Case 3:12-cv-00280-HTW-LRA Document 57-2 Filed 10/26/12 Page 1 of 3

IN THE UNITED STATES DISTRICT COURT

FOR THE SOUTHERN DISTRICT OF MISSISSIPPI
JACKSON DIVISION
DR. ORL Y T AITZ, ESQ., ET AL. PLAINTIFFS
v. CIVIL ACTION NO. 3:12cv280-HTW-LRA
DEMOCRAT PARTY OF MISSISSIPPI, ET AL. DEFENDANTS
DECLARATION OF LORETTA J. FUDDY
I, LORETTA J. FUDDY, A.C.S.W, M.P.H., declare as follows:
1. I am over the age of 18 years. I have personal knowledge of the facts stated
herein, except those stated on information and belief, and, if called upon, could and would testify
competently to them. I make this declaration as a special appearance in support of my Motion to
Dismiss for Lack of Personal Jurisdiction.
2. I am informed that on or about April 19, 2012, a First Amended Complaint was
filed in this action by plaintiffs Orly Taitz, Brian Fedorka, Leah Lax, Laurie Roth, and Torn
MacLeran.
3. I am the Director of Health for the State of Hawaii's Department of Health in
Honolulu, Hawaii.
4. I am a citizen and an adult resident of the State of Hawaii.
5. I have never lived in the State of Mississippi.
6. I have never considered the State of Mississippi to be my domicile.
7. I have never owned real property in the State of Mississippi.
8. I have never voted in the State of Mississippi.
9. I have never held a driver's license from the State of Mississippi.
10. I have never filed suit in any court in the State of Mississippi.
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Case 3:12-cv-00280-HTW-LRA Document 57-2 Filed 10/26/12 Page 2 of 3
11. I have never been sued in any court in the State of Mississippi (with the exception
of the present case).
12. I have never conducted personal business in the State of Mississippi.
13. I have never been employed by any Mississippi employer.
14. I have never consented to the exercise of jurisdiction over me by the courts of the
State of Mississippi.
15. I have never, to my knowledge, purposefully availed myself of the benefits or
protections ofthe laws ofthe State of Mississippi.
16. I am not qualified to do business in Mississippi.
17. I have neither incurred nor paid taxes in Mississippi.
18. I have not appointed an agent for service of process in Mississippi.
19. I have no office, no place of business, no officers, no agents, no employees, no
salesman, no licensees, no franchisees, and no distributors in Mississippi.
20. I have never advertised in local Mississippi media and am not listed in any
Mississippi telephone directories
21. I have never sent representatives, agents, or personnel to Mississippi.
22. I am informed that page 32 of the First Amended Complaint alleges that I aided
and abetted President Barack Obama and was complicit in an alleged cover up of a forged birth
certificate from the state of Hawaii. None of these acts are alleged to have occurred in the State
of Mississippi.
23. I am also informed that page 39 of the First Amended Complaint alleges that I
obstructed justice in order to aid and abet President Barack Obama in his use of a forged birth
certificate. None of these acts are alleged to have occurred in the State of Mississippi.
24. I am also informed that various other acts are alleged to have been perpetrated by
one or more of the twenty-nine defendants named in the First Amended Complaint. None of
these alleged acts, as they might relate to me, are alleged to have occurred in the State of
Mississippi.
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Case 3:12-cv-00280-HTW-LRA Document 57-2 Filed 10/26/12 Page 3 of 3
25. It would be a tremendous burden upon me personally if I was required to attend a
trial of this lawsuit in Mississippi. In addition, if I was required to attend a trial of this lawsuit in
Mississippi; it would be very difficult for me to fulfill my duties as Director of Health for the
State of Hawaii's Department of Health, thereby injuring the citizens of the State of Hawaii.
I declare under penalty of perjury under the laws of the State of Hawaii that the foregoing
is true and correct.
Executed on c?d: 2"2- , 2012 in Honolulu, Hawaii.
SWORN TO AND SUBSCRIBED BEFORE ME, this the 22ND day of OCTOBER
'2012.
VICKIE DONAYRI
My Commission Expires:
DECEMBER 17, 2014
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NOTARY CERTIFICATION
ooc. DATE: 10/22/12 #PAGES: ___J_
VICKIE DONAYRI 1sr JUDICIAL CIRCUIT
ooc. oesCRtPTION: DEClARATION OF LOREITA J FUDm
i!J=.. /u/.J.J//er
NOTARY DATE
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