Philip J Berg filed an Opposition to Obama’s Motion for a Protective
order to prevent Discovery. Obama’s motion was a delay tactic to
prevent Judge Surrick from ruling that Obama must provide proof
of citizenship.
Jeff Schreiber is currently reviewing it. As soon as it appears we will
provide more details.
Philip J Berg’s website:
http://obamacrimes.com
* Update *
Here is the first part of Philip J Berg’s motion in text form:
“UNITED STATES DISTRICT COURT
FOR THE EASTERN DISTRICT OF PENNSYLVANIA
PHILIP J. BERG, ESQUIRE, :
Plaintiff :
vs. : CIVIL ACTION NO. 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 :
ORDER
AND NOW this ______day of October, 2008, upon consideration of Defendants,
Barack H. Obama and the Democratic National Committee’s Motion for a Protective
Order and Stay Pending the Decision on Defendants Dispositive Motion and Plaintiff’s
Response in Opposition thereto, it is hereby
ORDERED and DECREED as follows:
1.
Defendants Motion for Protective Order Staying Discovery
pending the Court’s Decision on Defendants dispositive Motion is
DENIED;
2.
Defendants are hereby ORDERED to Answer Plaintiff’s
Discovery Requests by way of Admissions and Request for
Production of Documents by October 15, 2008.
IT IS SO ORDERED
BY THE COURT:
R. Barclay Surrick, J.
Case 2:08-cv-04083-RBS Document 18 Filed 10/09/2008 Page 2 of 22
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 :
ORDER
AND NOW this ______day of October, 2008, upon consideration of Defendants,
Barack H. Obama and the Democratic National Committee’s Motion for a Protective
Order and Stay pending the Decision on Defendants Dispositive Motion and Plaintiff’s
Response in Opposition thereto, it is hereby
ORDERED and DECREED as follows:
1.
Defendants Motion for Protective Order Staying Discovery pending
the Court’s Decision on Defendants dispositive Motion is DENIED in
part and GRANTED in part;
2.
Pending the Decision on the Defendants, Barack H. Obama and the
Democratic National Committee’s Motion to Dismiss, discovery is
stayed except for the following:
Defendants, Barack H. Obama and the Democratic National Committee are
ORDERED to turn over the following documents by October 15, 2008:
1.
A certified copy of Obama’s “vault” (original long version) birth
certificate;
Case 2:08-cv-04083-RBS Document 18 Filed 10/09/2008 Page 3 of 22
2.
Certified copies of all reissued and sealed birth certificates of
Obama in the names referred to in the caption of this lawsuit;
3.
A certified copy of Obama’s Certification of Citizenship;
4.
A certified copy of Obama’s Oath of Allegiance taken upon age of
majority;
5.
Certified copies of Obama’s Application and Admission forms for
Occidental College, Columbia University and Harvard Law
School; and
6.
Certified copies of any Court Orders or legal documents changing
Obama’s name from Barry Soetoro to Barack Hussein Obama.
Defendant, Barack Hussein Obama is ORDERED to serve upon Plaintiff
Answers to the following Request for Admissions by October 15, 2008:
Admissions, Request No. 1.
Admit you were born in Kenya.
Admissions, Request No. 2.
Admit you are a Kenya “natural born” citizen.
Admissions, Request No. 3.
Admit your foreign birth was registered in the State
of Hawaii.
Admissions, Request No. 4.
Admit your name was legally changed to Barry
Soetoro and citizenship status was changed to
“natural citizen” of Indonesia.
Admissions, Request No. 5.
Admit you were adopted by Lolo Soetoro, M.A. a
citizen of Indonesia.
Admissions, Request No. 6.
Admit Lolo Soetoro, M.A. a citizen of Indonesia.
Signed a Government “Acknowledgement” form
legally acknowledging you as his son.
Admissions, Request No. 7.
Admit you are an Indonesian citizen.
Admissions, Request No. 8.
Admit you are currently not a “natural born” United
States citizen.
Case 2:08-cv-04083-RBS Document 18 Filed 10/09/2008 Page 4 of 22
Admissions, Request No. 9.
Admit you are not eligible to serve as the President
of the United States pursuant to Article II, Section I
of the United States Constitution.
Admission, Request No. 10.
Admit you are unable to prove your citizenship
status.
Defendant, the Democratic National Committee is ORDERED to serve upon
Plaintiff Answers to the following Request for Admissions by October 15, 2008:
Admissions, Request No. 1.
Admit you have not verified Barrack Hussein
Obama’s eligibility to serve as President of the
United States.
Admissions, Request No. 2.
Admit Barrack Hussein Obama was born in Kenya.
Admissions, Request No. 3.
Admit Barack Hussein Obama’s citizenship status
was changed to a “natural” citizen of Indonesia
when his stepfather, Lolo Soetoro, M.A. legally
“acknowledged” Obama as his son.
Admissions, Request No. 4.
Admit Barack Hussein Obama’s name was legally
changed to Barry Soetoro, an Indonesian citizen.
Admissions, Request No. 5.
Admit Barrack Hussein Obama is not a “natural
born” United States citizen.
Admissions, Request No. 6:
Admit you have not inquired into Barrack Hussein
Obama’s citizenship status.
Admissions, Request No. 7.
Admit the United States Constitution does not allow
for a Person to hold the Office of President of the
United States unless that person is a “natural born”
United States citizen.
Admissions, Request No. 8.
Admit you collected donations on behalf of Barack
Hussein Obama for his Presidential campaign.
Admissions, Request No. 9.
Admit the DNC has promised Plaintiff and all
American citizens that the DNC will ensure Open
and Honest Government and uphold the United
States Constitution to protect the United States
citizens.
Case 2:08-cv-04083-RBS Document 18 Filed 10/09/2008 Page 5 of 22
Admissions, Request No. 10. Admit Barack Hussein Obama is not a legal citizen
of the United States.
IT IS SO ORDERED
BY THE COURT:
R. Barclay Surrick, J. “
Citizen WElls 