bring this action and failed to state a claim which relief could be
granted.
5. This Honorable Court requested Plaintiff to file any Responses in
Opposition to Defendants Motion within five [5] days, that being on or before
September 29, 2008 and Plaintiff complied by filing a Response in Opposition to
Defendants Motion to Dismiss.
6. On or about Monday, October 6, 2008, Defendants Obama and the DNC’s
Attorney called Plaintiff requesting Plaintiff to agree to Staying discovery
pending a decision on their Motion to Dismiss. Plaintiff declined as Obama’s
citizenship status is of National security as he is running for President of the
United States.
7. In the afternoon of October 6, 2008, Defendants, Obama and DNC, filed a
Motion for Protective Order staying all discovery pending the Court’s decision on
their Motion to Dismiss. In their Motion Defendants acknowledged receipt of the
Requests for Admissions.
8. On or about October 9, 2008, Plaintiff filed his Response in Opposition to
Defendants Motion for Protective Order.
9. Defendants have failed to timely Answer Plaintiff’s Requests for
Admissions, which were served on September 15, 2008 and Defendants Answers
were due thirty [30] days thereafter. Therefore, these matters are automatically
deemed admitted in accordance with Federal Rules of Civil Procedure 36(a).
McNeil v. AT&T Universal Card
, 192 F.R.D. 492, 494 (E.D. Pa. 2000),
Goodman
v. Mead Johnson & Co
., 534 F.2d 566, 573 (3d Cir. 1976), cert. denied, 429 U.S.
1038, 97 S. Ct. 732 (1977); Siss
v. County of Passaic
, 75 F. Supp. 2d 325, 331
(D.N.J. 1999).
10. No order staying discovery has been entered in this forum. Because the
proceedings in this matter have not been stayed, and because the Defendants,
Obama and DNC, failed to timely Answer Plaintiff’s Request for Admissions,
they have been deemed admitted in accordance with Federal Rules of Civil
Procedure, Rule 36(a).
11. Plaintiff has diligently prosecuted his case. Accordingly, Plaintiff
requests an Order deeming Plaintiff’s First Request for Admissions to Defendant
Obama numbered 1-56 and to Defendant DNC numbered 1-27 Admitted.
Respectfully submitted,
Dated: October 21, 2008 s/ Philip J. Berg
Philip J. Berg, Esquire
Attorney in
Pro Se
555 Andorra Glen Court, Suite 12
Lafayette Hill, PA 19444-2531
Identification No. 09867
(610) 825-3134″
Philip J Berg’s website:
Citizen WElls 
A Closer Look At The Birth Certificate
http://www.thebulletin.us/site/index.cfm?newsid=20171644&BRD=2737&PAG=461&dept_id=576361&rfi=8
Translation please?
That was provided in a post earlier today.
Is the Obama campaign aware that you can’t filibuster a lawsuit?? Or can you? For just long enough? 😉
I am sorry to hear of Mr. Obama’s grandmother and her serious illness. Losing a loved one is never fun, so I hope she gets better soon. However, are there other reasons for his trip to Hawaii again so soon? Or is this something that Obama does a lot? Maybe she was sick before and just got worse, but to the skeptic one might see where there could be other motives.
As “Obama Suspends Campaign to Visit Ailing Grandma in Hawaii”, another act of in the “Obama impeachment” script, we should recall this question:
Now, who was first re-named to the illuminati icon format, i.e. Louise Ciccone to Madonna or Barry Soetoro to Barack Hussein Obama II?
Help to let you answer:
… (1)
Note
(1) See
Barack Hussein Obama II vs. Madonna: role of birth certificate in naming illuminati icons
http://illuminati-icons.blogspot.com/2008/10/barack-hussein-obama-ii-vs-madonna-role.html
BTW I just reread my above comment and realized that the last sentence could be taken the wrong way.
I was trying to say that maybe the reason he went back there for “vacation” the first time was to visit his sick grandmother (though you would think that would be great PR, so why call it a vacation) or to make some legal or illegal arrangements (READ: COLB).
Others have mentioned that he has dropped his legal license. Some people do that because they don’t want to use it anymore. Some people also do that because the powers that be (the licensing entity) have no jurisdiction over you anymore if you do that.
Re: Fox News!
http://pub10.bravenet.com/forum/839764659/fetch/1179575/
Federal Election Commission Files Motion to Dismiss for Lack of Proper Jurisdiction
http://www.americasright.com/2008/10/federal-election-commission-files.html
JUST IN . . . Berg lawsuit was dismissed due to a “standing” technicality. Crap! I was hoping that would go through. Now what?????
Michelle Obama tapes’ imminent release approaching: API in a serious negotiation with FOX NEWS on the best way forward
Posted by africanpress on October 21, 2008
API has an ongoing discussion with FOX NEWS on the best way forward in the process of releasing Michelle Obama tapes to the American people.
API hopes the negotiation will be completed as soon as possible so that the tapes can be made available to FOX NEWS in the next few days and specifically before the voting day – the 4th of November.
API will make use of Legal Representation in the US when finalising the hand-over of the tapes and on any legal matters that may arise after the contents of the tapes become public.
We want to thank all our readers – those who have managed to be patient and also those who have exhibited total impatience. We assure them that an agreement will be reached soon between API and FOX NEWS one way or another, so that API fulfills the promise it gave to the readers.
The important thing we want the readers to know is how the tapes will be handled once it finally leaves API’s custody. API has confidence in FOX NEWS and will allow them to decide whether the tapes will be aired in full, edited or unedited. Once the tapes are released to FOX NEWS as per agreement that will be arrived at between the parties, API believes that FOX NEWS is competent enough to decide on how to proceed in handling the tapes because – better than us in API – they know what is best for the American listeners.
Some may not understand why this has taken long to accomplish. Sensitive issues requires careful steps so that nobody gets hurt in the process. People have questioned why the delay. API wanted to take time and make a good choice on the way forward and we can now happily say we are on the right track and hopefully you do not have to wait for long before your wishes are fulfilled.
Now that the release of the tapes is imminent, as soon as an agreement is reached, API hopes that those who finally gets access to its contents will use them wisely, in a way that brings the American people closer to one another despite their political allienation and to be above racial behaviour and work together for a better United American Nation. API does not wish to see the information from the tapes being misused by those who may wish to satisfy their own interests and achieve a particular aim.
The release of the tapes will take place without costs to any one. The negotiation between API and FOX NEWS bears no sign of money involved and that has been API’s wish all along.
Published by Chief Editor Korir /African Press International – API.
Michelle Obama tapes’ imminent release approaching: API in a serious negotiation with FOX NEWS on the best way forward
http://africanpress.wordpress.com/2008/10/21/michelle-obama-tapes-imminent-release-approaching-api-in-a-serious-negotiation-with-fox-news-on-the-best-way-forward/
Update on Madelyn Dunham. I feel bad….I hope she pulls through. Obama should have left as soon as he was notified of her condition. IMAO!!
http://www.honoluluadvertiser.com/article/20081021/BREAKING01/81021027
Youtube Posters note:
Playlist: Obama’s radical Muslim ties EXPOSED AGAIN
Description: Commentary and analysis on Obama’s radical Muslim connections including Bill Ayers, Tony Rezko. This explains why Obama wants his birth certificate and past well hidden.
Added: October 21, 2008
4 Part Commentary, appox. 36 minutes:
http://www.youtube.com/view_play_list?p=AEC33E398F31DEC1
Rumor’s are a-flyin’ about FOX in negotiations with API… sure hope they aren’t being conned again (or US being conned?).
No matter what that fraud will be in the WH.
Excerpt: …and conversations with American emissaries who assure that “Obama will be the next U.S. president.”
Article here:
http://www.military.com/opinion/0,15202,163481,00.html?wh=news
Will Oliver North’s warning come to pass?
New Evidence of (Witch) Nancy Pelosi Associate Supporting Chavez, Marxists, & Terrorists
Excerpt:
Why does the U.S. media steadily ignore the ties Speaker Pelosi has to Chavez and the terrorist group FARC through her association with Senator Córdoba?
Article here:
http://newsbusters.org/blogs/warner-todd-huston/2008/10/15/new-evidence-nancy-pelosi-associate-supporting-chavez-marxists-t
Have you seen this series of vids?
They are self explanatory:
http://www.youtube.com/watch?v=tWH9P57qg3k
You may follow through with the other 3 in the series.
Let’s get one thing straight here, this is not about Obama. He’s the puppet. The money and media cover is nothing he could have ever put together himself. He’s just not that F’n smart. This is huge on a scale past his capabilities. He is simply an opportunist from Hawaii that reads cue cards well.
Democrat or Republican, if you’re a true American republican (little “r”) this is a battle against the installation of a fascist regime in the United States. And make no mistake; Wall Street is your enemy in this battle. Obama must be defeated, not because McCain has the solutions and answers. He doesn’t. He is simply not purposefully evil. He will try to do what is right because he is a patriot and because of that we may be able to influence him.
Observer,
I entirely concur and have thought this for many months. But look at this as yet another example.
http://theamericansentinel.com/2008/10/21/lies-lies-and-opinion-polls-what-do-the-polls-mean-if-anything/
The public has been fed a constant diet of distortions, and Obama has only led the pack. It has been a mighty feat to overcome.
In the last 2 weeks, Obama must be defeated. McCain and Palin certainly think we can and unlike Obama theirs is not a pretense.
Citizen wells.. LOOK AT FILING # 23 on Docket.. Click onto # 23. It takes you to a filing that contains info about the limoseen ride.. Congrads Larry.. You are NOW in the Berg lawsuit intervened by another claimant.. http://dockets.justa.com/docket/court-paedce/case_no-2:2008cv04083/case_id-281573/.. Scroll down, click onto # 23 and read.. WOW!! LARRY!!!! YOU DID IT!!!
http://online.wsj.com/article/SB122463210033356561.html
Here’s another example.
This is a must read, for it is another example
of the power of a patriot, committed to
defending and preserving democracy.
For those who never heard or saw Patsy in action during the primaries, you missed a treat.
And she is a real soldier…….
See and read how she answers the call to help deal with the “threat” of ‘smears and outright lies’ identified in her home turf….…NC!
As you go about your own strategies,
check another patriot on duty.
Drum Roll please!!
http://hillbuzz.wordpress.com/2008/10/21/patsy-rogers-one-day-we-want-you-in-congress/
i personally wish they were ‘smears and outright lies’ – about the deciever O — but, Marielle, they are not! The lies are all on the Barrack Hussein Obama site – ‘answers to the smears’ — or more accurately, ‘More Lies’ to quell the masses with – to keep them far from the truth. And he is ‘divinely’ protected by the liberal brain controlling media …