Welcome to Scribd, the world's digital library. Read, publish, and share books and documents. See more
Download
Standard view
Full view
of .
Look up keyword
Like this
59Activity
0 of .
Results for:
No results containing your search query
P. 1
SDMS 2012-10-29 - ECF 59 - Joint Answer and Affirmative Defenses to Plaintiffs' FAC

SDMS 2012-10-29 - ECF 59 - Joint Answer and Affirmative Defenses to Plaintiffs' FAC

Ratings: (0)|Views: 898 |Likes:
Published by Jack Ryan
10/29/2012 59 Joint ANSWER to Complaint ( Taitz First Amended Complaint) by Barak Hussein Obama, Obama for America, Nanci Pelosi.(Begley, Samuel) (Entered: 10/29/2012)
10/29/2012 59 Joint ANSWER to Complaint ( Taitz First Amended Complaint) by Barak Hussein Obama, Obama for America, Nanci Pelosi.(Begley, Samuel) (Entered: 10/29/2012)

More info:

Published by: Jack Ryan on Oct 29, 2012
Copyright:Attribution Non-commercial

Availability:

Read on Scribd mobile: iPhone, iPad and Android.
download as PDF, TXT or read online from Scribd
See more
See less

04/11/2014

pdf

text

original

 
 
Page 1
IN THE UNITED STATES DISTRICT COURTFOR THE SOUTHERN DISTRICT OF MISSISSIPPIJACKSON DIVISIONDR. ORLY TAITZ, ESQ., BRIANFEDORKA, LAURIE ROTH, LEAHLAX, AND TOM MACLERANPLAINTIFFSVS. CIVIL ACTION NO. 3:12-CV-280 HTW-LRADEMOCRAT PARTY OF MISSISSIPPI,SECRETARY OF STATE MISSISSIPPI,BARAK HUSSEIN OBAMA, OBAMAFOR AMERICA, NANCI PELOSI,DR. ALVIN ONAKA, LORETTA FUDDY,MICHAEL ASTRUE, JOHN DOES, JOHNDOES 1-100DEFENDANTSDEFENDANTS BARACK H. OBAMA, II, NANCY PELOSIAND OBAMA FOR AMERICA
SANSWER AND AFFIRMATIVE DEFENSESTO PLAINTIFFS
FIRST AMENDED COMPLAINT
COME NOW Defendants President Barack H. Obama, II (President Obama),Representative Nancy Pelosi, Democratic Leader, United States House of Representatives(Representative Pelosi), erroneously sued as Nanci Pelosi, and Obama For America(OFA) (and, collectively, Defendants), for themselves and for no other parties, who herebyfile their Answer and Affirmative Defenses to the Plaintiffs First Amended Complaint(Complaint) in this action, and hereby state the following, through their undersigned attorneys,to wit:
Case 3:12-cv-00280-HTW-LRA Document 59 Filed 10/29/12 Page 1 of 20
 
 
Page 2
ANSWER 
President Obama, Representative Pelosi and OFA respond to the allegations set forth inthe First Amended Complaint paragraph by paragraph,
1
as follows:The three unnumbered paragraphs appearing on the top half of page 2 of the Complaintare introductory in nature, indicating that the Plaintiffs are seeking declaratory relief, injunctiverelief and treble damages. These allegations do not appear to set forth any facts or law requiringadmission or denial by Defendants. However, to the extent any allegations are raised entitling thePlaintiffs to the relief they are seeking, Defendants specifically deny any and all such allegationsand, likewise, deny that the Plaintiffs are entitled to any relief whatsoever.
PARTIES
1. All allegations set forth in paragraph 1 on page 2 are denied.2. Defendants are without sufficient information to admit or deny the allegationscontained in paragraph 2 on page 3 regarding Defendants Brian Fedorka, and therefore deny thisallegation.3. Defendants are without sufficient information to admit or deny the allegationscontained in paragraph 3 on page 3 regarding Leah Lax, and therefore deny such allegations.3. [
 sic
] Defendants are without sufficient information to admit or deny the allegationscontained in the second paragraph 3 on page 3 regarding Laurie Roth, and therefore deny suchallegations.
1
 
This Answer follows the paragraph numbering of the First Amended Complaint. The numbersare sometimes out of order or repetitive and some paragraphs are unnumbered. Such unnumberedparagraphs are denoted _. where appropriate.
 
Case 3:12-cv-00280-HTW-LRA Document 59 Filed 10/29/12 Page 2 of 20
 
 
Page 34. Defendants are without sufficient information to admit or deny the allegationscontained in paragraph 4 on page 3 regarding Tom Maclaren [
 sic
], and therefore deny suchallegations.5. The allegations contained in paragraph 5 on page 3 are denied as stated. Defendantsadmit only that President Barack Hussein Obama is currently the duly elected President of theUnited States, and is also the Democratic nominee for President of the United States in the 2012general election for President of the United States.6. The allegations contained in paragraph 6 on page 3 are denied as stated. Defendantsadmit only that OFA is the principal campaign committee of President Barack Obama as he seeks re-election in 2012.7. Defendants deny the allegations contained in paragraph 7 on pages 3-4 as stated.Defendants admit only that the Secretary of State is the duly elected Mississippi Secretary of State whose authority and obligations are established by law; has been sued only in his officialcapacity; and plaintiffs have alleged no RICO causes of action against him. Defendants denythat the Plaintiffs are entitled to any relief whatsoever against the Secretary of State, andtherefore deny any and all other allegations contained in paragraph 7 of the Complaint.8. Defendants deny the allegations contained in paragraph 8 on page 4 as stated.Defendants are informed and believe, and on that basis admit only that the MississippiDemocratic Party is a political party organized under the laws of the State of Mississippi formatters relating to the 2012 Party Presidential Preference Primary Ballot and 2012 GeneralElection Ballot, and for other purposes, but deny all other allegations set forth in paragraph 8.
Case 3:12-cv-00280-HTW-LRA Document 59 Filed 10/29/12 Page 3 of 20

Activity (59)

You've already reviewed this. Edit your review.
1 thousand reads
1 hundred reads
Sidney Sosin liked this
funnyhaha71 liked this
Sophia Cullison liked this
Jude Messineo liked this
esilvermanwm liked this

You're Reading a Free Preview

Download
scribd
/*********** DO NOT ALTER ANYTHING BELOW THIS LINE ! ************/ var s_code=s.t();if(s_code)document.write(s_code)//-->