That would be because it is the law. From the FBI’s website on FOIA requests:
“If your request is for information about another living person, that information is usually not disclosed unless you have obtained the persons written consent or unless public disclosure is authorized by law. Requests for information about another living person should be accompanied by evidence of the subject's consent. Please use U.S. Department of Justice Certification of Identity Form DOJ-361 and complete the section identified as: Authorization to Release Information to Another Person. You may submit an attachment listing additional information that may aid in locating responsive records. Please place your name and contact information on the attachment.”
FOIA works on the Mom only because she is dead. So even if Obama’s birth certificate was in her record, which it may very well not have been, it couldn't be released without his consent, which you, the requestor, have to obtain.
Sir,
I hate to be a pest but because this line of inquiry is so central to my premise, I would like to ask you again:
Where do you think the appeal will be heard?
Who do you believe will represent him on appeal?
Huck