If you note the date on the Certified Copy, it was created by the Registrar in Kenya on Feb. 17, 1964. The Kenyan Birth Certificate would have been issued in the midst of the divorce -- AFTER the divorce was filed by Ann in Hawaii on Jan. 20, but BEFORE the divorce was granted by Judge King on March 20.
Furthermore, it's quite plausible that once Ann actually had this Kenyan birth certificate in her hands, and the divorce was granted on March 20, her attorney, George Kerr, counseled her on Hawaiian birth certificate "loopholes" and told her how to file for a Hawaiian "Certificate of Delayed Birth" to get Welfare or OTHER support for young Obama as a child of a non-supporting foreign national.
If you’ve gone through one of those things and have dealt with lawyers, the FReeper’s interpretation makes perfect sense.