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Georgia - Farrar Primary Ballot Challenge Re Obama - Motion for Extensioin of Time and Leave to File Amended Complaint

Georgia - Farrar Primary Ballot Challenge Re Obama - Motion for Extensioin of Time and Leave to File Amended Complaint

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Published by Jack Ryan
MOTION FOR EXTENSION OF TIME AND A LEAVE OF COURT TO FILE A FIRST AMENDED COMPLAINT
HON. MICHAEL MALIHI PRESIDING
MOTION FOR EXTENSION OF TIME AND A LEAVE OF COURT TO FILE A FIRST AMENDED COMPLAINT
HON. MICHAEL MALIHI PRESIDING

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Categories:Types, Research, Law
Published by: Jack Ryan on Dec 01, 2011
Copyright:Attribution Non-commercial

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12/04/2011

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ORLY TAITZ ESQ 29839 SANTA MARGARITA, STE 100 RANCHO SANTA MARGARITA, CA 92688 949-683-5411 FAX 949-766-7603 ORLY.TAITZ@GMAIL.COM COUNSEL FOR THE PLAINTIFF CA BAR LIC 223433 ADMINISTRATIVE COURT STATE OF GEORGIA DAVID FARRAR, ) CASE NO.: 1215136-60-MALIHI ) ) ) MOTION FOR EXTENSION OF ) TIME AND A LEAVE OF COURT ) TO FILE A FIRST AMENDED ) COMPLAINT ) HON. MICHAEL MALIHI ) PRESIDING )
DAVID FARRAR V BARACK OBAMA MOTION FOR LEAVE OF COURT TO FILE A FIRST AMENDED COMPLAINT AND FOR EXTENSION OF TIME 1

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PLAINTIFF, VS. BARACK OBAMA, DEFENDANT

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Plaintiff herein, David Farrar, by and through his counsel submits this NOTICE OF MOTION AND MOTION FOR LEAVE OF COURT TO FILE A FIRST AMENDED COMPLAINT and for 30 DAYS TIME EXTENSION to submit such complaint. Plaintiff filed this complaint pro se. Only 2 days ago counsel for the plaintiff was granted Pro Hac Vice to represent the Plaintiff. Counsel was at a time in Hawaii on another case. Response to the pretrial order is due today. Counsel is respectfully requesting this honorable court to grant her leave of court to file a proper First Amended Complaint and 30 days time extension to draft and file such amended

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complaint. Plaintiff would be greatly prejudiced, if he is not given an opportunity to submit a proper complaint. Respectfully submitted /s/ Dr. Orly Taitz, ESQ I attest, that the defendant was served with a copy of this motion through his counsel, by e-mailing his counsel Michael Jablonski at Michael.jablonski@comcast.net, and Scott Kwain at kwainscott@barackobama.com

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Dated this 12.01.2011

/s/ Orly Taitz _______________________ Dr. Orly Taitz ESQ 29839 Santa Margarita ste

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100 Rancho Santa Margarita, CA 92688

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