I.INTRODUCTORY STATEMENTAppellees, by and through their undersigned counsel, hereby set forth theirOpposition to Appellants’ “Emergency Petition for Writ of Mandamus.” Asdemonstrated infra, the Petitioners have no standing herein, this case presents non- justiciable political questions, the person against whom mandamus is sought is nota party, and the grounds set forth in Appellants’ moving papers are factually falseand legally frivolous.II.APPELLANTS ARE NOT PROPER PARTIES HEREIN BECAUSETHEY LACK STANDING, AND THE CASE PRESENTS NON-JUSTICIABLE POLITICAL QUESTIONSAs set forth in Appellees’ Answering Brief, filed herein on or about October13, 2010, Appellants are not proper parties, as they lack standing to bring theaction, and this case presents non-justiciable political questions. These arguments,as well as others supporting the dismissal of this case, are set forth in Appellees’Answering Brief, a copy which is attached hereto for the Court’s convenience asAppendix 1, and will not be repeated here.III.APPELLANTS HAVE NOT SET FORTH A LEGAL BASIS FOR THISCOURT TO EXERCISE JURISDICTION OVER LORETTA FUDDY,WHO IS NOT A PARTY TO THIS CASEAppellants seek a Writ of Mandamus from this Court directing LorettaFuddy, who is the Director of Health of the State of Hawaii, to allow Appellants’counsel, Orly Taitz, and her forensic document “experts” to examine the original1961 long-form birth certificate of President Obama. Counsel provides no legalbasis whatever to support the issuance of such a writ to a non-party. In the absenceof such showing, the Petition should be denied.
Case: 10-55084 11/07/2011 ID: 7957482 DktEntry: 52-1 Page: 2 of 6