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UNITED STATES DISTRICT COURT, CENTRAL DISTRICT OF CALIFORNIA
Notice of Electronic Filing
The following transaction was entered by Taitz, Orly on 8/1/2009 at 10:08 PM PDT and filed on 8/1/2009
Case Name: Ambassador Alan Keyes PhD, et al v. Barack Hussein Obama, et al
Case Number: 8:09-cv-82
Filer: Alan Keyes PhD
Document Number: 34
Docket Text:
NOTICE OF MOTION AND MOTION to Expedite authentication, MOTION for Issuance of Letters Rogatory for authenticity of Kenyan birth certificate filed by Plaintiff Alan Keyes PhD.
(Attachments: # (1)
Appendix Photocopy of Obama’s birth certificate from Kenya)(Taitz, Orly)
8:09-cv-82 Notice has been electronically mailed to:
UNITED STATES OF AMERICA david.dejute@usdoj.gov
Orly Taitz dr_taitz@yahoo.com
8:09-cv-82 Notice has been delivered by First Class U. S. Mail or by fax to: :
The following document(s) are associated with this transaction:
Document description:
SPECIAL MOTION FOR LEAVE TO CONDUCT PRE-RULE 26(f) DISCOVERY
TO DEFENDANT HILLARY RODHAM CLINTON and
CERTAIN NON-PARTY WITNESSES
TO PERPETUATE TESTIMONY, PRESERVE EVIDENCE, and to
TRANSMIT LETTERS ROGATORY PURSUANT to
28 U.S.C. §§1781(a)(2)-(b)(2)
The undersigned counsel for Plaintiffs has acquired possession of a color copy of one certain document (attached as Exhibit A to this motion), regarding which there are no ready means of authentication except by recovery of the original document. As should be apparent from the nature and content of the document, if authenticated, and shown to be genuine, the contents of this document will significantly narrow and shorten the discovery and pre-trial litigation period necessary in this case, and might lead to an early resolution by settlement or transfer of these proceedings to the United States House of Representatives and Senate according the procedures outlined in the Constitution.
It is also apparent (and hearsay evidence available to Plaintiffs’ counsel aggravates her concerns) that political pressure may be brought to bear to destroy all relevant evidence, whether such evidence exists within or outside the borders of the United States of America.
It would appear to the undersigned counsel that either 28 U.S.C. §1781(a)(2) or 28 U.S.C. §1782(b)(2) or some combination of these statutory authorizations outlines the procedures by which to transmit letters rogatory and other requests to the proper authorities abroad in Kenya and the United Kingdom of Great Britain and Ireland.
For two classes of evidence at issue here, namely all requests for relevant passport materials and other documents existing within the United States of America, as well as all requests to be made through diplomatic channels to foreign tribunals, Defendant HILLARY RODHAM CLINTON is the Secretary of State of the United States of America, and accordingly, Secretary Clinton is the first and primary proper target of letters rogatory to be submitted pursuant to 28 U.S.C. §1781(a)(2).
FIRST, Plaintiffs pray that this court authorize Plaintiffs to issue a special subpoena for deposition duces tecum to Secretary HILLARY RODHAM CLINTON be cited to appear within 21 days pursuant to (or in the letter and spirit of) Rule 27 of the Federal Rules of Civil Procedure (even though this action has been filed and served, many months will pass before the Rule 26(f) Conference can be held to plan for discovery among the parties). The purpose of Rule 27, even though designed for pre-filing discovery, is fulfilled and relevant here, in that some (above-noted) hearsay evidence exists that an individual involved in the examination of passport files at the United States Department of State relating to and involving certain 2008 Presidential candidates may have been killed in relation to such inquiry. Last year it was announced by former secretary of State Candoleeza Rice that there was tampering with the passport records of three major presidential candidates and it was investigated by the inspector general. Lt. Querl Harris was one of the suspects in passport tampering scandal. Washington post has announced that he was cooperating with the FBI and shortly thereafter he was found dead, shot in the head, sitting in his parked car.
This case remains open and unresolved. Under such circumstances, “perpetuation of evidence” becomes a more and more significant and time-sensitive issue.
SECOND, Plaintiffs pray that this court will send a request for letters rogatory pursuant to 28 U.S.C.§1781(a)(2) to Defendant HILLARY RODHAM CLINTON and other relevant officers in the United States Department of State to issue and transmit letters rogatory through proper diplomatic channels to the following foreign offices of public record and vital statistics:
For the Republic of Kenya:
KENYA
The Principal Civil Registrar
Dept of Civil Registration
Office of the President
PO Box 49179
Nairobi Kenya