3consideration of its motion. And even if the LFBC would be relevant (which, as MDEC Counsel had justbeen explained, it is not), the Court could take judicial notice of other
statements made by the Hawaii Department of Health
regarding the document.
at 19-20. In short,
Taitz’s claim that
MDECCounsel asked this Court to take judicial notice of the LFBC is simply wrong and, as such, her Motion forSanctions should be
The MDEC had no obligation to accept the incompetent, incorrect, andalready discredited information that Taitz provided to it.
Taitz claims that the alleged request for judicial notice of the LFBC
which MDEC Counsel didnot, in fact, make
” and “malicious”
because, at the time they attached a copy of theLFBC to the MDEC Motion, they
“were in possession of testimony showing such documents to beforgeries.”
Motion for Sanctions at 3. Specifically, Taitz claims that counsel had the following
“testimony” in their possession:
“1. Sworn te
a computer expert Felicito Papa, attesting that a documentin question, an alleged copy of a long form birth certificate is a computer generated forgery(Exhibit 2, Affidavit of Felicito Papa first Amended Complaint).
2. Transcript of the Public announcement and press conference by Sheriff Joe Arpaio of Maricopa County, Arizona and investigator Zullo, advising the public that the long formbirth certificate in question is a forgery (Exhibit 3
First Amended Complaint, Transcript of Sheriff Joe Arpaio).
[“Arpaio Press Conference Materials
3. Sworn testimonybya seniordeportationofficerJohnSampson, attesting tothefactthat
thedocumentinquestion is a forgery (Exhibit 4 (First Amended Complaint, affidavit of
senior Deportation officer john
4. Sworntestimonybya scanning and copyingmachinesexpert Douglas Vogt, attesting to
thefactthatthedocumentinquestion isa forgery. (Exhibit 5) (First Amended Complaint
Affidavit of Scanning and Copying machines
expert Douglas Vogt).
Taitz Motion at 3-4.
While not referenced in her Motion for Sanctions, Taitz filed with her motion an “
Orly Taitz for U.S. Senate presents
DVD,seeking donations to her current political campaign for the U.S. Senate in the State of California.
Docket No. 26. Giventhat (a) the transcript of the hearing reflected in the DVD is already included in the record (
Docket No. 1-1 at 112-157), and
Case 3:12-cv-00280-HTW-LRA Document 30 Filed 05/21/12 Page 3 of 10