DEFENDANT ALVIN ONAKA AND LINDA ROSENS JOINDER IN MISSISSIPPI DEMOCRATIC PARTY EXECUTIVE COMMITTEES OPPOSITION TO PLAINTIFF ORLY TAITZS MOTION FOR LEAVE OF COURT TO FILE ADDITIONAL NEW FACTS AND OPINIONS AND SEPARATE RESPONSE IN OPPOSITION
COME NOW the Defendants, Dr. Alvin Onaka and Dr. Linda Rosen, by and through undersigned counsel, and file their J oinder in Mississippi Democratic Party Executive Committees Opposition to Plaintiff Orly Taitzs Motion for Leave of Court to File Additional New Facts and Opinions [ECF Doc. 110] and Separate Response in Opposition, and in support thereof, would show unto this Honorable Court the following: Defendants, Dr. Alvin Onaka and Dr. Linda Rosen, hereby join in, and adopt herein by reference, the Opposition to Plaintiff Orly Taitzs Motion for Leave of Court to File Additional New Facts and Opinions filed by the Mississippi Democratic Party Executive Committee on April 25, 2014 [ECF Doc. 110], to the extent the legal issues, arguments, and authorities are aligned with and benefit Dr. Alvin Onaka and Dr. Linda Rosen. Additionally, Defendants, Dr. Alvin Onaka and Dr. Linda Rosen, request that the Court deny Plaintiffs Orly Taitzs Motion and specifically disregard the statements and/or arguments contained in Paragraph 5 of said Motion. [See ECF Doc. 109 at 3-4]. Plaintiff Orly Taitz, in an effort to persuade this Court that that former Defendant Loretta Fuddys death was the result of foul playa fact which is of no significance to the Hawaii Defendants pending motion to Case 3:12-cv-00280-HTW-LRA Document 113 Filed 05/07/14 Page 1 of 3 2
dismisshas attached a copy of a response she received from the National Transportation Safety Board which purports to characterize the investigation of airplane crash as ongoing. [ECF Doc. 109-4]. Additionally, Plaintiff Orly Taitz embarks on a discussion regarding guidelines for obtaining the release of autopsy reports in Maui County. [ECF Doc. 109 at 4]. To be clear, these arguments, and the unsubstantiated and inadmissible evidence claimed to support them, have absolutely nothing to do with the Hawaii Defendants motion to dismiss which is based on various procedural defects. For these reasons, Defendants Dr. Alvin Onaka and Dr. Linda Rosen respectfully request that the Court deny Plaintiff Orly Taitzs Motion and disregard all materials attached thereto. Defendants, Dr. Alvin Onaka and Dr. Linda Rosen, further request that the Court dispense with the requirement of filing a separate Memorandum of Authorities under the Local Rules in support of this J oinder as the reasons supporting the same are fully set forth above. WHEREFORE, PREMISES CONSIDERED, Defendants, Dr. Alvin Onaka and Dr. Linda Rosen, respectfully request that this Court enter an Order denying Plaintiff Orly Taitzs Motion for Leave of Court to File Additional New Facts and Opinions [ECF Doc. 109]. RESPECTFULLY SUBMITTED, this the 7th day of May, 2014. DR. ALVIN ONAKA AND DR. LINDA ROSEN, DEFENDANTS
BY: DUKES, DUKES, KEATING & FANECA, P.A.
BY: s/ Walter W. Dukes WALTER W. DUKES
Case 3:12-cv-00280-HTW-LRA Document 113 Filed 05/07/14 Page 2 of 3
CERTIFICATE OF SERVICE
I hereby certify that a true and correct copy of the foregoing document has been electronically filed with the Clerk of Court and thereby served on the following persons, and also separately served by electronic mail as indicated below:
Orly Taitz Scott J . Tepper 29839 Santa Margarita Parkway, Suite 100 Garfield & Tepper Rancho Santa Margarita, California 92688 1801 Century Park East, Suite 2400 orly.taitz@gmail.com Los Angeles, California 90067-2326 scottjtepper@msn.com
Samuel L. Begley Harold E. Pizzetta, III Begley Law Firm, PLLC J ustin L. Matheny P.O. Box 827 Office of the Attorney General J ackson, Mississippi 39205 550 High Street, Suite 220 sbegley1@bellsouth.net P.O. Box 220 J ackson, Mississippi 39205 And to the following persons by electronic mail:
Brian Fedorka Tom MacLeran 812 Shiloh Drive 1026 Deer Ridge Road Columbus, MS 39702 Kingston Springs, TN 37082 bfedorka82@gmail.com tom@macleran.com
Leah Lax Laura Roth 350 Market Street 15510 E. Laurel Rd. Highspire, PA 17034 Elk, Washington 99009 lealax1234@aol.com drljroth@aol.com
SO CERTIFIED, this the 7th day of May, 2014.
s/ Walter W. Dukes WALTER W. DUKES
Walter W. Dukes (MSB No. 6214) Dukes, Dukes, Keating & Faneca, P.A. 2909 13 th Street, Sixth Floor Post Office Drawer W Gulfport, Mississippi 39501 Telephone: (228) 868-1111 Facsimile: (228) 863-2886 walter@ddkf.com Case 3:12-cv-00280-HTW-LRA Document 113 Filed 05/07/14 Page 3 of 3