Dr. Orly Taitz, Esquire

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 -- George Orwell

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 -- Mahatma Gandhi



Important, Notice of January 25 hearing and motion to move to the District of Columbia

Posted on | December 24, 2009 | 8 Comments

Motions

8:09-cv-00082-DOC-AN Captain Pamela Barnett, et al v. Barack Hussein Obama, et al CASE CLOSED on 10/29/2009
(ANx), APPEAL, CLOSED, DISCOVERY, MANADR

 

UNITED STATES DISTRICT COURT, CENTRAL DISTRICT OF CALIFORNIA

Notice of Electronic Filing

The following transaction was entered by Taitz, Orly on 12/24/2009 at 11:16 AM PST and filed on 12/24/2009

Case Name:Captain Pamela Barnett, et al v. Barack Hussein Obama, et al
Case Number:8:09-cv-82
Filer:Cynthia Davis
 Timothy Jones
 Alan Keyes PhD
 Pamela Barnett
 Richard Norton Bauerbach
 Robin D Biron
 John D Blair
 David L Bosley
 Loretta G Bosley
 Harry G Butler
 Glenn Casada
 Jennifer Leah Clark
 Timothy Comerford
 Charles Crusemire
 Thomas S Davidson
 Matthew Michael Edwards
 Jason Freese
 Kurt C Fuqua
 Clint Grimes
 Julliett Ireland
 D Andrew Johnson
 Israel D Jones
 David Fullmer LaRoque
 Gail Lightfoot
 Lita M Lott
 David Grant Mosby
 Steven Kay Neuenschwander
 Frank Niceley
 Jerry ONeil
 Robert Lee Perry
 Harry Riley
 Jeffrey Wayne Rosner
 David Smithey
 John Bruce Steidel
 Douglas Earl Stoeppelwerth
 Eric Swafford
 Neil B Turner
 Richard E Venable
 Jeff Graham Winthrope
 Mark Wriggle
WARNING: CASE CLOSED on 10/29/2009
Document Number:105

Docket Text:
NOTICE OF MOTION AND First MOTION to Transfer Case to District of Columbia filed by plaintiff Clint Grimes, Julliett Ireland, D Andrew Johnson, Israel D Jones, Timothy Jones, David Fullmer LaRoque, Gail Lightfoot, Lita M Lott, David Grant Mosby, Steven Kay Neuenschwander, Frank Niceley, Jerry ONeil, Robert Lee Perry, Harry Riley, Jeffrey Wayne Rosner, David Smithey, John Bruce Steidel, Douglas Earl Stoeppelwerth, Eric Swafford, Neil B Turner, Richard E Venable, Jeff Graham Winthrope, Mark Wriggle, Alan Keyes PhD, Pamela Barnett, Richard Norton Bauerbach, Robin D Biron, John D Blair, David L Bosley, Loretta G Bosley, Harry G Butler, Glenn Casada, Jennifer Leah Clark, Timothy Comerford, Charles Crusemire, Cynthia Davis, Thomas S Davidson, Matthew Michael Edwards, Jason Freese, Kurt C Fuqua. Motion set for hearing on 1/25/2010 at 10:00 AM before Judge David O. Carter. (Taitz, Orly)
8:09-cv-82 Notice has been electronically mailed to:

David A DeJute     USACAC.Civil@usdoj.gov, David.Dejute@usdoj.gov

Gary G Kreep     usjf@usjf.net, elliotwilson@gmail.com, emun8dog@gmail.com

Orly Taitz     dr_taitz@yahoo.com

Roger E West    USACAC.Civil@usdoj.gov, Roger.West4@usdoj.gov

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:

Main Document
Original filename:C:\fakepath\Keyes notice and motion to transfer to DC pdf (Autosaved).pdf
Electronic document Stamp:
[STAMP cacdStamp_ID=1020290914 [Date=12/24/2009] [FileNumber=8973682-0
] [185698a23ab5ef7e0deddc8727a69c937fb31144be9f9139b0a416dbd9ce0c52585
b0ed431fb9582cd6ae619fab243926f4d3a19ee64a3b2c7a9a18150a3605e]]

Dr. Orly Taitz, Attorney-at-Law  

29839 Santa Margarita Parkway

Rancho Santa Margarita CA 92688

Tel: (949) 683-5411; Fax (949) 766-3078 

California State Bar No.: 223433

E-Mail: dr_taitz@yahoo.com

 

UNITED STATES DISTRICT COURT

FOR THE CENTRAL DISTRICT OF CALIFORNIA

 

Captain Pamela Barnett, et al.,          §

                              Plaintiffs,                      §

                                                                      §

                    v.                                              §        Civil Action:

                                                                      §

Barack Hussein Obama,                                 §        SACV09-00082-DOC-AN

Michelle L.R. Obama,                                    §         NOTICE OF MOTION AND

Hillary Rodham Clinton, Secretary of State,  §        MOTION TO TRANSFER

Robert M. Gates, Secretary of Defense,         §        TO Honorable judge

Joseph R. Biden, Vice-President and             §        Royce Lamberth- chief

President of the Senate,                                  §        judge of the district court

                              Defendants.                     §        for the District of Columbia

 

NOTICE OF MOTION HEARING AND MOTION TO TRANSFER TO THE DISTRICT OF COLUMBIA  

All the parties in the above captioned case are hereby notified of the motion hearing to be held on January 25, 2010, at the Central District Court of California, Santa Ana Division, Judge Honorable David O. Carter, 411 W 4th str. Courtroom 9D, Santa Ana, California, Ronald Reagan Federal Building.  Motion to be heard is the Motion to transfer the above captioned case to Honorable judge Royce Lamberth, chief judge of the US district court for the District of Columbia

MOTION FOR TRANSFER OF THE CASE TO THE HONORABLE ROYCE LAMBERTH CHIEF JUDGE OF THE US DISTRICT COURT OF THE DISTRICT OF COLUMBIA

Pursuant to local rule 7-4 prior to making the motion below the undersigned attorney contacted the US attorneys’ office for the Meet and Confer conference and got a response from the assistant US attorney David DeJutte via e-mail on 12.23.09.

 Here come the plaintiffs in this case aside from Willey Drake and Markham Robinson represented by Mr. Kreep and state the following:

  1. During the October 5 motion hearing pursuant to the motion to dismiss due to lack of jurisdiction, the moving parties, the assistant US attorneys David DeJutte and Roger West have argued that they believe that the proper jurisdiction for this case is the District of Columbia.
  2. On October 29 this case was dismissed for want of jurisdiction only and was never heard on the merits, as this court noted in the above order that the proper jurisdiction is the District of Columbia court.
  3. 28 US Chapter 87 §1391 (b) A civil action wherein jurisdiction is not founded solely on diversity of citizenship may, except as otherwise provided by law, be brought only in (1) a judicial district where any defendant resides, if all defendants reside in the same state, (2) a judicial district where a substantial part of the events or omissions giving rise to the claim occurred, or a substantial part of property that is the subject of the action is situated, or (3) a judicial district in which any defendant may be found, if there is no district in which the action may otherwise be brought.
  4. 4.    28 US Code Chapter 87 § 1404 (a) For the convenience of parties and witnesses, in the interest of justice, a district court may transfer any civil action to any other district or division where it might have been brought. 
  5. In the interest of judicial economy, for the convenience of parties and witnesses, in the interest of expedient resolution of this case of National importance for “we the people of the United States of America”, in the interest of the National Security and in the interest of Justice, the undersigned counsel respectfully moves the court to transfer this case to Honorable Judge Royce Lamberth, chief judge of the US District Court for the District of Columbia, for the case to be heard on the merits as soon as possible.  

 

MEMORANDUM OF POINTS AND AUTHORITIES

28 US Code Chapter 87 § 1404 (a) For the convenience of parties and witnesses, in the interest of justice, a district court may transfer any civil action to any other district or division where it might have been brought. 

Precedents of Biochem Pharma Inc v. Emory University 148F. Supp 2d 11, 13 (D.D.C 2001); Osan Ltd. V. Accenture LLP 2005 U.S. Dist. Lexis 27488; Fleming v Ford Motor Co., 2005 U. S. Dist. Ct. 497559 2006 U,.S. Ct Pleading Lexis 24093 have held that a case can be transferred to another district for the convenience of the parties and witnesses and in the interest of justice, and the transfer analysis requires the district court to weigh the private and public factors involved in the case. 

The defendants in this case have already argued for the transfer during the October 5, 2009 hearing, stating that the proper venue is the District of Columbia therefore they cannot argue against this motion. The October 29 order stated that this was the opinion of the court. The undersigned counsel has filed a motion for clarification seeking to find out whether the October 29 order was an order with the leave to amend. As the latest order clarified that this court is not willing to provide for leave to amend in the Central District of California, the only reasonable solution and conclusion would be the transfer of the case to the US District Court of Columbia, for which the defendants have argued previously and to which the plaintiffs now agree as the only viable alternative. All the defendants are residents of the District of Columbia and officials in the federal government in the DC area, which satisfied both the private and public prongs of the test. Appealing the October 29 order to the circuit court of appeals will delay the hearing of the case for a year to a year and a half. Considering the position and influence of the defendants, it might be even a longer process. Transfer of the case to the District of Columbia will resolve any challenges to the jurisdiction on part of the defendants, and would give the plaintiffs an opportunity to start the discovery immediately. This will bring about an immediate resolution of this case, which of course will serve the interest of the parties and public interest. As such the under signed counsel moves this honorable court to transfer the case to the US District Court of Columbia. 

 

                                        PRAYER FOR RELIEF

  1. WHEREFORE, the undersigned counsel respectfully moves this Honorable court to transfer this case to Honorable Judge Royce Lamberth, chief judge for the US District Court for the District of Columbia, for the case to be heard on the merits in the District of Columbia as soon as possible.   

 

 

                                                                      /s/ DR ORLY TAITZ ESQ

                                                            By:__________________________________

                                                            Dr. Orly Taitz, Esq. (California Bar 223433)

                                                            Attorney for the Plaintiffs

29839 Santa Margarita Parkway ste 100

Rancho Santa Margarita CA 92688

Tel.:  949-683-5411; Fax: 949-766-7603

E-Mail: dr_taitz@yahoo.com 

PROOF OF SERVICE

          I, the undersigned Orly Taitz,  hereby declare under penalty of perjury that on this, December 24, 2009, I provided electronic copies of the Plaintiffs’ above-and-foregoing Notice of Filing to all of the following non-party attorneys whose names were affixed to the “STATEMENT OF INTEREST” who have appeared in this case in accordance with the local rules of the Central District of California, to wit:

ROGER E. WEST roger.west4@usdoj.gov (designated as lead counsel for President Barack Hussein Obama on August 7, 2009)

DAVID A. DeJUTTE

FACSIMILE (213) 894-7819

          DONE AND EXECUTED ON THIS 24th day of December, 2009

 

/s/Orly Taitz

 

Dr. Orly Taitz Esq

29839 Santa Margarita PKWY

Rancho Santa Margarita CA 92688

 

 

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Comments

8 Responses to “Important, Notice of January 25 hearing and motion to move to the District of Columbia”

  1. harveydawabbitt
    December 24th, 2009 @ 4:21 pm

    i dont understand why this is a civil action when crimes have been committed.
    why isnt this a criminal action orly?

    4. 28 US Code Chapter 87 § 1404 (a) For the convenience of parties and witnesses, in the interest of justice, a district court may transfer any CIVIL ACTION to any other district or division where it might have been brought.

  2. P. Huck Witt
    December 24th, 2009 @ 6:50 pm

    Dr Orly,

    You got’em on the run now!

    Now that even them DOJ lawyers are agreein’ with you you should file the reply from thet Dejutte fella as evidence before Holder makes him change his mind.

    Go get’em Lady Liberty

  3. Sly P. Seconds
    December 24th, 2009 @ 7:37 pm

    Attorney Taitz,

    I have been closely following this constitutional crisis for the last year.

    This latest move of yours proves beyond doubt that, as a lawyer, you come second to none!

    In awe

    Sly P Seconds

  4. Lori I
    December 24th, 2009 @ 11:11 pm

    Best present for America this Christmas 2009!!

  5. FUCK WHITEY
    December 26th, 2009 @ 12:23 am

    FUCK YOU STUPID ASS WHITE PEOPLE…YOU ALL KNOW GOOD AND DAMN WELL OBAMA IS AN AMERICAN CITIZEN HIS MOM WAS AN AMERICAN WHAT THE FUCK IS WRONG WITH YOU. SHE WAS A LILY WHITE WOMAN FROM KANSAS WHO HAD A THING FOR BLACKS. YOU DUMB FUCKIN WHITE PEOPLE ARE GOD’S MISTAKE THE WHOLE WORLD IS LAUGHING AT YOU ALL AND THIS LAWSUIT. FUCK YOU ALL I CAN’T STAND YOU INBREDED PEOPLE YOU MAKE ME SICK AND YOU ALL CALL YOURSELVES AMERICANS

  6. HorizonScanner
    December 26th, 2009 @ 1:19 am

    We Tea Party Patriots ought to convene another multi million rally in D.C. at the courthouse on the moment this trial is gaveled into reality by Judge Lamberth.

  7. TtruthSeeker
    December 30th, 2009 @ 2:11 am

    Dr. Orly,

    Way to go and thank you from us – we the people. How about also subpeona Nancy Pelosi and the DNC Presidential Nominating Committee for knowingly removing from the nomination certificate (which was notarized and sent to all the States in U.S) the text reference to constitutional eligibility of Obama’s nomiation for President.

    Pelosi et. al need to testify under oath in court and explain why.

    Thanks and God Bless America and our freedom (at least what’s left of it).

  8. Victoria Zink
    January 4th, 2010 @ 3:05 pm

    This is a very tough battle, and will continue to be with all the cover-up potential and protection that is available. The direction of the government is frightening all good solid true Americans. We want our country back and the freedom that has been our backbone. This man has to be stopped, his agenda is diluting America. Those who want a free ride without work who live with their hands in others pockets will prevail if we don’t fight to keep what we have worked so hard to call our own.
    Thanks for fighting for us and for our freedom.
    God Bless you and all of us still clinging to the hope of keeping America free.