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NOTICE AND MOTION TO TRANSFER TO THE DISTRICT OF COLUMBIA
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Dr. Orly Taitz, Attorney-at-Law29839 Santa Margarita ParkwayRancho Santa Margarita CA 92688Tel: (949) 683-5411; Fax (949) 766-3078California State Bar No.: 223433
E-Mail: dr_taitz@yahoo.com
UNITED STATES DISTRICT COURTFOR THE CENTRAL DISTRICT OF CALIFORNIACaptain 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 THEDISTRICT OF COLUMBIA
All the parties in the above captioned case are hereby notified of the motion hearingto be held on January 25, 2010, at the Central District Court of California, Santa AnaDivision, Judge Honorable David O. Carter, 411 W 4
th
str. Courtroom 9D, SantaAna, California, Ronald Reagan Federal Building. Motion to be heard is the Motionto transfer the above captioned case to Honorable judge Royce Lamberth, chief judgeof the US district court for the District of Columbia
Case 8:09-cv-00082-DOC-AN Document 105 Filed 12/24/2009 Page 1 of 7
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NOTICE AND MOTION TO TRANSFER TO THE DISTRICT OF COLUMBIA
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MOTION FOR TRANSFER OF THE CASE TO THE HONORABLE ROYCELAMBERTH CHIEF JUDGE OF THE US DISTRICT COURT OF THEDISTRICT OF COLUMBIA
Pursuant to local rule 7-4 prior to making the motion below the undersigned attorneycontacted the US attorneys
’
office for the Meet and Confer conference and got aresponse 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 MarkhamRobinson represented by Mr. Kreep and state the following:1.
During the October 5 motion hearing pursuant to the motion to dismiss due tolack of jurisdiction, the moving parties, the assistant US attorneys DavidDeJutte 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 wasnever 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 foundedsolely on diversity of citizenship may, except as otherwise provided by law, bebrought only in (1) a judicial district where any defendant resides, if alldefendants reside in the same state, (2) a judicial district where a substantialpart of the events or omissions giving rise to the claim occurred, or a
Case 8:09-cv-00082-DOC-AN Document 105 Filed 12/24/2009 Page 2 of 7
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NOTICE AND MOTION TO TRANSFER TO THE DISTRICT OF COLUMBIA
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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 inwhich the action may otherwise be brought.
4.
28 US Code Chapter 87 § 1404 (a) For the convenience of parties andwitnesses, in the interest of justice, a district court may transfer any civilaction to any other district or division where it might have been brought.
5.
In the interest of judicial economy, for the convenience of parties andwitnesses, in the interest of expedient resolution of this case of National
importance for “we the
people of the United States of America”
, in the interestof the National Security and in the interest of Justice, the undersigned counselrespectfully moves the court to transfer this case to Honorable Judge RoyceLamberth, 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 AUTHORITIES28 US Code Chapter 87 § 1404 (a) For the convenience of parties andwitnesses, in the interest of justice, a district court may transfer any civilaction 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;
Case 8:09-cv-00082-DOC-AN Document 105 Filed 12/24/2009 Page 3 of 7
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