Posted on 09/26/2009 7:40:31 AM PDT by Elderberry
Dr. Orly Taitz: Important - Plaintiffs hereby move and request leave of court to file a surreply in response to Defendants’ Reply filed and served on Friday, September 25, 2009.
(Excerpt) Read more at oilforimmigration.org ...
“FREE THE LONG FORM!”
Orly is asking for time to file a response to the filing of Friday, 9-25-09 by the other party.
Plaintiffs’ L-R 7-10 Motion for Leave to File Sur-Reply
To Defendants’ Reply to Plaintiffs’ Response to
Defendants’ September 4, 2009 Motion to Dismiss
Plaintiffs hereby move and request leave of court to file a surreply in response to Defendants’ Reply filed and served on Friday, September 25, 2009. Plaintiffs cite the following authority from the Local Rules of the Central District of California:
L.R. 7-10 Reply Papers. A moving party may, not later than the seventh calendar date (not excluding Saturdays, Sundays, and holidays) before the date designated for the hearing of the motion, serve and file a reply memorandum, and declarations or other rebuttal evidence. Absent prior written order of the Court, the opposing party shall not file a response to the reply.
Plaintiffs submit that the Defendants have raised new matter in their reply which require an answer. Namely, the Defendants submit cast in a highly prejudicial light to the Plaintiffs’ cause, namely the orders of the Honorable Clay D. Land from the Middle District of Georgia.
It is true that Judge Land ruled in favor of defense in a case seeking stay of deployment of active duty military pending verification of Mr. Obama’s legitimacy for the position of the President and Commander in Chief. What is most important in that case, is that for the first time after over a 100 legal actions filed all over the Nation challenging Mr. Obama’s legitimacy for presidency, a judge in this case found standing, as judge Land got straight to the substance of the Plaintiffs’ case, assuming standing of the members of the military to challenge the legitimacy of the Commander in Chief, but deciding to exercise discretionary abstention on the issue of deployment. Most of the plaintiffs in this case before His Honor, judge Carter, are members of the military, and as such, based on the precedent set in Rhodes case, they have standing to challenge legitimacy of Mr. Obama, therefore contradicting the defendants’ main argument in the motion to dismiss, their claim that none of the plaintiffs have standing. The fact that Judge Land decided to abstain on the issue of deployment is irrelevant in this case, as it goes to the final disposition of the case, and whether the judiciary should abstain from reviewing a certain procedure within the military.
Furthermore, the Defendants assert that the Plaintiffs have not addressed the question of “redressability”, and this matter needs to be clarified in light of the Plaintiffs’ substantive due process contentions regarding the intersection of the First and Ninth Amendments as sources of the right of discrete and insular but politically powerless minorities to invoke strict scrutiny of obvious deviations from and therefore to enforce precisely and exactly the letter of the Constitution on the model of Flast v. Cohen and this charge requires a surreply.
Finally, the Defendants continue to misrepresent the Plaintiffs’ contentions regarding standing and how standing as a barrier to self-governing enforcement of the Constitution through Petition to Article III Courts (as advocated by the Defendants, in any case) would itself constitute a violation of Plaintiffs’ constitutional right to due process of law in the enforcement of the plain letter of the Constitution.
WHEREFORE, Plaintiffs’ pray, pursuant to L.R. 7-10, that they be allowed to file a surreply to Defendants’ response in this case, and even to do so as late as Thursday, October 1, 2009, especially since they are precluded from filing their Second Amended Complaint prior to the hearing on Defendants’ Motion to Dismiss by this Court’s Minute Order entered Thursday, September 24, 2009.
Respectfully submitted,
Saturday, September 26, 2009
But,sir, you’re wrong. If you had any actual legal experience you would be familiar with the use of the prefix “sur” tracing back quite a ways, as in “surrebutter,” and “surreply.”
Another document filed on Friday:
Dr Orly Taitz is one of the very few people willing to stand up to the sitting president and his million dollar lawyers. She’s already been through the hell of the Soviet Union making fighting 0bama look like a “piece of cake.” She speaks five languages, so maybe she doesn’t get every word spelled correctly or her sentences follow the structure and grammar of another of her languages and not of American English. So the heck what! SHE is doing something while YOU sit there and I donate to her.
Put your money where your mouth is and send her some money to help http://www.orlytaitzesq.com/ or at the least do more research about her past . . . I admire this woman for being so willing to be a target for 0bama’s “anti-birther’s movement.” She makes me less afraid to speak my mind and to send emails via the White House dot gov website!
My take:
Barry’s REAL father is Louis Farrakhan or Frank Marshall Davis.
Barry’s College Transcripts will show 1) extremely poor grades, 2) that he attended as a Foreign Student from Indonesia, 3) that he was a very vocal and active member of the Students for a Democratic Society at Occidental College and beyond.
Since the “birthers” are so embarassing to your highness of media designed public image, why not just avoid these threads? Also, so you don’t hurt your proud politically correct image, you should avoid most threads on Free Republic.
BamBam is the public image that the media promotes as lovely. Don’t pay attention to the message behind the lovely or ugly image. The image is all that matters.
“Good lord, doesn’t this crazy woman have anybody to proofread her documents?”
How about you, or do you just like to bitch?
I fully support Orly Taitz and her efforts...this issue needs to be kept at the forefront at all times during this man’s administration.
She is fighting to have the constitution upheld...that is more than MILLIONS of other US citizens are willing to do...and she is a Russian born immigrant who loves this country and the freedoms it provides her because she’s lived under the oppression of a communist regime.
Calling her names is absurd! If you’re going to call her names, then I suggest you get your butt down to the courthouse and start taking some action to try to reveal the fraud that has been committed against this country.
If you can’t do that, then STHU!!!!
I hope You sent this to me in ERROR!
I used to think this woman was insane. Now I believe it's more a case that the law means nothing to her. She's using the courts as a staging platform to draw media attention to herself, and she doesn't give two figs about the "glorious cause" of "removing the usurper," or her clients -- she thrives on attention, even when it's overwhelmingly negative, so the more outrageous her behavior, the more attention. Rinse and repeat.
Narcissist Orly v Narcissist Obama, and it's not hard to figure out who will prevail, when he finally decides she's no longer useful as a figurehead useful in painting the entire right as nutjobs.
No thanks. An attorney working on such a high profile case should be able to handle this herself.
I want to see all of the President’s records released. At first, I was rooting for Ms. Taitz, but no longer. Now it seems to me that she can’t get it together. She may be doing more harm than good at this point.
I did...I sincerely apologize...I sent it to the wrong name.
No harm. It happens to me too.
If you know anything about court, which you don’t, you would realize that court is a parallel universe. Even the most reputable law firms do whatever they have to do to win. Orly’s behavior is exemplary and she is fighting as hard as they are. There is nothing embarrassing about what she is doing. As a matter of fact given the odds it is amazing that she is getting this far and that is because of who she is. She is all talent.
Yes, all talent. Didn’t she have one of her pleadings thrown back at her because she didn’t spell her own name correctly?
First Malcolm X, now Calypso Louie?
Well, any three of them would at least put to rest his eligibility issues.
Kook is pretty tame. She has been called every name in the book.
I forget where name calling falls in the COLB Playbook.
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