IN THE SUPREME COURT STATE OF GEORGIA KEVIN RICHARD Applicant V. BARACK OBAMA, POWELl.

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CASE NO.

Respondent

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APPLICATION

FOR DISCRETIONARY

APPEAL

MARK HATFIELD HATFIELD & HATFIELD, P.C. Attorney for Applicant 201 Albany Avenue P.O. Box 1361 Waycross, Georgia 31502 (912) 283-3820 Georgia Bar No. 337509 mhatfield@wayxcable.com

J.

IN THE SUPREME COURT STATE OF GEORGIA KEVIN RICHARD Applicant V. BARACK OBAMA, POWELJi.,

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CASE NO.

Respondent APPLICATION

*
FOR DISCRETIONARY APPEAL

Now comes Appl:_cant Kevin Richard undersigned pursuant counsel., and respectfully

Powell, by and through applies to this Court for leave to

to O.C.G.A.

§§

5-6-35(a) (1) and 21-2-5(e) from the Superior

file a discretionar~T appeal County's Dismiss,"

Court of Fulton to

"Order GraIlting Respondent which was entered

Barack Obama's Motion

and filed on March 2, 2012, in a Final

Applicant's Decision

Fulton ~;uperior Court action appealing Secretary

of Georgia

of State Brian P. Kemp denying of Respondent Barack

Applicant's Obama,

challencJe to the qualifications

a presidentiill candidate, of the~ United

to seek and hold the Office of Obama

the President eligible

States, and finding Respondent primary

as a candiejate for the presidential respectfully a'3 Exhibit

election.

Applicant attaching Granting
nBn

shows to the Court that he is
nAn

hereto:

a copy of the aforesaid to Dismiss"; Review"

"Order

Respondent

Barack Obama's Motion

as Exhibit

a copy of the "::>etitionFor Judicial

filed by Page -1-

Applicant

in the Superior
"C'I

Court of Fulton County on February "Motion

15,

2012; as Exhibit

a copy of Applicant's

For Expedited of

Review or, Alternat~_vely, For Stay of Decision State and For Postpc)nement of Presidential Election" Respondent Support

of Secretary

Preference

Primary

filed on ~~ebruary 22, 2012; as Exhibit Barack Obama's "Motion to Dismiss"

"0" a copy of

and Brief in "E" a

thereof

served on February "Response

27, 2012; as Exhibit Motion

copy of Applicant's submitted

to Respondent's

to Dismiss"

to and acc:epted by the Superior

Court of Fulton County, by email on March 5, 2012; and as

as per the Court's

I)ermission and instructions,

2, 2012 and thereaf-~er stamped as filed on March Exhibit "F" a copy of a letter dated January attorn(~y to Secretary

25, 2012 from

Respondent's

of State Brian P. Kemp.

PART ONE

STATEMENT 1. TYPE OF Q~SE. Appea.

OF THE CASE For

This case is an Application to O.C.G.A.

Discretionary 2-5(e)

pursuant

§§ 5-6-35 (a) (1) and 21Court

for leave to appeal

from the Order of the Superior "Petition Secretary

of Fulton County di:3missing Applicant's Review" of a Final :)ecision of Georgia challenge

For Judicial of State Brian of

P. Kemp denying Applicant's Respondent Office Obama,

to the qualifications

a presidential

candidate,

to seek and hold the

of the Presi(lent of the United

States, and finding for the presidential

Respondent primary

Obama el.Lgible as a candidate

election. Page -2-

2.

SUPREME COURT JURISDICTION. to entErtain

The Supreme pursuant

Court has to O.C.G.A. to the 1983

jurisdiction

this Application

§§ 5-6-35(a) (1) and 21-2-5(e), Constitution Paragraph

as well as pursuant Article

of the State of Georgia,

VI, Section VI, the to Presidential

II, as this case draws into question of O.C.G.A.

constitutionality Preference

§

21-2-5 as applied

Primarie~:, and as this case involves borr Citizen" presidential

the construction

of the ~natural requirement

eligibility 5 of the United this Court's

of Article

II, Section

I, Clause

States Constitution, exclusive 3. appellate

and this case thus falls within jurisdiction.

JUDGMENT 1l,PPEALEDAND DATE OF ENTRY. ~Order Granting was entered

The Superior Barack

Court of Fulton County's Obama's Motion 2012. 4. Respondent Committee STATEMENT

Respondent

to Dismiss"

and filed on March 2,

OF FACTS.

On or before

October

31, 2011,

Barack Obama submitted of the Dem0cratic Democratic on Nov2mber

a letter to the Executive seeking to be listed Primary Ballot. Party

Party of Georgia

on the Georgia Consequently, Chairman

Presidential

Preference

1, 2011, Georgia pursuant

Democratic

Mike Berlon

submitted,

to O.C.G.A. Secretary

§

21-2-193,

the name of Respondent Office as a candidat2

Obama to the Georgia

of State's

to be listed on the Georgia Primary Ballot.

Democratic

Presidential

Prefere~ce

Page -3-

Thereafter, Powell,

pursuant

to O.C.G.A. County,

§

21-2-5(b),

Applicant

a residentJf

Gwinnett

Georgia

and a registered to vote for filed

voter in the State ()f Georgia candidates

and an elector

eligible

for the IJresidency of the United States, timely Sec:retary of State a written challenge

with the Georgia qualifications Presidency Respondent requirement

to the

of REspondent

to seek and hold the Office of the Applicant contended that

of the U~ited

States.

does not meet the "natural born Citizen" of Article II, Section I, Clause

eligibility

5 of the United

States Constitution. As prescribed Secretary b'{ O.C.G.A.

§

21-2-5(b),

the Office of the to an of

of State referred law judge

Applicant's

challenge

administrative

(hereinafter

"ALJ") of the Office "OSAH").

State Administrative pursuant hearing to proper on January

Hearings notice

(hereinafter

Thereafter, a

to all parties,

the ALJ conducted

26, 2012. into the to the

Applicant record, through

was pr"esent at trial and submitted coun~el, evidence and testimony However,

pertaining

issues raised by his challenge. served with a Notice Respondent

despite being timely counsel requiring

to Produce by Applicant's appear

to personally

for trial and to bring with him by Applicant at trial,

certain documents Respondent Likewise,

for use as evidence

failed to appear Respondent's

for trial on January

26, 2012.

attorney

also failed to appear for trial.

Page -4-

No evidence

or testimony

whatsoever

was introduced at trial.

into the

record by or on beh~lf Respondent

of Respondent to appear

The failure of

and his attorney

for trial on January 26, by a January to Georgia

2012 was knowing

and intentional,

as demonstrated attorney

25, 2012 letter written Secretary

by Respondent's

of State Erian P. Kemp evidence

(Exhibit "F"). that Respondent's

Applicant's

at trial established

father, Barack Hussein of Great Britain. Respondent's citizen

Obama, was born in Kenya and was a subject Applicant established that

Additionally,

aforesaid

father, Barack Hussein

Obama, was not a

of the United

States as of the date of birth of

Respondent

in 1961 or at any other time whatsoever.

Nevertheless, Decision

00 February 3, 2012, the ALJ issued an initial
eligible as a candidate to O.C.G.A. for the

finding Res?ondent primary

presidential the ALJ's

election.

Pursuant

§

21-2-5(b),

Decision

was reported

to the Secretary

of State.

Subsequently 5(c), Georgia Decision

on FebrJary Secretary

7, 2012, pursuant

to O.C.G.A.

§

21-2-

of State Brian P. Kemp issued a Final Decision of the ALJ and denying

adopting

th,~ initial

Applicant' s challengl~. On February Applicant timely 15, 2012, pursuant to O.C.G.A.

§

21-2-5(e),

fil(:;d in the Superior

Court of Fulton County a and seeking judicial (Exhibit "B")

"Peti tion For Judicia.l Review"

appealing

review of the Secretilry of State's

Final Decision

Page -5-

Applicant's expedited Georgia

Petition

also requested

that the Court grant an

hearing

ani review of the case due to the fact that the Preference Primary Election was scheduled 6, 2012. to In of

Presidential

take place less than three

(3) weeks later, on March

a further effort to ·Jbtain some action by the Court in advance the election "Motion Decision date, AJplicant then filed, on February

22, 2012, a

For Expedite,j Review or, Alternatively, of Secretary

For Stay of of

of State and For Postponement Primary Election"

Presidential

Prefere~ce

(Exhibit "C") served a in which over the

On February

27, 2012, counsel

for Respondent

"Motion to Dismiss" Respondent

.3nd Brief in Support thereof

argued th.3t the Court lacked jurisdiction

subject matter;

that there was a failure of service of process; Petition failed to state a claim upon which

and that Applicant's

relief could be granted On March

(Exhibit "0"). counsel for Applicant

1, 201.2, the Court notified

by email that, if ApJlicant "Motion mornlng, 16-17). to Dismiss,"

wished to respond

to Respondent's

counsel would have until the following

March 2, 2012 at 9:30 a.m., to do so (Exhibit "E," pp. Counsel for Applicant thereafter submitted to the Court,

by the aforesaid Motion

dea,iline, Applicant's

"Response

to Respondent's

to Dismiss"

(~xhibit "E," p. 14), and the Court of same in an email sent at 8:30 a.m. on the (Exhibit "E," p. 15). Just over two and

acknowledged morning

receipt

of March 2, 2012

Page -6-

one-half

(2~) hours later, the Court emailed Respondent

its file-stamped to Dismiss"

"Order Granting (Exhibit "A,"

Barack Obama's Motion

pp. 1-2).
PART TWO ENUMERATION OF ERRORS

1.

The Superior

Court erred in holding

that O.C.G.A. to the Preference

§

21-

2-5 does not apply in the context qualifications Primary.
2.

of a challenge

of a candidate

in the Presidential

The Superior

Court erred in holding to a challenge

O.C.G.A.

§

21-2-5

unconstitutional of a candidate
3.

as applied

to the qualifications Primary. that Applicant action

in the Presidential

Preference

The Superior

Court erred in holding and in dismissing

failed to perfect

sErvice

Applicant's service.

based upon a finding 4.

of failure to perfect

The Superior

Court erred in failing to reverse the of State on the basis of the

Final Decision ALJ's

of the Secretary

and the Secretary

of State's errors in failing to determine of proof and in failing to challenge.

the proper placement

of the burden

apply such determin2tion
5.

in ruling upon Applicant's

The Superior

Court erred in failing to reverse the of State on the basis of the in finding as "fact"

Final Decision

of tte Secretary

ALJ's and the Secretary that Respondent

of State's errors

was born in the United

States and that

Page -7-

Respondent's

mother

was a citizen of the United birth.

States at the

time of Respondent's
6.

The Superior

Court erred in failing to reverse the of State on the basis of the error in finding that born Citizen" pursuant to

Final Decision

of tte Secretary

ALJ's and the Secretary Respondent Article qualifies

of State's

as a "natural

II of the United

States Constitution,

despite

the fact

that Respondent's

father was not a United birth.
PART THREE

States citizen at the

time of Respondent's

ARGm!IENT AND CITATION

OF AUTHORITY

Applicant 34, concerning provides

would note at the outset that this Court's the standard for granting discretionary

Rule

appeals,

in pertinent

part that "[a]n application [pursuant to] O.C.G.A.

for leave to 5-6-35 shall be error appears is

appeal a final judgment granted,"

§

among other instances,

when " [r]eversible

to exist" or when "[t]he establishment desirable." In the instant

of a precedent

case, as set forth hereinbelow,

the Superior

Court, as well as the ALJ and the Secretary number of reversible errors. Additionally,

of State, made a as this case raises authority and as to

significant

issues regarding

the State of Georgia's

screen the qualifications these issues are certainly

of presidential capable

contenders,

of being raised with regard to

Page -8-

future presidential IS both necessary 1.

candidacies, and desirable.

the establishment

of a precedent

The Superior

Court erred in holding

that O.C.G.A. to the Preference

§

21-

2-5 does not apply in the context of a challenge qualifications Primary. The Superior qualifications Presidential Court held that a.C.G.A. of a candidate in the Presidential

§

21-2-5, the Georgia

chal~_enge statute, PreferE:nce Primary, delegates,

does not apply to the as the Presidential Preference

Primary apportions nomination

but does not result

in the The Court for the

or election

of a presidential

candidate.

also found that Res:pondent is not yet a "candidate" Presidential Primary Election Electic1n, and that the Presidential

Preference of the Georgia

is not an "E!lection" within the meaning Code. In this connection, Respondent

contended

before

the Superior a.C.G.A.

Court t.hat the definition includes general

of "election"

found in but

§

21-2-2(5)

or special elections, in which

not a primary "election"

or special primary

unless the context the inclusion

is used ~clearly

requires"

of a primary

or special primary. The Superior provisions Court and Respondent overlooked, as however, the

of a.C.G.A.

§

21-2-15

inasmuch

This chapter shall apply to any general or special el.ection in this state to fill any federal, ~tate, county, or municipal office,

Page -9-

to any general or special primary to nominate candidate,) for any such office, and to any federal, state, county, or municipal election or primar; for any other purpose whatsoever, unless otherwise provided. Also, the qual:Lfications challenge 5, grants a right t() challenge candidate," the Superior Presidential statute, O.C.G.A. of "any Despite in a by

§

21-2-

the qualifications

regardl(~ss of the specific

type of election. contestants

Court'~3 finding to the contrary, Preference

Primary are specifically O.C.G.A.

designated

statute as "candidates." Respondent

§

21-2-193.

alscl argued in the Court below that a "candidate" by the state executive committee of a see have

must be "certified political O.C.G.A. party"

or must submit "a notice of candidacy," and that neither O.C.G.A. of such conditions

§ 2l-2-5(a),

taken place as to Respondent. however, that a challenge

§

21-2-5 (b) provides, of any candidate of such be

of the qualifications

may be made "at any time prior to the election candidate," and Resrondent's political

party would presumably prior to the general

filing a certification election. "notice Georgia Addition~lly,

of his nomination Applicant

submits that "certified" defined

and

of candidacy" Election

are not specifically

terms in the

Code, and one could argue that the list of Primary candidates party pursuant submitted by 21-2-193

Presidential Respondent's constituted

Preference political

to O.C.G.A.

§

a "certification"

or a "notice of candidacy."

Page -10-

Accordingly, challenge Preference

it is apparent

that the Georgia

qualifications

statute dces, in fact, apply to the Presidential Primary; that the Superior Court did properly Petition; have

subject-matter Superior 2.

juri~:diction of Applicant's reversible

and that the otherwise.

Court committed The Superior

error in holding

Court erred in holding to a challenge

O.C.G.A.

§

21-2-5

unconstitutional of a candidate

as applied

to the qualifications Primary. for lack of argument that

in tbe Presidential

Preference

The Superior subject~matter First

Ccurt also granted dismissal

jurisdiction

based upon Respondent's associational

(and Fourteenth)

Amendment

rights of a right to determine Primary ballot.

political

party give the party the exclusive on its Presidential contended

whom to include

Preference

While Respondert associational situation ballot

that First Amendment in the

rights of a party are "most often litigated" to permit

in which a party refuses

a name on a primary 50 U.S. Cleland,

(citing Democratic

Part V of u.S.

v. Wisconsin,

107, 101 S.

Ct. 101C, 67 L.

Ed. 2d 82 (1981); Duke v.

954 F. 2d 1526 reverse

(lltt Cir. 1992)), he also claimed that "the right

is also true" in that the party has the unchecked certain rames on its primary ballot.

to require however,

Respondent,

cited no a~thority

for the latter proposition. adopted Respondent's of State may not

The Superior argument,

Court essentially

as the Co~rt held that the Secretary

Page -11-

interfere

with a political

party's

determination

of its

candidates, presidential

and the Secretary's elector"s. However,

authority

is limited to examining

none of the cases or statutes are authority for

cited by the Superic1r Court or by Respondent the conclusion associational require that a political right~ deprive party's

constitutional of its ability to

a state government

that candidates requiren~nts

meet constitutional

or statutory on the

eligibility

for office in order to be placed

state ballot. In point of fac:t, O.C.G.A. the Georgia to challenge Secretary

§§

21-2-5(b)

and

(c) authorize elector, of

of State, or an eligible qualifications, to determine

Georgia

a candidate's

and the Secretary whether

State is thereafter is qualified an elector

empowered

the candidate 21-2-5(e) gives

to see~: and hold office. challenging

O.C.G.A.

§

unsucces~fully

a candidate's of State's

qualifications decision County.

the r"ight to appeal the Secretary
2"

by filing

petition

in the Superior

Court of Fulton

Given the ~tate's

right to run its own elections, rights of the Court of

nothing pertaining Respondent's subject-matter Superior

to the associational

politic:al party deprived

the Superior

juriE:diction over Applicant's

case, and the

Court comm~ptted error in holding

otherwise.

Page -12-

3. failed

The Superior to perfect

Court erred in holding

that Applicant action

service and in dismissing to perfect

Applicant's service.

based upon a finding- of failure The Superior properly Applicant

Court also ruled that, even if the Court pursuant to O.C.G.A. personal

had jurisdiction "failed entirely

§

21-2-5,

to perfect by O.C.G.A.

serVlce upon and O.C.G.A.

Respondent(s) 9-11-4.

as required

§

21-2-5(e)

§

The Superior

Court apparently

believed

Applicant's

case

to be subject to dismissal that "service [R]espondent's

for the reason argued by Respondent was made by mailing that personal suit. Public to

of the summons and complaint attorney." Respondent

claimed

service or a waiver However,

thereof was required

for a viable Co. v.

the case of Douqlas Asphalt

Georqia

Service Commission, controlling.

263 Ga. App. 711, 589 S.E. 2d 292

(2003) lS

In Douqlas Asphalt,

the Court held that in an of a state agency or other for judicial review

appeal of an administrative tribunal, personal

decision

~;ervice of the petition

upon the agency was not required, to preserve specifically decision pertinent the jurisdiction

and service by mail was proper The Court from an agency In

of the court.

noted that service of appeals

is governec. by O.C.G.A.

§

5-3-21, which provides of appeal

part that "[a] copy of the notice

shall be

served on all partiE~s in the same manner

prescribed

by Code

Page -13-

Section

5-6-32."

O.C.G.A.

§

5-6-32(a),

in turn, provides

In

pertinent

part that Whenever under this article service or the giving of any notice is required or permitted to be made upon a party and the party is represented by an attorney, the service shall be made upon the attorney unless service upon the party himself is ordered by the court. Service of all notices and other papers hereunder and service of motions for new trial, motions in arrest, motions for judgment notwithstanding the verdict, and all other similar motions, orders, and proceedings may be made by the attorney or party filing the notice or paper, in person or by mail, and proof thereof shown by acknowledgment of the attorney or party served, or by certificate of the attorney, party, or other person perfecting service.

Therefore, Respondent accordance

in the instant

case, service of the Petition was in

upon

Obama by mailing with Georgia law.

same to his attorney

Applicant

further notes, however,

that even if the service valid, O.C.G.A. to perfect

by mail were for any reason not considered 2l(b) states in pertinent

§

5-3-

part that "[f]ailure

service

on any party shall rot work dismissal, shall grant continuances necessary appeal." to permit Dismissal

but the superior

court

and enter such other orders as may be determination of the

a just and expeditious

based upon the issue of service was therefore Court erred to the extent that service.

inappropriate, its dismissal

and the Superior

was bcsed upon failure to perfect

Page -14-

4.

The Superior Court erred in failing

to reverse the

Final Decision of the Secretary of State on the basis of the ALJ's and the Secret,ary of State's errors in failing to determine to

the proper placement, of the burden of proof and in failing

apply such determina,tion in ruling upon Applicant's challenge.
In dismissing Superior Applicant's Petition For Judicial Review, the

Court failed to address

the ALJ's complete

failure to of

make a determinatior, as to the proper placement proof as between apply the burden On January Determination the parties,

of the burden failure to

as well as the ALJ's

of proof to his factual and legal conclusions. 19, 2012, Applicant filed a "Motion For

of Placement

of Burden of Proof" in which he sought 273 Ga. 106, 108-109, to affirmatively 538

an order, pursuant S.E. 2d 430, 433 establish

to Havnes v. Wells, (2C:00), requiring

Respondent

his eligibility motion

for office. in advance

Not only did the ALJ not of trial, as was requested or resolved the

rule on Applicant's by Applicant, motion

but tt.e judge never even addressed

in his final ruling. provides that, with certain shall bear the

OSAH Rule 616-~-2-.07(1) exceptions burden

not appl~_cable herein,
2111

"[t]he agency Further,

of proof in

matters."

OSAH Rule 616-1-2of the hearing,

.07(2) states that, "[p]rior the Administrative requires

to the commencement

Law Judge may determine placement

that law or justice of proof."
Page -15-

a different

of the burden

The challenge initiated of State. pursuant

to Respondent's agency,

qualifications

herein was not

by the applicable Rather,

the Office of the Secretary by Applicant, complaint

the challenge

was commenced

to O.C.G.A.

§

21-2-5(b),

"by filing a written

with the Secretary challenge, procedure, challenge

of State .... "

Upon the filing of Applicant's as a matter of

the Secretary also pursuant

of State was required to O.C.G.A.

§

21-2-5(b),

to refer the

to the OSAH for a hearing. the ALJ, the "agency," i.e. the of

Prior to the trial before Office of the Secretary candidate qualifications;

of State, made no determination issued no decision;

and was not a party been inappropriate suggested must

to the challenge,

and it would have therefore

for the agency to bear the burden by OSAH Rule 616-1-2-.07(1). have been placed ineligible) However, required, regarding

of proof as initially

The burden

of proof therefore

either with Applicant
(i.e.,

(i.e.,

to prove Respondent eligible)

or with Respondent

to prove himself

under HavnE~,

273 Ga. at 108-109, Applicant "to disprove

was not

and should not be required, [Respondent Obama's]

anything

eligibility

to run for office .... "

rd.
The significance of the ALJ's apparent. failure to rule on the burden Respondent and his lawyer and such

of proof is immediately

failed to attend trj.al and failed to offer any evidence, failures were intent:ional, as shown by Respondent's

counsel's

Page -16-

letter of January Applicant Respondent

25, 2012

(Exhibit ~F").

If Respondent

did, as

contends,

bear the burden

of proof at trial, then his burden,

can in no way be said to have satisfied was entitled to judgment.

and Applicant Superior

Thus, the failure of the of State, and the ALJ, on of proof is

Court to reverse the Secretary

the basis of their failure to address the burden reversible 5. error. The Superior Court erred in failing

to reverse

the

Final Decision ALJ's and the

of the Secretary

of State on the basis of the in finding as "fact"

Secre1:~ary

of State's errors

that Respondent Respondent's

was born in the United was a citizen

States and that States at the

mother

of the United

time of Respondent' ~:~irth. b The ALJ's rulirlg, and consequently challenge the Secretary of State's

ruling, on Applicant's relied upon certain ~considered." Respondent Respondent

to Respondent's

qualifications

alleged

~facts" which the ALJ said he 1) that

Spec:Lfically, the ALJ found as ~fact":

Obama was born in the United Obama's rnother was a citizen

States; and 2) that of the United States at

the time of Respond':;nt' birth. s However, burden as se: forth hereinabove, his eligibility Respondent carried the as

of proving

for office.

Inasmuch

Respondent

and his ~ttorney

did not appear and inasmuch

for trial and did not as the ~natural born

offer any evidence

whatsoever,

Page -17-

Citizen"

requirement

for presidential

eligibility

mandates

an of

examination

of Respondent's parents

place of birth and the citizenship at the time of Respondent's Respondent birth

both of Respondent's (as is explained burden

hereinbelow),

failed to carry his

of proof as to his eligibility,

and the above ~facts" The Superior Court's

found by the ALJ were legally unsupported. failure to reverse the Secretary

of State, and the ALJ, with error.

regard to these findings

of ~fact" is reversible

6.

The Superi.or Court erred in failing

to reverse the

Final Decision of tb.e Secretary of State on the basis of the ALJ's and the Secret:.aryof State's error in finding that Respondent qualifies: as a "natural born Citizen" pursuant to Article II of the United States Constitution, despite the fact at the

that Respondent's fc:Lther was not a United States citizen time of Respondent'B birth.
The ALJ's was grounded (and subsequently the Secretary

of State's)

ruling

in the ALJ's adoption

of the non-binding

reasonlng

of the Indiana Court of Appeals 916 N.E. person United

in Ankenv

v. Governor of Indiana,
finding that a

2d 678 (20()9), with regard to the ALJ's as a natural born citizen a United

qualifies

if he was born in the at birth.

States becau~3e he became

States citizen

Although, no evidence his burden

as p()inted out hereinabove,

there was absolutely at trial to carry place of birth,
Page -18-

whatsOe"ler submitted of proof and establish

by Respondent Respondent's

the ALJ's

ruling that a person's confers

birth in the United

States

automatically pursuant

the status of "natural born Citizen" States Constitution of the applicable is law; and

to Article

II of the United statement

unfounded; is contrary

is an incorrect

to the ruling of the United

States Supreme Court in

Minor v. Happersett, 162 (1875). Minor Article is bindirg

88 U.S. 162, 167, 22 L. Ed. 627, 21 Wall.

authority

for the proposition

that the

II phrase

"ratural born Citizen" (2) parents themselves

refers to a person born who were then (at the

in the United

State~: to two

time of the child's birth) Because, as Applicant's Respordent

United

States citizens. at trial States

undisputed Obama's

evidence

demonstrated, citizen

father was not a United birth, Respondent requirement

at the time of Respondent's

does not for the

meet the Article presidency,

II "natural born Citizen"

and the ALJ and the Secretary ottlerwise. The Superior

of State committed Court thus likewise

error in finding committed Secretary

reversible

error in failing to reverse the ALJ and the

of State on this issue.1 CONCLUSION

For the above ~lnd foregoing requests

reasons, Applicant

respectfully For

that the Supreme Court grant this Application

lThis issue will be more fully briefed by Applicant upon the granting ofthis Application For Discretionary Appeal. Page -19-

Discretionary Superior

Appeal

and review and reverse the decision

of the

Court in this case. submitted, this 12th day of March, HATFIELD & HATFIELD, 2012.

Respectfully

P.C.

201 Albany Avenue P.O. Box 1361 Waycross, Georgia (912) 283-3820

31502

Page -20-

CERTIFICATE

OF SERVICE for Applicant, do hereby Application For

I,

J. Mark Hatfield,

Attorney

certify that I have this day served the foregoing Discretionary Appeal upon: Michael K. Jablonski Attorney at Law 2221-0 Peachtree Road NE Atlanta, Georgia 30309
Mr.

Honorable Brian P. Kemp Secretary of State State of Georgia 214 State Capitol Atlanta, Georgia 30334 by placing addressed a copy of same in the United envelope ~rith sufficient delivery, States Mail in a properly affixed thereto in

postage

order to insure proper Jablonski

and by emailing

same to Mr. same

at michae~.4ablonski@comcast.net, Kemp at v:cusso@sos.qa. crO'I. 2012. HATFIELD

and by emailing

to Secretary

This 12th day of March,

& HATFIELD,

P.C.

201 Albany Avenue P.O. Box 1361 Waycross, Georgia (912) 283-3820

31502

Mark Hatfield
From:
Sent: To: White, Connie [Connie.White@fultoncountyga.gov] Friday, March 02,2012 11:04 AM david. is.farrar@gmail.com; codyj udy@hotmail.com; mhatfield@wayxcable.com; van@liberty,egalfoundation.org; michael.jablonski@comcast.com; cale@sos.ga.gov; vrusso@smi.ga.gov; dpwelden@gmail.com Order Granting Respondent Barack Obama's Motion(s) to Dismiss-2012cv211398, 2012cv211~:27, 2012cv211528, 2012cv211537 DOC006.pdf

Subject:

Attachments:

~~.
;, ,~, ,~

,

DOC006.pdf KB)

(563

Hello, Please find attached Motion(s) to Dismiss Wright's office. Thank you, Connie White

a stamp filed copy of the Order Granting Respondent Barack Obama's 2012cv211398, 2012cv211527, 2012cv211528, 2012cv211537 from Judge

PLAINTIFF'S EXHIBIT
,/J

11

\l

1

A
*

IN THE SUPERIOR COURT OF FULTON COUNTY STATE OF GEORGIA FILE NO. 2012 CIVIL ACTION

*

*

* ROTH, LAX, CODY

©@~y(\
FILED IN OFFICE ~

[

MAR 2.1011
CLERK SUPERIOR GA N COUNTY.

_

Ie",
~ ~

DEPUTY

COURT

+

~

* *
FILE NO. 2012CV211527 CIVIL ACTION * CARL SWENSSON

* *
*

* * KEVIN RICHARD POWELL,
FILE NO. 2012CV211528 CIVIL ACTION

*

* *

Farrar; et aI. v. Obama, et al: Civil Action No. 2012CV211398 Civil Action No. 2012CV211527 Powell v. Obama: Civil Action No. 2012CV211528 Welden v. Obama: Civil Action No. 2012CV211537
Swensson v. Obama: ORDER GRANTING MOTION{S) TO DISMISS

Page 1

v.

* DAVID P. WELDEN

FILE NO. 2012CV211537 * CIVIL ACTION

**

* *

ORDER GRANTING l:tESPONDENT BARACK OBAMA'S MOTION(S)

TO DISM1SS

The above-captiolli:.ldactions are before the Court on the Petition(s) for Judicial Review of Petitioners David Farral', et aI., Carl Swensson, Kevin Richard Powell, and David P. Welden, which were filed in this Court on February 13, 2012 and February 15, 2012, respectively. Although initially a.ssigned to four (4) different Superior Court Judges, the matters were transferred to the Honorable Chief Judge Cynthia D. Wright, to whom the flIst-filed case was assigned (Farrar, et al. v, Obama, et al., Civil Action File No. 2012CV211398), because each is an appeal of the same deci1;ionissued on February 3,2012 by Administrative Law Judge Michael M. Malihi in the Office of State Administrative Hearings and thereafter adopted by the Secretary of State. Presently before the Court is the Motion to Dismiss of Respondent Barack Obama, filed in each of the above-refenmced actions on February 27, 2012. The Motion(s) to Dismiss are identical in form and substance and will, therefore, be addressed by the Court in one consolidated Order to be applied in each case. Now, having considered the Motion(s) to

Dismiss, the other pleading!; of record, and applicable Georgia law, the Court fmds as follows: Petitioners filed their AppeallPetition for Judicial Review of the Secretary of State's decision in this Court pursu.mt to O.C.G.A. § 21-2-5(e), which provides as follows:
Farrar, et al. v. Ohama, et al: Civil Action No. 2012CV211398 Swensson V. Obama: Civil Actlon No. 2012CV211527 Powell v. Obama: Civil Action No. 2012CV211528 Welden v. Oboma: Civil Action No. 2012CV211537
ORDER GRANTING MOTION(S) TO DISMISS

Page 2

The elector filing the challenge or the candidate challenged shall have the ri ght to appeal the decision of the Secretary of State by filing a petition in the Superior Court of Fulton County within ten days after the entry of the final decision by the Secretary of State. The filing Df the petition shall not itself stay the decision of the Secretary of State; however, the reviewing court may order a stay upon appropriate terms for good cause shown. As soon as possible after service of the petition, the Secretary of State shall transmit the original or a certified copy of the entire record of the proceedings under revi,;w to the reviewing court. The review shall be conducted by the court without a jury and shall be confined to the record. Petitioners allege that Respondent thus, is not qualified for candidacy Barack Obama is not a "natural born citizen"l and, 2012 Presidential Primary. Despite its

in Georgia's

application in the court beilow, this Court does not believe that O.c.G.A. case because the challenge at issue involves the Presidential Preference

§ 21-2-5 applies in this
Primary, which by its

terms, is an opportunity for electors "to express their preference for one person to be a candidate for nomination."

O.C.G.l~. § 21-2-191.

The Presidential

Preference

Primary

apportions

delegates, but neither elec ts nor nominates candidates for the Presidency. Respondent Barack Obama is not yet a "candidate" for the Presidential

Therefore, because

election in question and

because the Presidential Preference Primary is not an "election" within the meaning of a.C.G.A. § 21-2-1, et seq., O.C.G.A. § 21-2-5 does not apply. See O.c.G.A. § 21-2-2(5) and 21-2-5.

Moreover, it is weB established in Georgia as elsewhere in the United States that voters vote on "presidential electors," rather than voting directly for a candidate, when voting for the The political parties' candidates

Office of President of the United States. O.C.G.A. § 21-2-172.

for President are determined by convention of the political party. See O.C.G.A. §§ 21-2-191 to

I Petitioners claim is based, in pa:i, on a contention that at the time of his birth, Respondent's father was not a citizen ofthe United States.
Farrar, et al. v. Ohama, et al: Civil Action No. 2012CV211398 Swensson v. Ohama: Civil Action No. 2012CV211527 Powell v. abama: Civil Action No. 2012CV211528 Welden v. Ohama: Civil Action No. 2012CV211537
ORDER GRANTING MOTIONI:S) TO DISMISS

Page 3

21-2-200.

In the case of a democratic candidate for President, the Democratic Party of Georgia

has the sale discretion to detennine the qualifications of potential candidates and the name( s) to be included on its Presidential Preference Primary ballot. O.C.G.A. § 21-2-193; see Duke v.

Cleland, 954 F.2d 1523 (] lth Cir. 1992); Duke v. Cleland, 884 F. Supp. 511, 515-16 (N.D. Ga. 1995). The Secretary of State is prohibited by the Fourteenth Amendment Constitution and Georgi;;1 statutory law from infringing of the United States rights of the electors.

on the associationa1

Democratic Party of Georgia and is limited in its authority to examining presidential O.c.G.A.

§§ 21-2-172 to 21-2-200; Duke v. Cleland, 884 F. Supp. at 515-16 (N.D. Ga. 1995). claims are valid, the Secretary of State Id.

Even if the Secretary of State believes that a challenger's

may not interfere with a po litical party's internal decision-making.

Based upon Georgi a law and governing precedent, the Court finds it has no authority to exercise jurisdiction over the Democratic Preference Party of Georgia's Primary selection of the names(s) to be the qualifications of those

included in the Presidental

or to examine

individuals. Therefore, thei::e actions should be DISMISSED 11-12(b). Additionally, matters and provided

in accordance

with O.C.G.A. § 9-

even iif the Court had determined that O.C.G.A. § 21-2-5 applied to these the Court with appellate jurisdiction over same, the Court finds that as required by

Petitioners have failed entirely to perfect personal service upon Respondent(s)

O.c.G.A. § 21-2-5(e) and O.C.G.A § 9-11-4. See Bible v. Bible, 259 Ga. 418, 418 (1989). Therefore, IT IS HEREBY ORDERED AND ADJUDGED that Respondent Barack

Obama's Motion(s) to Dismiss in the above matters are GRANTED, hereby DISMISSED. Farrar, et al. v. Ohama, et al: Civil Action No. 2012CV211398 Swensson v. Ohama: Civil Action No. 2012CV211527
Powell v. Obama: Civil Action No. 2012CV211528 Welden v. Obama: Civil Action No. 2012CV211537 ORDER GRANTING MOTION(S) TO DISMISS

and the above actions are

Page 4

SO ORDERED this the

2nd

day of March, 2012.

c--~~\~
Copies to: Via Email and U.S. Mail:: David Farrar, Pro Se 2059 Cavesprong Road Cedartown, Georgia 30125 david. is. farrar@gmail.com Cody Robert Judy, Pro Se 3031 Ogden Avenue, Suite #2 Ogden, Utah 84403 codviudv@hotmail.com J. Mark Hatfield, Esq. Hatfield & Hatfield, P.c. 201 Albany Avenue P.O. Box 1361 Waycross, Georgia 31502 mhatfield@wayxcable.coln Van R. Irion, Esq. Liberty Legal Foundation 9040 Executive Park Drive: Suite 200 Knoxville, TN 37923 van(@'libertvlegalfoundatioll.org Michael K. Jablonski, Esq. 2221-D Peachtree Road, NE Atlanta, Georgia 30309 michael. iablonski@comca~::t.net

CYNTHIA D. WRIGHT, ChIef Judg~ Fulton County Superior Court Atlanta Judicial Circuit

Farrar, et al. v. abama, et al: ':::ivilAction No. 2012CV211398 Swensson v. Ohama: Civil Action No. 2012CV211527 Powell v. ahama: Civil Action No. 2012CV211528 Welden v. ahoma: Civil Actio 11 No. 2012CV211537
ORDER GRANTING MOTION(S) TO DISMISS

Page 5

Cam-Anh Le, Esq. Vincent Robert Russo, Jr., Esq. Office ofthe Georgia Secretary of State Executive Office 214 State Capitol Atlanta, Georgia 30334 cale@sos.ga.gov vrusso(aJ,sos. ga. gov

David P. Welden, Pro Se 5530 Wright Road Powder Springs, Georgia 30127 dpwelden(W,grnail.com

Farrar, etal. v. Ohama, et al: Civil Action No. 2012CV211398 Swensson v. Ohama: Civil Action No. 2012CV211527 Powell v. Ohama: Civil Action No. 2012CV211528
Welden v. Ohama: Civil Action No. 2012CV211537 ORDER GRANTING MOTIONC::) TO DISMISS

Page 6

Court /ill' Su perior D State Plaintiff(s)
POWELL,
Last

KEVIN RICHARD
First First I. Suffix1 Prefix First Prefix Last Maiden Maiden Middle Middle I. Suffix Prefix

Defendant(s)
OBAMA, BARACK

No. of Defendants D Pro Se

1

Last

First

Middle I.

Suffix

Bar #

337509

Check Primary Type (Che<:konly ONE)

o

If Tort is Case Type: (Check no more than TWO)
D
Auto Accident Other Professional Negligence Premises Liability Liability Medical Malpractice ProductSpecifY

Contract! Account Wills/Estate Real Property Dispossessory/Distress Personal Property Equity Habeas Corpus Appeals, Reviews

o o o
o

D D

o o
~

D

Are Punitive Damages Pleaded? DYes
Post Judgment Garnishment, Other Relief Non-Domestic Contempt Attachment, or

D No

o o

Tort (If tort, fill in right column) Other General Civil Specif)' _, _

o

PLAINTIFF'S

j

b

EXHIBIT 1'15 \

IN THE SUPERIOR COURT OF FULTON COUNTY, GEORGIA
136 PRYOR STREET, ROOM C-I03, ATLANT A, GEORGIA 30303

KEVIN

RICHARD

POWELL

SUMMONS ; C ••• No"

. 'D 201) C~'1)I :52.~

I.

Plaintiff,
VS.

BARACK OBAMA

Defendant

TO THE ABOVE NAMED DEFENDANT(S):

Your are hereby summoned

alld required to file with the Clerk of said Court and serve upon plaintiffs

attorney, whose name and addl"ess is:

J.

MARK HATFIELD HATFIELD & HATFIELD, P.C. 201 ALBANY AVENUE P.O. BOX 1361 WAYCROSS, GEORGIA 31502 (912) 283-3820
served upon you, within 30 days after service of this BY

An answer to the complaint summons DEFAULT

,,vhich is herewith

upon you, exclusivl: of the day of service. IF YOU FAIL TO DO SO, JUDGMENT WILL BE TAKEN AGAINST YOU FOR THE RELIEF DEMANDED

IN THE

COMPLAINTd This

--)_,=.2_----.--

To defendant upon whom this petition is served: This copy of complaint and summons was served upon you , 20 _

Deputy Sherriff

Instructions:

Attach addendum

sheet for additional

parties if needed, make notation on this sheet if addendum

is used

IN THE SUPERIOR

COURT OF FULTON COUNTY

STATE OF GEORGIA KEVIN RICHARD POWELl:.,

* * *
CIVIL No.2 ~ I.. FILE ACTIOr: )/2C/Y21

Petitioner

v.
BARACK OBAMA,

J ~ );32 '1)

* *
P]~TITION FOR .JUDICIAL REVIEW

Respondent

Now comes Petitioner undersigned against counsel,

Kevin Richard

Powell, by and through For Judicial Review

and files this Petition

Respondent

Barack Obama as follows:

1.
This action Secretary Powell's Obama, is an appeal of a Final Decision of Georgia Kevin Richard Barack

of State Brian P. challenge

Kemp denying

Petitioner

to the qualifications candidate,

of Respondent

a presidential

to seek and hold the Office of and finding ~espondent primary Obama

the President eligible

of the United

States,

as a candidate

for the presidential

election.

2.
This Court has jurisdiction O.C.G.A. of this appeal pursuant to

§

21-2-5(e).

3.
Petitioner in Gwinnett Kevin Richard Georgia. Powell is a natural He is a registered person residing

County,

voter in the Page -1-

State of Georgia, candidates presidential

and he is an elector

eligible

to vote for

for the i?residency of the United

States, including herein.

candida.te Barack Obama, the Respondent
4 •

Respondent letter Georgia

Obaln.a,on or before October Committee

31, 2011, submitted Party of

a

to the Executive

of the Democratic

seeking to be listed on the Georgia Preference Primary Ballot. Democratic

Democratic on

Presidential November

Consequently,

1, 2011, Georgia pursuant

Party Chairman Mike Berlon the name of

submitted, Respondent candidate Preference

to O.C.G.A.

§

21-2-193,

to the GE:~orgiaSecretary

of State's Office as a Democratic Presidential

to be list,ed on the Georgia Primary Ballot. 5.

Pursuant

to O.C.G.A. Secretary

§

21-2-5(b),

Petitioner

timely

filed to the of the

with the Georgia qualifications Presidency contended Citizen"

of State a written

challenge

of Respondent

to seek and hold the Office Petitioner's challenge

of the United that Respondent

States.

does not meet the "natural born of Article II, Section I, Clause

eligibility

requirement

5 of the United

States Constitution.
6.

Also pursuant Secretary

to O.C.G.A.

§

21-2-5(b),

the Office

of the for

of State thereafter

referred

Petitioner's

challenge

Page -2-

a hearing

before an administrative Hearings. 7•

law judge of the Office of

State Administrative

Pursuant conducted Michael

to proper

notice

to the parties,

a hearing

was

on January 26, 2012 before Administrative Petitioner was present evidence

Law Judge

M. Malihi.

at trial and submitted and testimony Respondent and

into the record, through pertaining

counsel,

to the iE:sues raised by his challenge. however, did not appear

his attorney, submit

for trial and failed to

any evidence

or testimony

whatsoever.

8.
On February initial Decision, 3, 2012, the administrative a copy of which is attached eligible law judge issued an hereto as Exhibit for the

"A," finding Respondent presidential primary

as a candidate Pursuant

election.

to O.C.G.A. was reported

§

21-2-5(b),

the administrative Secretary of State.

law judge's

Decision

to the

9.
On February Georgia Secretary 7, 2012, pursuant to O.C.G.A.

§

21-2-5(c),

of State Brian P. Kemp issued a Final Decision, hereto as Exhibit "B," adopting the

a copy of which is attached initial Decision

of the administrative

law judge and denying

Petitioner's

challen'je.

Page -3-

10. Pursuant seeks judicial to O.C.G.A.

§

21-2-5(e),

Petitioner of State's

now appeals and Final Decision

revil~w of the Secretary

in this case, and fllrther seeks a reversal Decision, Petitioner conclusions, (a) state; (b) of State; (c) (d) (e) Made upon unlawful Affected Clearly procedures; In excess of the statutory for the rE!aSOn that substantial have beerl prejudiced and decisions because

of that Final rights of the inferences,

the findings,

of the Secretary

of State are: and laws of this

In violati.on of the Constitution

authority

of the Secretary

by other errors of law; erroneous in view of the reliable, and by an abuse probative,

and substantial (f)

evidence

on the whole record;

Arbitrary

~nd capricious

and characterized exercise

of discretion

and a:learly

unwarranted

of discretion.

11.
In particular, specific Decision (a) Secretary grounds Petitioner would enumerate the following Final

for review

of the Secretary

of State's

in this case: The admini:5trative law judge, and consequently of State aciopting the initial a s::_ngle ruling Decision the

of said judge,

erred in issuing

applicable

to the cases of

Page -4-

Page -5-

erred

in failing to make a determination

as to the proper

placement burden

of the bu~den of proof and in failing to apply the factual and legal conclusions the fact that Petitioner in

of proof in~eaching case, despite

Petitioner's

specifically of

filed a pre-trial Burden of Proof"; (e) Secretary erred appear

"l1otion For Determination

of Placement

The admin:_strative law judge, and consequently of State adopting the initial Decision

the

of said judge, failure to

in failing to find Respondent's for trial an event of default

deliberate

and in failing to sustain qualifications on that

Petitioner's independent (f) Secretary erred

challerlge to Respondent's basis;

The administrative of State adopting

law judge, and consequently the initial Decision

the

of said jud~e,

in adopting

the reasoning

of the Indiana Court of Appeals

in Ankenv

v. Governor

of Indiana and in finding that a person born Citizen," pursuant being of to

automatically Article

qualii:ies as a "natural

II of the United

States Constitution,

by merely

born in the United his parents; (g) Secretary

States, without

regard to the citizenship

The administrative of State adopting

law judge, and consequently the initial construe Decision

the

of said judge,

erred in failing to properly States Supreme

the ruling of the United

Court in Minor v. Hapoersett;

Page -6-

(h) Secretary erred

The administrative of State adopting

law judge, and consequently the initial Decision

the

of said judge,

in finding that Respondent pursuant to Article

qualifies

as a "natural born States father was not a birth; and the

Citizen"

II of the United

Consti tution, despi':e the fact that Respondent's United States citizen at the time of Respondent's

(i) Secretary erred Court, finding

The admin:,-strati e law judge, and consequently v of State ildopting the initial Decision at Petitioner's

of said judge, to this a of

in failing

request to certify

for a determination

of appropriate

action including behavior

of contempt,. the facts of the contemptuous (and Respondent's counsel) in knowingly,

Respondent

intentionally, Petitioner's

and deliberately Notice

failing to comply with

to Produce served upon Respondent. 12.

Petitioner expedited

resfectfully

requests

that this Court grant an due to the fact is (3)

hearing

and review of this Petition Presidential Preference

that the Georgia scheduled

Primary Election

to take place on March

6, 2012, less than three

weeks hence. 13. Pursuant respectfully Decision to O.C.G.A. requests

§

21-2-5(e)~

Petitioner

further

that this Court order a stay of the Final of State finding Respondent eligible to

of the Secretary

Page -7-

be included on the::lallot in Georgia presidential Court primary election pending

as a candidate

for the of this

a final judgment

reviewing

said Final Decision. 14.

This Petition entry

is timely

filed within

ten

(10) days after the of State.

of the Final Decision by the Secretary 15. Pursuant to O.(:.G.A.

§

21-2-5(e),

the Secretary

of State, as to

soon as possible transmit entire

after service of this Petition,

is required

to this Court the original

or a certified

copy of the

record of the proceedings

under review. Powell respectfully

WHEREFORE, requests (1)

Petj.tioner Kevin Richard

that this Court: Conduct a hearing and review the record in this case on

an expedited (2) Secretary the ballot election (3) Secretary Article removing Georgia,

basis; a stay of the Final Decision Respondent eligible of the on

Grant Petitioner of State finding in Georgia

to be included

as a candidate

for the presidential

primary

pending

a final judgment

of this Court; the Final Decision of the

Issue an ord~r reversing of State, finding

that Respondent

does not meet the for the presidency, ballot in

II "natural

born Citizen"

requirement

Respondent's and adjudging

name from the presidential Respondent in contempt

of court for his

Page -8-

deliberate

failure to comply with Petitioner's proceedings; and

Notice to Produce

in the administrative (4) deem

Grant such other and further

relief as the Court may

just and prope.r. This 15th day of February, 2012.

HATFIELD

& HATFIELD,

P.C.

201 Albany Avenue P.O. Box 1361 Waycross, Georgia (912) 283-3820

3J.502

Page -9-

OFFICE OF STATE ADMINISTRATIVE ST ATE OF GEORGIA
DA VID FARRAR, LEAH LAX, CODY JUDY, THOMAS MALAREN, LAURIE ROTH, Plaintiffs,

HEARINGS

Docket Number: OSAH-SECST ATE-CE1215136-60-MALIHI Counsel for Plaintiffs: Counsel for Defendant: Orly Taitz Michael Jablonski

v.
BARACK OBAMA, Defendant.

DAVID P. WELDEN, Plaintiff, Docket Number: OSAH-SECST ATE-CE121 5137-60-MALIHI Counsel for Plaintiff: BARACK OBAMA, Counsel for Defendant: Defendant. Michael Jablonski Van R. Irion

v.

CARL SWENSSON, Plaintiff,
v.

Docket Number: OSAH-SECSTATE-CE1216218-60-MALIHI Counsel for Plaintiff: J. Mark Hatfield Michael Jablonski

BARACK OBAMA, Counsel for Defendant: Defendant.

KEVIN RICHARD POWELL, Plaintiff, Docket Number: OSAH-SECST ATE-CE1216823-60-MALIHI Counsel for Plaintiff: BARACK OBAMA, Counsel for Defendant: Defendant. Michael Jablonski

v. J. Mark Hatfield

'.,PLAINTIFF'S

j ,', "'~~~!BIT "

DECISION

I

Plaintiffs allege that Defendant President Barack Obama does not meet Georgia's eligibility requirements £Dr candidacy in Georgia's 2012 presidential primary election.

Georgia law mandates thd candidates meet constitutional and statutory requirements for the office that they seek. O.C.G.A. § 21-2-5(a). Mr. Obama is a candidate for federal

office who has been certified by the state executive committee of a political party, and therefore must, under Georgia Code Section 21-2-5, meet the constitutional and statutory qualifications for holding the Office of the President of the United States. States Constitution requin;:s that a President be a "natural bom [c]itizen." II, § 1, d. 5. As required by GeDrgia Law, Secretary of State Brian Kemp referred Plaintiffs' challenges to this Court fi)r a hearing. O.c.G.A. § 21-2-5(b). A hearing was held on

ld.

The United

U.S. Const. art.

January 26, 2012 .. The record closed on February 1,2012.

Plaintiffs Farrar, Lax, Judy,

Ma1aren, and Roth and their counsel Orly Taitz, Plaintiffs Carl Swensson and Kevin Richard Powell and their counsel J. Mark Hatfield, and Plaintiff David P. Welden and his counsel Van R. Irion, all appeared and answered the call of the case. However, neither Defendant nor his counsel, Michael Jablonski, appeared or answered. Ordinarily, the

Court would enter a defaul t order against a party that fails to participate in any stage of a proceeding. Ga. Compo R.

& Regs. 616-1-2-.30(1) and (5). Nonetheless, despite the

I This Decision has been consolidated to include the four challenges to President Obama's candidacy filed by Plaintiffs David farrar, et at., David P. Welden, Carl Swensson, and Kevin Richard Powell. Section I of this Decision applies only to the case presented by Ms. Tailz on behalf ofMr. Farrar and his co-plaintiffs, Leah Lax., Cody Judy, Thomas Malaren, and Laurie Roth, and does not pertain, in any way, to the cases of Mr. Welden, Mr. Swensson, and Mr. PowelL Section II applies to all Plaintiffs.

2

Defendant's

failure to appear, Plaintiffs asked this Court to decide the case on the merits

of their arguments and evi dence. The Court granted Plaintiffs' request. By deciding this matter on the merits, the Court in no way condones the conduct or legal scholarship of Defendant's attorney, Mr. Jablonski. This Decision is entirely

based on the law, as well as the evidence and legal arguments presented at the hearing.

3

I.

Evidentiary Arguments of Plaintiffs Farrar, et al.
Plaintiffs Farrar, Lax, Judy, Malaren, and Roth contend that President Barack

Obama is not a natural born citizen. To support this contention, Plaintiffs assert that Mr. Obama maintains a fraudulently obtained social security number, a Hawaiian birth

certificate that is a computer-generated

forgery, and that he does not otherwise possess

valid U.S. identification papers. Further, Plaintiffs submit that Mr. Obama has previously held Indonesian citizenship, and he did not use his legal name on his notice of candidacy, which is either Barry Soetoro or Barack Obama Soebarkah. (Pl.s' Am. Compl. 3.)

At the hearing, Plaintiffs presented the testimony of eight witnesses2 and seven exhibits in support of the:ir position. (Exs. P-I through P-7.) When considering the

testimony and exhibits, this Court applies the same rules of evidence that apply to civil nonjury cases in superior court. Ga. Compo R. & Regs. 616-1-2-.18(1)-(9). The weight

to be given to any evidence shall be determined by the Court based upon its reliability and probative value. Ga. Compo R.

& Regs.

616-1-2-.18(10).

The Court finds the testimony of the witnesses, as well as the exhibits tendered, to be of little, if any, probative allegations.3 Ms. Taitz value, and thus wholly insufficient to solicit expert testimony to support Plaintiffs' from several of the

attempted

witnesses without qualifyirlg or tendering the witnesses as experts. See Stephens v. State, 219 Ga. App. 881 (1996) [the unqualified testimony of the witness was not competent evidence). For example, two of Plaintiffs' witnesses testified that Mr. Obama's birth

Originally, Ms. Taitz indicat~:d to the Court that she would offer the testimony of seven witnesses. However, during her closing argllment, Ms. Taitz requested to testify. Ms. Taitz was sworn and began her testimony, but shortly thereafte1'.,the Court requested that Ms. Tatiz step-down and submit any further testimony in writing.
2

) The credibility of witnesses i!; within the sole discretion of the trier of fact. In non-jury cases that discretion lies with the judge. See Mustang Tramp .. Inc. l'. fr. fV Lowe & Sons, Inc., 123 Ga. App. 350, 352 (1971).

4

certificate was forged, but neither witness was properly qualified or tendered as an expert in birth records, forged documents or document manipulation. Another witness testified that she has concluded that the social security number Mr. Obama uses is fraudulent; however, her investigatory methods and her sources of information were not properly presented, and she was never qualified or tendered as an expert in social security fraud, or fraud investigations in gl~neral. Accordingly, the Court cannot make an objective threshold determination oCthese witnesses' testimony without adequate knowledge of their qualifications. See Rnudsen l'. Dl~Uee-Freeman. Inc., 95 Ga. App. 872 (1957) (for the testimony of an expert witness to be received, his or her qualifications as such must be first proved). None of the testifying witnesses provided persuasive testimony. Moreover, the Court finds that none of tile written submissions tendered by Plaintiffs have probative value. Given the unsatisfaGtoryevidence presented by the Plaintiffs, the Court concludes that Plaintiffs' claims are not persuasive.

5

II,

Application of tht:~"Natural Born Citizen" Requirement

Plaintiffs allege th,1tPresident Barack Obama is not a natural born citizen of the United States and, therefDre, is not eligible to run in Georgia's presidential primary election. As indicated supra, the United States Constitution states that ,,[n]o person except a natural born Citizen ... shall be eligible for the Office of the President ... U.S. Canst. art. II, § I,

:4

d. 5.

For the purpose of this section's analysis, the following facts are considered: I) Mr. Obama was born in the United States; 2) Mr. Obama's mother was a citizen of the United States at the time of his birth; and 3) Mr. Obama's father was never a United States citizen. Plaintiffs c{mtendthat, because his father was not aU .S. citizen at the time of his birth, Mr. Obama is constitutionally ineligible for the Office of the President of the United States. The Court does not agree. In 2009, the Indiana Court of Appeals ("Indiana Court") addressed facts and issues similar to those befi)re this Court. Arkeny v. Governor, 916 N.E.2d 678 (Ind. Ct. App. 2009). In Arkeny, thl~plaintiffs sought to prevent certification of Mr. Obama as an eligible candidate for president because he is not a natural born citizen. fd. at 681. The plaintiffs argued, as the Plaintiffs argue before this Court, that "there's a very clear distinction between a 'citizen of the United States' and a 'natural born Citizen,' and the difference involves having [two] parents of U.S. citizenship, owing no foreign allegiance." ld. at 685. The Indiana Court rejected the arb'llment that Mr. Obama was

4 The definition of this clause Ilas been the source of much debate. See, e.g., Gordon, Who Can Be President of the United States: nIl' Unresolved Enigma, 28 Md. L. Rev. 1 (1968); Jill A. Pryor, Note, The Natural-Born Citizen Clause and Presidential Eligibility: An Approach for Resoh-ing Two Hundred Years or Uncertainty, 97 Yale L.J. 881 (1988); Christina S. Lohman, Presidential Eligibility: The Meaning of the Natural-Born Citizen Clause. .16 GOIlL L. Rev. 349 (2000); William T. Han, Bl~yond Presidential Eligibility: The Natural Born Clrizen Clause as a Source (if Birthright Citizenship,58 Drake L. Rev. 457

(2010).

6

ineligible, stating that children born within the United States are natural born citizens, regardless of the citizenship of their parents. and analysis ofArkeny persuasive. The Indiana Court began its analysis by attempting to ascertain the definition of "natural born citizen" because the Constitution does not define the term. ld. at 685-86; See Minor v. Happersett, 88 U.S. 162, 167 (1875) ("The Constitution does not, in words, say who shall be natural born citizens. Resort must be had elsewhere to ascertain that:'); see also United States v. Wong Kim Ark, 169 U.S. 649 (1898) (noting that the only mention of the term "natural born citizen" in the Constitution is in Article is not defined in the Constitution). The Indiana Coulil first explained that the U.S. Supreme Court has read the Id. at 688. This Court finds the decision

II, and the term

Fourteenth Amendment and Article II (natural born citizen provision) in tandem and held that "new citizens may be born or they may be created by naturalization."

ld. at 685

(citing Minor, 88 U.S. at 167); See U.S. Const. amend. XIV, § 1. ("All persons born or naturalized in the United States and subject to the jurisdiction thereof, are citizens of the United States .... "). In Minor, the Court observed that: At common-law, with the nomenclature of which the framers of the Constitution were f::uniliar, it was never doubted that all children born in a country of parents who were its citizens became themselves, upon their birth, citizens also. These were natives, or natural-born citizens, as distinguished from aliens or foreigners. Some authorities go further and include as citizens I~hildren born within the jurisdiction without reference to the citizenship of their parents. As to this class there have been doubts, but never as to the first. For the purposes of this case it is not necessary to solve these doubts. !d. at 167-68. Plaintiffs ask this Court to read the Supreme Court's decision in Minor as defining natural born citizens as only "children born in a country of parents who were its

7

citizens:' 88 U.S. at 167. However, the Indiana Court explains that Minor did not define the term natural born citiizen. In deciding whether a woman was eligible to vote, the
Minor Court merely conduded that children born in a country of parents who were its

citizens would qualifY as natural born, and this Court agrees. The Minor Court left open the issue of whether a child born within the United States of alien parent(s) is a natural born citizen. Next, the Indiana Court looked to United States v. Wong Kim Ark, in which the Supreme Court analyzed tile meaning of the words "citizen of the United States" in the Fourteenth Amendment and "natural born citizen of the United States" in Article II to determine whether a ehild born in the United States to parents who, at the time of the child's birth, were subject~;of China "becomes at the time of his birth a citizen of the United States, by virtue of the first clause of the fourteenth amendment .... " !d. at 686 (citing rVong Kim Ark, 169 U.S. at 653). The Indiana Court determined that the two provisions "must be interprl~tedin the light ofthe common law, the principles and history of which were familiarly known to the framers of the constitution." Id. (citing Wong Kim
Ark, 169 U.S. at 654).

The Indiana Court agreed that ··[t]he interpretation of the

constitution of the United States is necessarily influenced by the fact that its provisions are framed in the language
'Jf

the English common law, and are to be read in the light of

its history." !d. (citing Wong Kim Ark, 169 U.S. at 655) (internal citation omitted). The
Wong Kim Ark Court exten sively examined the common law of England in its decision

and concluded that Wong J.;;jmArk, who was born in the United States to alien parents,

8

became a citizen of the United States at the time of his birth.5 Wong Kim Ark, 169 U.S. at 705.

5

The Wong Kim Ark Court explained: The fundamental principle of the common law with regard to English nationality was birth within the allegiance. also c:aUed "ligealty," "obedience," "faith" or "power," of the King. The principle embraced all persons born within the King's allegiance and subject to his protection. Such allegiance and protection were mutual ... and were not restricted to natural-born subject') and naturalized sul:Uects, or to those who had taken an oath of allegiance; but were predicable of aliens in ami':y, so long as they were within the kingdom. Children, born in England, of such aliens, were therefore natural-born subjects. But the children, born within the realm, of foreign amba~;sadors, or the children of alien enemies, born during and within their hostile occupation of part of the King's dominions, were not natural-born subjects, because not born within thf~ allegiance, the obedience, or the power, or, as would be said at this day, within the jurisdiction of the King.

169 U.S. at 655. It thus clearly appears that by the law of England it)r the last three centuries, beginning betl1re the settlement of this country, and continuing to the present day, aliens, while residing in the dominions possessed by the Crown of England. were within the allegiance, the obedience. the faith or loyalty, the protection, the power, the jurisdiction, of the English Sovereign; and therefore every child born in England of alien parents was a natural-born subject, unless the child of an ambassador or other diplomatic agent of a foreign State. or of an alien enemy in hostile occupation of the plai:e where the child was born. [d. at 658. Further: Nothing is better settled at tLe common law than the doctrine that the children, even of aliens, born in a country, while the :Jarents are resident there under tlle protection of the government, and owing a temporary allegiance thereto, are subjects by birth. 1£1.at 660 (quoting Inglis v. Trw·tees o./Sailors· concurring». And: The first section of the citizen.' It thus assumes of the constitution was this country at the time place of birth. Snug Harbor, 28 U.S. (3 Pet.) 99,164 (1830) (Story, J .•

seccnd article of the constitution uses the language, 'a natural-born that ,:itizenship may be acquired by birth. Undoubtedly, this language used in reference to that principle of public law. well understood in of the adoption of the constitution, which referred citizenship to the

1£1.at 662 (quoting Dred Scot! v. Sanford, Finally:

60 U.S. (19 How.) 393, 576 (1856) (Curtis, J., dissenting».

All persons born in the allegimce of the king are natural-born subjects, and all persons born in tlle allegiance of the United~;tates are natural-born citizens. Birth and allegiance go together. Such is the rule of the common law, and it is the common law of this country, as well as of England.

Id. at 662-63 (quoting United States

1'.

Rhodes, (1866) (Mr. Justice Swayne». 9

••··••••···ft •.__

·_····_··_··

Relying on the language

of the Constitution

and the historical

reviews

and

analyses of Minor and Wong Kim Ark, the indiana Court concluded that persons born with in the borders of the United States are "natural born citizens" for Artide II, Section 1 purposes, regardless of the citizenship of their parents. Just as a person "born within the British dominions [was) a natural-born Briti~:h subject" at the time of the framing of the U.S. Constitution, so too were those "born in the allegiance of the United States [] natural-born citizens." 916 N.E.2d at 688. The Indiana Court determined that a person qualifies as a natural born citizen if he was born in the United States because he became a United States citizen at birth.6 For the purposes (If this analysis, this Court considered that President Obama was born in the United States. Barack

Therefore, as discussed in Arkcny, he became a

citizen at birth and is a natural born citizen. Accordingly, CONCLUSION President Barack Obama is eligible as a candidate for the presidential election under a.C.G.A. primary

§ ::.1-2-5(b).

SO ORDERED, February

::;rd,

2012.

;\

~J~J~.,V~
MICHAEL M. MALIHI, Judge
This Court recognizes that the U'ong Kim Ark case was not deciding the meaning or"natural born citizen" for the purposes of detennining rresidential qualifications; however, this Court finds the Indiana Court's analysis and reliance on these cas~:sto be persuasive.
6

10

IN THE OFFICE OF THE SECRETARY OF STATE STATE OF GEORGIA
DAVID FARRAR, LEAH LAX, CODY .JUDY, THOMAS MALAREN, I,AIJRI.E: ROTH, Docket Number: OSAH-SECSTAT.E:CE-1215136-60- MALUII Petitioners,
v.

Counsel for Petitioners: Orly Taitz Counsel for Respondent: Michael.Jablonski

BARACK OBAMA, ResJlondent.

DA VID P. WELDON, Petitioner,
v.

Docket Number: OSAH-SECSTATECE-1215137-60- MAUHI Counsel for Petitioners: Van R. Irion Counsel for Respolldent: Michael Jablonski

BARACK OBAMA, Respondent.

CARL SWENSSON, Petitioner,
v.

Docket Number: OSAH-SECSTATECE-1216218-60- MAUHI Counsel for Petitioners: Counsel for Respondent: J. Mark Hatfield Michael Jablonski

BARACK OBAMA, Respondent.

KEVIN RICHARD POWEU .., Petitioner,
v.

Docket Number: OSAH-SECST ATECE-1216823-60- MAUHI Counsel for Petitioners: Counsel for Respondent: J. Mark Hatfield Mich~lel Jablonski

BARACK OBA~fA. Respondent.

PLAINTIFF'S

11'8" ,,'

""', .EXHIBIT

FINAL DECISION1
Petitioners filed candidate challenges pursuant to O.C.G.A.
§

21-2-5(b) contending that

Respondent docs not meet be State of Georgiats eligibility requirements for his name to be listed on the 2012 Presidential Preference Primary ballot. Judge ("AU") for the Officl~ of State Administrative Judge Michael Malihi, Administrative Law

Hearings, held a hearing on each candidate eases on

challenge on January 26, 2012 and entered an initial decision for the above-captioned February 3,2012. final decision. Thel'efore, DENIED. SO DECIDED this ~;~ day of Fcbmary, 2012. IT IS HEREBY DECIDED THAT the above-captioned

The Secretary of State formally adopts the initial decision of the ALJ into this

challenges

are

. ~ '-fP. KEMP

~ '~L.

~

Georgia Secretary of State

I Judge Michae1Malihi previously C Dnsolidatcd the above-captioned candidate challenges for the purpose of issuing his initial decision. Those candidatl:' challenges remain consolidated for the purpose of issuing this Final Decision.

CERTIFICATE I, J. Mark Hatfield, certify Petition Attorney

OF SERVICE for Petitioner, do hereby Summons and

that I have this day served the foregoing For Judicial Review and attachments

thereto upon:

Mr. Michael K. Jablonski Attorney at Law 260 Brighton Road NE Atlanta, Georgia 30309-1523 Honorable Brian P. Kemp Secretary of State State of Georgia 214 State Capitol Atlanta, Georgia 30334 Honorable Michael M. Malihi Administrative Law Judge Office of State Administrative 230 Peachtree Street NW Suite 850 Atlanta, Georgia 30303 by placing addressed a copy of same in the United envelope with sufficient

Hearings

States Mail in a properly affixed thereto in

postage

order to insure proper d~livery, Jablonski Secretary

and by emailing

same to Mr. same to

at michael.4ablonski@comcast.net, Kemp at vrJsso@sos.oa.oov, at kbeal@osah.oa.aov. 2012.

by emailing

and by emailing

same to

Judge Malihi

This 15th day of February,

201 Albany Avenue P.O. Box 1361 Waycross, Georgia (912) 283-3820

31:102

IN THEi,: SUPERIOR

COURT OF FULTON COUNTY

STATE OF GEORGIA KEVIN RICHARD POWELl., Petitioner V. BARACK OBAMA,

*
* *
CIVIL ACTION FILE NO. 2012CV211528

I L_

~~;;
DEPUTY CLERK SUPERIOR COURl Fl(LTON COUNTY, GA ~

~

* *

Respondent

MOTION FOR, EXPEDITED REVIEW OR, ALTERNATIVELY, FOR STAY OF :DECISION OF SECRETARY OF STATE AND FOR POSTPONEMENT OF, PRESIDENTIAL PREFERENCE PRIMARY ELECTION Now comes Petitioner undersigned counsel, Kevin Richard Powell, by and through review

and moves

the Court for an expedited proceeding or, in the

of the above-captioned alternative, Secretary

appellate

for a stay of the Final Decision

of the Georgia of the Georgia

of State herein Preference

and for a postponement Election,

Presidential Motion,

Primary

and in support of this

Petitioner

shows to the Court the following:

1.
This action Secretary Powell's Obama, is ~n appeal of a Final Decision of Georgia Kevin Richard Barack

of State Brian P. challenge

Kemp denying

Petitioner

to the qualifications candidate,

of Respondent

a presidential

to seek and hold the Office of and finding Respondent primary Obama

the President eligible

of the United

States,

as a candidate

for the presidential

election.

Page -1-

PLAINTIFF'S EXHIBIT

I/c.~

2.

The Georgia scheduled

Presidential

Preference

Primary Election

is

to take place on March

6, 2012, only two

(2) weeks from

the date of this Motion.

3.
O.C.G.A. appellate State

§

21-2-5(e)

guarantees

Petitioner

the right to of

review of the adverse

decision

of the Secretary

in this matte:[. 4. Petitioner's aI~eal involves, among other issues, a law, i.e. whether or not

s~gnificant Respondent, United

issue of constitutional

whose fa.ther was a foreign national meets the "natural

and never a

States citizen,

born Citizen" I, Clause 5 of the

eligibility United

requirerr~nt of Article

II, Section

States Constitution.

5.
Unless this Court grants expedited Court State review, or unless this of the Secretary of

orders a stay of the Final Decision and a postponement Election pending of the Georgia

Presidential

Preference

Primary

a final judgment

of this Court, action is moot Preference Primary

Respondent

will likely claim that Petitioner's of the Georgia ~etitioner Presidential

after the holding Election.

Although

would disagree, nevertheless

and does disagree, Petitioner

with any such claim by Respondent,

Page -2-

anticipates

that Respondent

would probably

make such an argument of this appeal.

in an effort to avoid a decision

on the merits

6.
With regard to Petitioner's of this appeal, Petitioner 6.7 request for an expedited Superior review

shows that Uniform that

Court Rule

("Motions in em(~rgencies.") provides

Upon written nc)tice and good cause shown, the assigned judge may shorten or waive the time requirement applicable to emergency motions, except motions for summary judgment, or grant an immediate hearing on any matter requiring such expedited procE!dure. The motion shall set forth in detail the necessity i"or such expedited procedure. 7. In connection with Petitioner's alternative request for a

stay of the Final Decision herein

of the Georgia

Secretary

of State

and for a postponement Primary Election, 21-2-5(e),

of the Georgia Petitioner

Presidential to

Preference
O.C.G.A.

shows that pursuant

§

while "[t]he filing of the petition of the Secretary of Stater,]

shall ...the

not itself stay the jecision reviewing court may
Jrder

a stay upon appropriate

terms for good to court

cause shown." appeals

Furth<~r, O.C.G.A.

§

5-3-28(b),

applicable

to superior

I:ourt, provides

that "[t]he superior

may issue such order:3 and writs as may be necessary jurisdiction on appea.l."
8 .

in aid of its

Petitioner

subm:.ts that, in order that Petitioner of State's Final Decision

may secure to which Page -3-

the review of the Secretary

Petitioner significant

is entitled

by Georgia

law, and in order that the interpretation raised by adjudicated,

issue of constitutional

Petitioner's

action may be finally and decisively review

this Court should g.rant expedited or, in the alternative, Final Decision postponement Election

of the instant appeal

the Court should grant a stay of the Secretary of State herein and a Preference Primary

of the Georgia

of the Georgia

Presidential

currently

~;cheduled for March

6, 2012. Powell respectfully requested by Petitioner

WHEREFORE, requests herein.

Petitioner

Kevin Richard

that this Court grant the relief

This 21st day of February,

2012. & HATFIELD, P.C.

HATFIELD

rk Hatfierd Atbdrney Bar No. 3~7###BOT_TEXT###9 for Pet1t\oner Georgia 201 Albany Avenue P.O. Box 1361 Waycross, Georgia (912) 283-3820

31502

Page -4-

CERTIFICATE

OF SERVICE

I, J. Mark Hatfield, Attorney for Petitioner, do hereby
certify that I have this day served the foregoing Motion Review or( Alternatively, For Stay of Decision of Presidential For of

Expedited Secretary Preference

of State and For Postponement Primary Election upon:

Mr. Michael K. Jablonski Attorney at Law 260 Brighton Road NE Atlanta, Georgia 30309-1523

Honorable Brian P. Kemp Secretary of State State of Georgia 214 State Capitol Atlanta, Georgia 30334 by placing addressed a copy of same in the United envelope with sufficient delivery, States Mail in a properly affixed thereto in

postage

order to insure prop~r Jablonski

and by emailing

same to Mr. same

at michael.4ablonski@comcast.net Kemp at vrusso@sos.aa.gov. 2012.

and by emailing

to Secretary

This 21st day o~ February,

HATFIELD

& HATFIELD,

P.C.

201 Albany Avenue P.O. Box 1361 Waycross, Georgia (912) 283-3820

31502

IN THE: SUPERIOR

COURT OF FULTON COUNTY STATE OF GEORGIA

KEVIN RICHARD POWELL, Petitioner, vs. BARACKOBAMA, Respondent MOTION TO DISMISS Respondent moves t his Court for an order dismissing the petition as follows: 1. This Court :I acks jurisdiction over the subject matter. O.C.G.A. § 9-1112(b)(1). 2. Failure of service of process. O.C.G.A. § 9-11-12(b)(5). 3. Failure to state a claim upon which relief can be granted. O.C.G.A. § 911-12(b)(6). Argument in favor of the motion to dismiss is set forth in the accompanying brief. Respectfully submitted, This 27th day of February, 2012. Civil Action File Number 2012 CV 211528

MICHAEL JABLONSKI Georgia State Bar Number 385850
2221-D Peachtree Road NE

Atlanta, Georgia 30309

404-290-2977
michael.jablonski@cClmcast.net
PLAINTIFF'S EXHIBIT 'I ,\ =--r2

CERTIFICATE OF SERVICE I hereby certify that I have this day served the foregoing pleading upon Mr, Mark Hatfield Attorney at Law 201 Albany Avenue P.O. Box 1361 Waycross, Georgia 31502 by statutory electronic service pursuant to O.C.G.A. § 9-11-5(e) using the email address mhatfleld@wayxcable.com, This 27th day of February,
::2.012.

MICHAEL JABLONSKI Georgia State Bar Number ~:5850 2221-D Peachtree Road NE Atlanta, Georgia 30309 404 -290-2977 michael.jablo nskifcDco mcast.net

IN THE SUPERIOR COURT OF FULTON COUNTY STATE OF GEORGIA

KEVIN RICHARD POWELL, Petitioner, vs. BARACK OBAMA Respondent Civil Action File Number 2012 CV 211528

Brief in ~:~upportof Respondent's Motion to Dismiss

The appeal from the Secretary of State's decision finding that President Obama is qualified to appear on the Presidential Preference Primary ballot is one in a long line of persistent challenges filed across the country since 2008. Not a single challenge has ever been upheld.!

See, Georgia cases: RhodeB v. MacDonald, 670 F. Supp.2d 1363 (M.D. Ga. 2009), affd, 2010 WL 892848 (11th Cir. March 15, 2010) cert. denied, 129 S. Ct. 2830 (2009); Terry v. Handel, 08CV158774S (Superior Court Fulton County, 2008), appeal dismissed, No. S09D0284 (Ga. Supreme Court), reconsideration denied, No. S09A1373; Cook v. Good et aI, 4:2009cvoo082, 2009 WL 2163535 (M.D. Ga. July 16, 2008).
1..

Federal cases: Allen v. Soetoro, 4:09-cv-00373, 2011 WL 2130589, (D. Ariz. May, 2010); In re: American Grand Jur!/, 3:09mc00215(USDC Tenn., 2009); Keyes v. Obama, 8:09-cv-00082, 2009 WL 3861788, (U.S.D.C.D. Cal. Oct. 29, 2009), appeal pending, No. 10-55084 (9th Cir., 2011); Berg v. Obama et aI, 574 F.Supp.2d 509 (E.D.Pa. 2008), affd, 586 F.3rd 234 (3rd Cir. 2009), Cert. denied, 129 S. Ct. 1030 (2009); Berg v. Obama, 656 F. Supp.2d. 10'7CD.D.C.Cir. 2009); Beverly v. Federal Elections Commission, 09-15562 (KD. Cal., 2008), affdo9-15562 (9th Cir., 2009), cert. denied, 130 S. Ct. 1732 (2010); Bowhall v. Obama, 2:10cvo0609, 2010 WL 4932747, (M.D. Ala. November 30,2010); The Church of Jesus Christ Christian/Aryan Nations of Missouri et al v. Obama et aI, 6:08cv03405, 2011 WL 4916569 (W.D. Mo. Oct. 17, 2011); Cohen v. Obama, 1:08cv02150, 2008 WL 5191864 (D.D.C., Dec. 11,2008), aff'd, 2009 WL

2870668 (D.C. Cir. 2008); Cook v. Good et aI, 4:2009cvoo082, 2009 WL 2163535, (M.D. Ga. July 16,2008); Cook v. Simtechn 8:2009cV01382 (M.D. Fla., 2009); Craig v. U.s., 5:09-cv-00343 (W.D. Okla., 2009), cert. denied, 130 S. Ct. 141 (2009); Craig v. U.S., 5:09-CV-01345-C (W.D. Okla., 2010); Dawson v. Obama, 2:08cv02754, 2009 WL 532617 (E.n. Cal. March 2,2009); Ealey v. Sarah Obama, 4:08-mc-00504 (S.D.Tex., 2008); Essek v. Obama, OS-379-GFVT (E.D. Ky., 2008); Hamblin v. Obama, 2:09cV00410, 2009 WL 2513986 (D. Ariz. Aug. 14,2009); Hamrick v. Fukino, 1:08-cv00544, 2009 WL 1404535 (Haw., May 20, 2009); Herbert v. Obama, 3:08-cv-01164HES- TEM (M.D. Fla., 2008), cert. denied, 130 S. Ct. 562 (2009); Herbert v. US, 3:08cv-00634-TJC-MCR (M.D,Fla., 2008); Herbert v. US, 3:08cv01201, 2009 WL 129585, (S.D.Cal., Jan. 15, 2009); Hollander v. McCain, 566 F. Supp.2d 63 (D.N.H. 2008); Hollister v. Soetoro, 601 F, Supp.2d 179 (D.D.C. Cir. 2009), cert. denied, 131 S. Ct. 1017 (2011); Hunter v. U.S. Supreme Court, 2:08cv00232, 2009 WL 111683, (N.D.Tex., Jan. 16,2009), appeal dismissed, No. 09-10246, No. 10-10009, No. 10-100064 (5th Cir., 2009); Jones v. Obama, 2:10-CV-01075 (C.D. Cal., 2010); Judy v. McCain, 2:08cV01162 (USDC Nev., 2008); Kerchner v. Obama, 612 F.3d 204 (D.N.J. 2010), cert. denied, 131 S. Ct. 663 (2010); Liberty I,egal Foundation v. DNC, CH-11-1757 (D Ariz., 2011); Mackay v. Obama, 2:11-CV"05458-JP (E.D. Pa., 2011), voluntarily dismissed, No. 113862 (USDC Pa., 2011); McLanahan v. Obama, 2:11-CV-00374-EFS (D.Was., 2011); Morrow v. Barak Humane Obama, 1:08-cv-22345 (S.D. Fla., 200B); Neely v. Obama, 2:oB-cV-15243 (E.D.MI., 200B); Patriot's Heart Network v. Soetoro, 1:09-mc-00442RCL (D.D.C., 2009); In Re Paul Andrew Mitchell, 2:oB-cv-04083 (E.D. PA, 200B),affd 304 Fed. Appx 113, 200B vVL53B1436 (3rd Cir., 200B), mandamus denied, No. oB4443 (3d Cir., 2008); Purpura v. Sebelius, 3:1O-CV-04B14,2011WL 154776B, (D.N.J. Apr. 21, 2011); Rhodes v. Gates, 5:09-,cv-00703-XR (W.D.Tex., 2009); Rhodes v. MacDonald, 670 F. Supp.2d 1363 (M.D. Ga. 2009), affd, 2010 WL 892848 ( 11th Cir. March 15, 2010) cert. denied, 129 S. Ct. 2B30 (2009); Robinson v. Bowen, 567 F.SUpp.2d 1144 (N.D.Cal. 2008); Roy v. Fed. Election, 2:08cvOI519, 2008 WL 4921263, (W.D. Wa. Nov. 14, 200B); Stamper v. US, l:oB CV 2593, 2008 WL 4838073 (N.D.OH. 2008); Strunk v. Patterson, 1:oBcv042B9 (E.D.N.Y., 200B), appeal dismissed No. oB5422 (2d Cir. Nov. 14, 2008); Strunk v. U.S. Dept. of State, 693 F.SUpp.2d 112 (D.D.C. Cir. 2010), mandamus den l'ed, No. 09-5322 (D.D.C., 2009), appeal dismissed, No. 105092, (DC Cir., 2010); Super American Grand Jury, 1:09-mc-00346-RCL (D.D.C., 2009) ; Taitz v. Obama, 70? F.SUpp.2d 1 (D.D.C. Cir. 2010), appeal pending, No. 115304 (DC Cir., Oct. 31,2011); Taitz v. Astrue, 1:11-CV-00402, 2011 WL 3B05741, (D.D.C. Aug. 30,2011); Taitz v. Astl'ue, 1:1l-mC-0015B (D.Haw., 2011); Taitz v. Ruemmier, 1:11CV-01421(D.D.C., 2011); Thomas v. Hosemann, 1:oBmco02Bo (D. Haw., 200B); Thomas v. Hosemann, 2:oB-cv-00241-KS-MTP (SD Miss., 2008). State cases: Ankeny v. Daniels, 916 N.E.2d 678 (Ind. Ct. App. 2009) Affd, No. 49A020904-CV-353 (Ind. App. Court); Brockhausen v. Andrade, No. 08-1001-C365 (Tex. State Court); Broe v. Reed, 82473-B (Was. State Supreme Court); Connerat v. Browning, 999 So. 2d 644 O~la.Dist. Ct. App. 2008); Connerat v. Obama, No. 09003103SC (Fla. State Court); Connerat v. Obama, No. 09005522SC (Fla. State Court); Constitution Party v. Lingle, No. 29743, 200B WL 51259B4 (Haw. Dec. 5, 200B); Corbett v. Bowen, No. 30-2008-00114112-CU-FR_CJC, (Cal. Superior Court,

An effort to harass the President continues with qualification challenges filed across the country and in (}eorgia. Challengers ignore procedural and evidentiary requirements because thei r claims are without merit, based on fantasy, and offered in pursuit of a political agenda. See, for example, Rhodes v. MacDonald, 670 F. Supp.2d 1363,1364 (M.D. Ga. 2009), affd, 2010 WL 892848 (11th Cir. March 15, 2010) cert. denied, 129 S. Ct. 2830 (2009)("When a lawyer uses the courts as a platform for

2008); Craig v. Oklahoma: MA-109808 (Okla. Supreme Court); Donofrio v. Wells, No.

AN-I053-08T2 (NJ. Nov. 03, 2008), Cert. denied, 129 S. Ct. 752 (2008); Fitzpatrick v. Obama, no docket number (NC State Court); Greenberg v. Brunner, No. 2008cVI024 (Ohio State Court, 2008); In re John McCain's Ineligibility to be on Presidential Primary Ballot in Pa, 944 .A..2d 75 (Pa. 2008); Justice v. Fuddy, 253 P.3d 665 (Haw. 2011); Keyes v. Bowen, 189 Cal. App. 4th 647 (Cal. Ct. App. 2010) Cert. denied, 132 S. Ct. 99 (2011); US v. LTC Terrence L. Lakin, MCAT-JA-SC; Liberty Legal Foundation v. DNC, CH-11-1757 (Tenn. State Court); Lightfoot v. Bowen, No. 168690 (Cal. Supreme Court, 2008), Cert. denied, 555 U.S. 1151(2009); Marquis v. Reed, No. 08-2-34955-1 (Was. State Court, 2008); lI,fartin v. Lingle, No. 29414, 2008 WL 4684786, (Haw. Oct. 22,2008); Martin v. LinglE!,No. ICC08-1-002147, 2009 WL 1669050, (Haw. Jun. 9, 2009), Appeal Dismissed, :;W09 WL 2372096 (Haw. Aug. 3, 2009); Martin v. Bennett, No. lCClO-l-000969 (Haw. State Court); Meroni et al v. McHenry County Grand Jury Foreman et al, No. 09mr399 (Ill. State Court, 2009); Neal v. Brunner, No. 2008cv72726 (Ohio State Court, 2008); Patriot's Heart Media Network v. Illinois Board of Elections, No. loHoo0605 (Ill. State Court); Schneller v. Cortes, 199 MM 2008 (Pa. Supreme Court, :;W09), cert. denied, 129 S. Ct. 2830 (2009); Sorsensen v. Riley, cv-2008-1906 (Ala. S:ate Court, 2008); Spuck v. Sec. of State, 2008 CVI116(Ohio State Court, 2008); Stumpo v. Granholm, No. 08-140-MM (Mich. Dist. Ct. (30th) Mar. 31,2009), appeal dismissed:, No. 291681, (Mich. App. Ct., Jun. 3, 2009); Stunk v. Patterson, 029641/2008 (N.Y. State Court, 2008); Strunk v. Patterson, 029642/2008 (N.Y. State Court, 2008); Sv1livan v. Sec. of State, 08CV1076(N.C. State Court, 2008); Sullivan v. Marshall, 08cvs·, 021393 (N.C. State Court, 2008); Taitz v. Fuddy, lCCll-l001731 (Haw. State Court); 'Terry v. Handel, 08cv158774S (Superior Court Fulton County, 2008), appeal dismissed, No. S09D0284 (Ga. Supreme Court), reconsideration denied, No. S09A1373; Wroilnowski v. Bysiewicz, SC 18264 (Conn. Supreme Court, 2008).

political agenda disconnected from any legitimate legal cause of action, that lawyer abuses her privilege to pradice law.") President Obama was a United States citizen from the moment of his birth in Hawaii. Since he held citizli~nshipfrom birth, all Constitutional qualifications have been met. Ankeny v. Governor of State of Indiana, 916 N.E.2d 678 (Ind. App., 2009); see, United States v. Marguet-Pillado, 648 F.3d 1001, 1006 (9th Cir., 2011). There is no

basis to question the President's citizenship or qualifications to hold office. Specially appearing before this Court, respondent show that petitioner's actions should be dismissed as they have been in numerous cases for lack of jurisdiction over the subject matter, failure of service of process, and failure to state a claim upon which relief can be granted. O.C.G.A. § 9-11-12(b)(1), (5), and (6).
1. LACKOF SUBJECT MATTER JURISDICTION

A. THE STATE OF GEORGIA MAY NOT EXERCISE JURISDICTION- OVER A POLITICAL PARTY'S CHOICE OF NAMES TO IN(;LUDE IN THE PRESIDENTIAL PREFERENCE PRIMARY. The Democratic Part,? of Georgia, a political party as defined by O.C.G.A. § 21-22(25), participates in the Georgia Presidential Preference Primary "so that electors may express their preference for one person to be the candidate for nomination ... for the office of President of the United States." O.C.G.A. § 21-2-191. No one is elected to any office, nor is anyone nomin:lted to run for any office, as a result of the Presidential Preference Primary. Nomination of a candidate for the office of President will occur at the national convention in Charlotte, NC during the week of September 3, 2012.

The Democratic Party of Georgia determines names to include on its Presidential Preference Primary ballot at its sole discretion. O.C.G.A. § 21-2-193. A state political party "enjoys a constitutionally protected freedom which includes the right to identify the people who constitute this association that was formed for the purpose of advancing shared beliefs and to limit the association to those people only." See Democratic Party of

u.s. v.

Wisconsin, 50 U.S. 107, 101 S.Ct. 1010, 1019, 67 L.Ed.2d 82 (1981). Duke v.

Cleland, 954 F.2d 1526, 15~!,0-1 (nth Cir. 1992). First amendment associational rights of a political party are most often litigated in the context of a party refusing to allow a name to appear on a primmy ballot (such as in Democratic Party of

u.s. v.

Wisconsin

or Duke v. Cleland) but the reverse is also true: a political party enjoys the exclusive right to dictate names on it~;: rimary ballot. The right to associate not only contemplates p the ability to exclude but, necessarily, who to include. Apportionment of de legates as a result of preference primary results constitutes an internal party matter. The State of Georgia may not interfere with "the traditionally recognized autonomy of the political party's internal decision-making." Belluso v. Poythress, 485 F.Supp. 904, 912 (N.D. Ga., 1980); Duke v. Cleland, 954 F.2d 1526 (nth Cir., 1992). B. THE QUALIFICATIONS CHALLENGE STATUTE DOES NOT APPLY TO THE PRESIDENTIAL PREFERENCE PRIMARY. O.C.G.A. § 21-2-5 does not apply to the Presidential Preference Primary. The preference primary is not an election: by its terms, the preference primary is simply an opportunity for electors "to express their preference for one person to be a candidate for nomination." O.C.G.A. § 21-:;~-191. he election code defines "election" as "any general or T special election and shall not include a primary or special primary unless the context in

which the term is used clearly requires clearly requires that a primary or special primary is included. " O.C.G.A. § 21-2-2(5). Neither the preference statute nor the definition reference the Presidential Preference Primary. Nothing in the context of O.C.G.A. § 212-5 "clearly requires" applicability to the preference primary." O.C.G.A. § 21-2-5 applies when a candidate is "certified by the state executive committee of a political pailty or ... files a notice of candidacy." O.C.G.A. § 21-2-5(a). Neither occurred here. (CeJltification of candidates by a party executive committee refers to the qualification procedure in O.C.G.A. § 21-2-154(a) and the payment of qualifying fees, neither of which apply to preference primaries.) No fees may be charged for listing a name on the preference ballot. O.C.G.A. § 21-2-198. There is no qualifying nor does a political party file a certification of its qualified candidates, as it would in an election. See, O.C.G.A. § 21-2-154. The state executive committee simply lists names that it wishes to have on the preference primary ballot. O.C.G.A. § 21-2-193· II. SERVICE OF SUMMONS AND PETITION FOR REVIEW UPON AN ATTORNEY REPRESENTING A PARTY IS INSUFFICIENT The return of service filed with the Court shows that service of the summons and complaint was made by mailing to respondent's attorney. Petitioner did not seek a waiver of personal service as authorized by O.C.G.A. § 9-1l-4(d) nor did it attempt personal service using the m.ethods specified by O.C.G.A. § 9-1l-4(e) or 4(f). "Where there is no process and no waiver of process, no valid suit arises." State Hwy. Dept. v. Noble, 220 Ga. 410, 414,139 S.E.2d 318 (1964)·

III. THE PETITION FOR REVIEW DOES NOT STATE CLAIMS AGAINST THE PRESIDENT The proper party re:;;pondent when challenging a qualification decision made by the Secretary of State is the Secretary of State. In order to grant the relief sought by the petitioner the Secretary of State needs to be before the court. He is not. See, for example, Handel v. Powell, 284 Ga. 550 (2008), in which the only parties in the appeal were the Secretary of State and the c:hallenger of the Secretary's decision. The relief sought by the petitioner is relief from a decision of the Secretary of State. In paragraphs 13 and 15 of the review petition petitioner seeks to stay the action of the Secretary of Stay. The petition does not seek any relief against the President, but only against the Secretary. In order to grant relief, the Civil Practice Act requires the issuance of a summons signed by the clerk of court in order for the court to exercise power granting relief. The issuance of process signed by the clerk is a necessary part of acquisition of jurisdiction. OCGA § 9-11-8 (a) (2) (A); Schafer v. Wachovia Bank of Georgia, 248 Ga.App. 466, 646 S.E.2d 846 (2001). No summons commands appearance by the Secretary of State in this matter. The lack of personal jurisdiction over the Secretary of State deprives this Court of jurisdiction to grant relief. Bonner v. Bonner, 272 Ga.App. 545, 533 S.E.2cl72 (2000); Wilkinson v. Udinsky, 242 Ga.App. 464, 530 S.E.2d 215 (2000); Guerrero v. Tellez, 242 Ga.App. 354, 529 S.E.2d 639 (2000). Jurisdiction over the Secret~':ryof State must be established before the court can enter any ruling binding a party such as the Secretary of State or the ruling is declared null and void. See Estate of MarJorie C. Thurman v. Dodaro, 169 Ga.App. 531, 532(1), 313 S.E.2d 722 (1984). Knowledge that the suit exists does not substitute for compliance

with service of process statute. Williamsonv. 577 (2009).

Basenback, 298 Ga.App. 567, 680 S.E.2d

The relief sought by the petition is directed against the Secretary of State, not the President. The complaint does not state a claim against the President. IV. CONCLUSION Respondent specially appears in this Court to show that the petition for review should be dismissed.

Respectfully submitt sd, This 27th day of February, 2012.

MICHAEL JABLONSKI Georgia State Bar Number 385850 2221- D Peachtree Road NE Atlanta, Georgia 30309 404-290-2977 michael.jab Ionski@)comcast.l1et

CERTIFICATE OF SERVICE

I hereby certify that I have this day served the foregoing pleading upon Mr. Mark Hatfield Attorney at Law 201 Albany Avenue P.O. Box 1361 Waycross, Georgia 31502 by statutory electronic service pursuant to O.C.G.A. § 9-11-5(e) using the email address mhatfield@wavxcable.com.

This 27th day of February, ~W12.

MICHAEL JABLONSKI Georgia State Bar Number ~!,85850 2221- D Peachtree Road NE Atlanta, Georgia 30309 404-290-2977 micha el.jablonski (ji) comcast.net

IN THE: SUPERIOR

COURT OF FULTON COUNTY

STATE OF GEORGIA KEVIN RICHARD
POWELJI~,

*
*
CIVIL ACTION

r FI~~[iN OFFICE

Petitioner V. BARACK OBAMA,

I

[~AR 05_

2~_l
fnS

D~PU1Y CtERl( COUNTY, GACOURT • FULTON "WERIO. R ._

* * *

FILE NO. 2012CV211528

Respondent

PETITIONER'S RESPONSE TO RE:SPONDENT'S MOTION TO DISMISS Now comes Petitioner undersigned Motion counsel, Kevin Richard Powell, by and through to Respondent Barack Obama's

and responds

to Dismiss herein

as follows: STATEMENT claims that

PRELIMINARY Respondent the instant country Obama's Motion

to Dismiss initially

case is one in a series of cases filed across the Respondent. presumably to Respondent's

since 2008 in "[a]n effort to harass"

Respondent including

further claims that those individuals, Petitioner herein, bringing challenges

qualifications requirements fantasy,

for office because

"ignore procedural

and evidentiary based on Finally, from the

their claims are without merit, in pursuit of a political

and offered

agenda."

Respondent moment

claims that he "was a United States citizen and that therefore, have been met." "all

of his birth .in Hawaii"

Constitutional

(sic) qualifications

A review of

-

PLAINTIIFF'S EXHIUlT

-

Page -1-

IJ/:=_

-,\

the record in this action, assertions are completely

however, misguided.

reveals

that Respondent's

Petitioner Respondent Un~ted

firnt notes that no individual,

including of the of the

Obama, hcls a

vested right

to be the President

States.

An individual

seeking to hold the Office

Presidency

is expected

and required

to comply with the provisions requirements for

of the Constitution, the presidency, States thereof.

including

the eligibility

and the laws of the United

States and the Several

With the foregoing it was Respondent Obama,

in mind,

Petitioner

would point out that the submission Democratic of

in fact, who initiated

his name as a candidate Presidential under Georgia Ballot.

to be listed on the Georgia in accordance

Likewise,

with his rights challenge

law, P2titioner

raised an administrative

to the Respondent's pursuant to Article

qualifications

as a "natural born Citizen"

II of the United States Constitution. to have

Respondent

and his la.wyer tried, unsuccessfully, challenqe dismissed. Respondent requiring

Petitioner's

was then legally

served with a Notice

to Produce,

him to appear at trial with him.

and to bring certain documents The Respondent did not object.

and items of evidence

When the time for trial was imminent, lawyer wrote a lette!: to the Georgia he boldly criticized and attacked

the Respondent's of State in which law judge

Secretary

the administrative

Page -2-

and in which he stated that he and his client were refusing come to court. The day of trial, when Respondent schedule,

to

had no events

or duties on his official public Secretary

and after the to appear

of State llad warned him that his failure

would be at his own peril, the Respondent nevertheless Petitioner's failed to appear valid Notice

and his lawyer

for court and failed to comply with The Respondent thus not for

to Produce.

only presented office,

no ev·idence of his own as to his eligibility significant pieces

but he failEd to produce

of evidence

to which Petitioner

was legally entitled. and failings of total thereof, it

In view of the foregoing misconduct Respondent disregard appears

and his lawyer, and considering

Respondent's

of the laws of this State and the judiciary

that it

is Respondent,

and not Petitioner,

who "ignore[s] of a

procedural political

and evidentiary agenda,"

requirements,"

who is "in pursuit

and whose factual assertions

- which he fails

to support with any evidence - are "based on fantasy." Petitioner, availing himself far from seeking to "harass" of lawful procedures anyone, is simply

under Georgia

law in order

to properly whether a United

raise and have finally determined

the issue of

Respondent,

liVhose fa ther

was a foreign

na tiona]

and never

States

citizen,

is a "natural

born Citizen"

eligible of the

under Article United States.

II

of the Constitution In that regard,

for the Presidency contends

Petitioner

that the

Page -3-

"natural prevent national command

born CitiZl'~n"requirement

of Article

II was intended and dual

to

anyone born with dual national allegiance~3 from holding of this nat:_on's military e)f national

citizenship

the presidency forces.

and the ultimate

It is thus nothing

less than a matter and construction

security

that the proper meaning requirement, as

of the "natural

born Citizen"

set forth in Minor V. Happersett, 627, 21 Wall. Judiciary. I.

88 U.S. 162, 167, 22 L. Ed. confirmed by the

162 (1875), be conclusively

SUBJECT-Mlli.TTER JURISDICTION on the basis of a lack of subject-matter first argues that First party give the

Seeking dismissal jurisdiction Amendment

in this Court, Respondent

associational

rights of a political

party the exclusive Presidential contends

right to determine Primary ballot.

whom to include on its While Respondent rights of a party are

Preference

that First Amendment

associational

"most often litigated" to permit

in the situation

in which a party refuses Party of

a name on 3 primary ballot

(citing Democratic

U.S. v. Wisconsin,

58 U.S. 107, 101 S. Ct. 1010, 67 L. Ed. 2d 82 (11th Cir. 1992)), he

(1981); Duke v. Clel~3.nd,954 F. 2d 1526 also claims that "thl~ reverse the unchecked ballot. right:o

is also true" in that the party has

require certain names on its primary however, cites no authority for the latter are

Respondent,

proposition.

Moreover,

none of the cases cited by Respondent

Page -4-

authority

for the c~Jnclusion that a political asso(:iational rights deprive that candidates

party's of

constitutional its ability statutory placed

a state government or

to require

meet constitutional

eligibilit:y requirements

for office

in order to be

on the state ballot.

O.C.G.A. Secretary

§§

21--2-5(b) and

(c) authorize Georgia

the Georgia to challenge

of State, or an eligible

elector,

a candidate's thereafter qualified elector

qualii'ications, and the Secretary to determine whether

of State is is gives an

empowered

the candidate

to seek ard hold office. challenging

O.C.G.A.

§

21-2-5(e)

unsuccessfully

a candidate's

qualifications by filing a

the right to appeal petition state's

the Secretary

of State's decision

in the Superior

Court of Fulton County.

Given the to the

right to run its own elections, rights of the Respondent's

nothing pertaining political

associational

party deprives

this Court of subject-matter Respondent the Georgia

jurisdiction however,

in this matter.

also contends,

that O.C.G.A.

§

21-2-5,

qualifications Preference

challenge

statute,

does not apply to

the Presidential

Primary and that this Court therefore jurisdiction. In this connection, of "election" found in but

does not have subject-matter Respondent O.C.G.A. points

out that the definition includes general

§

21-2-2(5)

or special elections, the context in which

not a primary

or special primary

unless

Page -5-

"election"

is used

nclearly requires"

the inclusion

of a primary

or special primary. Respondent 21-2-15 inasmuch overlooks, as however, the provisions of O.C.G.A.

§

This chapter shall apply to any general or special eJection in this state to fill any federal, ::,tate, county, or municipal office, to any general or special primary to nominate candidates for any such office, and to any federal, ~;tate, county, or municipal election or primary for any other purpose whatsoever, unless otherwise provided. Respondent challenge further fails to realize that the qualifications

statute,

(I.C.G.A.

§

21-2-5, grants a right to challenge regardless of the specific Preference

the qualifications type of election. Primary

e,f "any candidate," Contestants

in a Presidential O.C.G.A.

are designated

as "candidates."

§

21-2-193. must be party"

Respondent "certified

nevertheless

argues that a "candidate" committee

by the state executive

of a political

or must submit

"a notice of candidacy," of such conditions

see O.C.G.A.

§

21-2-5(a),

and that neither Respondent. challenge

have taken place as to however, that a

O.C.G.A.

§

21-2-5(b)

provides,

of the qualifications

of any candidate

may be made "at and

any time prior to th,:; election Respondent's certification Petitioner candidacy" political

of such candidate,"

party would presumably

be filing a

of his nomination

prior to the general election. and "notice of

additiona:Lly submits that "certified" are not specifically defined

terms in the Georgia

Page -6-

Election

Code, and one could argue that the list of Presidential Primary candidates submitted 21-2-193 by Respondent's a political

Preference

party pursuant "certification"

to O.C.G.A. or
21

§

constituted

"notice

of candidacy." that the Georgia qualifications

Accordingly, challenge Preference jurisdiction
II.

it: is apparent

statute deles, in fact, apply to the Presidential Primary 2lnd that this Court does have subject-matter

herein.
Oli' SUMMONS

SERVICE

Respondent of the summons [R]espondent's service

alse, seeks dismissal and complaint attorney."

for the reason that "service to

was made by mailing

Respondent

claims that personal for a viable suit.

or a waiver

thereof was required

The case of Douglas Asphalt Commission, controlling.

Co. v. Georgia

Public Service

263 Ga. App. 711, 589 S.E. 2d 292 In DOt:,glas Asphalt,

(2003) is

the Court held that in an of a state agency or other for judicial review

appeal of an administrative tribunal, personal

decision

service of the petition

upon the agency was not required, to preserve specifically decision pertinent the jurisdiction

and service by mail was proper The Court from an agency in

of the court.

noted that service of appeals by O.C.G.A.

is governed

§

5-3-21, which provides

part that "[a] copy of the notice of appeal in the same manner prescribed

shall be

served on all parties

by Code

Page -7-

Section

5-6-32."

O.C.G.A.

§

5-6-32(a),

in turn, provides

in

pertinent

part that Whenever under this article service or the giving of any notice is required or permitted to be made upon a party and the party is represented by an attorney, the service shall be made upon the attorney unless service upon the party himself is ordered by the court. Service of all notices and other papers hereunder and service of motions for new trial, motions in arrest, motions for judgment notwithstanding the verdict, and all other similar motions, orders, and proceedins:rsmay be made by the attorney or party fili.ng the notice or paper, in person or by mail., and proof thereof shown by acknowledgment of the attorney or party served, or by certificate of the attorney, party, or other person perfecting service.

Therefore, Respondent accordance however,

in the instant

case, service of the Petition upon was in

Obama by mailing with Georgia law.

same to his attorney Petitioner

notes in passing,

that even if the service by mail were for any reason not proper, C.C.G.A.

considered

§

5-3-2l(b)

states in pertinent

part

that "[f]ailure dismissal,

to perfect

service on any party shall not work court shall grant continuances to permit and

but the superior

enter such other orders as may be necessary expeditious determination of the appeal."

a just and

III. STATEMENT Respondent

OF CLAIM AGAINST requests a decision

RESPONDENT because "[t]he proper of State

finally

dismissal

party when challenging is the Secretary

made by the Secretary

of state."

Respondent

states such contention

Page -8-

with no citation Respondent

of authority

whatsoever.

Nevertheless, action does not

goes on 1:0 claim that Petitioner's

seek any relief against Respondent,
Secretary of State. Respondent

but only against the contends that there is a of State, as of State in

further

lack of personal

ju]~isdiction over the Secretary appearance

"[n]o summons commands this matter." Beginning legal analysis Petitioner's decision action. O.C.G.A. service

by the Secretary

with the latter issue of "summons," is flawed. O.C.G.A.

Respondent's

§

21-2-5(e)

makes plain that

Petition

For Judicial

Review

is an appeal from the civil

of the Secretary

of State; it is not an original to service of the Petition in

The only reference

§

21-2-5(e)

states that "[a]s soon as possible

after

of the petit.ion, the Secretary or a certified Nowhere

of State shall transmit

the original reviewing

copy of the entire record ...to the in this statute is "summons" required

court."

or even mentioned. Likewise, that"
parties

O.C.C;.A.

§

5-3-21(b)

provides

in pertinent

part

[a] copy of t:he notice
.... "

of appeal

shall be served on all is "summons" required

Again,

nowhere

in the statute

or even mentioned. Furthermore, in DouQlas Asphalt, 263 Ga. App. at 711-712, by mail,

the state agency wa~: served with the petition summons at all. The Court affirmed

wi th no

the judgment

of the superior

Page -9-

court which denied dismiss personal

-:he agency's motion

to dismiss. of failure

The motion to to perfect

had been ba:3ed upon an allegation service. the Secretary

As for his rOlE! herein,

of State is not a the Secretary of

proper party to thi~; petition. State is essentially court. brought

In this appeal,

in a quasi-judicial

role, akin to a lower was not Petitioner (at of

The challen~re to Respondent'~

qualifications

by the SecrE~tary of State, but by Petitioner. were the named parties below,

and Respondent

and Respondent the Secretary

least up until trial) defended

the challenge;

State did not defen~. the challenge with an interest the Secretary

in any manner.

The entity not

at stake in this challenge

was Respondent,

of State. Petitioner's challenge of State was not a (i.e. the and of

Under these circumstances, dispute agency). between Petitioner

and the Secretary

The challenge

was a dispute between adjudicated

Petitioner

Respondent, State.

and same was merely Petition

by the Secretary

The instant

does therefore

state a claim against

Respondent. The items of relief action are a reversal sought by Petitioner in the instant of

of the Final Decision

of the Secretary II

State, a finding that Respondent "natural born Citizen"

does not meet the Article for the presidency,

requirement

a removal

of Respondent's

name from the ballot,

an order adjudging

Page -10-

Respondent

in

conter~pt of

court
Notice

for his deliberate to Produce

failure to

comply with Petitioner's proceedings; Presidential

in the administrative of the

and cOllditionally, a postponement Preference Primary Election.

Should the requested granted

relief be granted

b~' this Court,

such would be primarily the Final Decision to the Secretary

in the form of an order reversing Secretary of State ~rith direction

of the

of State as to

the appropriate

remedy to be crafted,

in much the same manner

that the Court of Appeals superior court judgn~nt

or Supreme Court would reverse a The Secretary of State this

with direction.

simply does not neec. to be a party in order to accomplish Court's granting of the requested require relief, and none of the

applicable considered

statutes a party.

the Secretary

of State to be named or

Petitioner Handel

further notes that Respondent's
2E:4 Ga. 550 (2008)

citation as the

to

v. Powell,

is misplaced, brought

Secretary

of State there personally qualifications.

the challenge

to a

candidate's elector,

There was no challenge instant case.

filed by an

as in Petitioner's

Powell, the candidate,

filed the petition Secretary initial

for judicial

review, and Powell and the (2) parties in both the

of State were the only two

challenge

and the appeal to superior

court. that even if the

Petitioner Secretary

again notes in passing,

however,

of State were for any reason deemed to be a necessary

Page -11-

party

to this appea:. who had not been properly states in pertinent

served, O.C.G.A. to perfect

§

5-3-2l(b) service

part that "[f]ailure

on any part~l shall not work dismissal,

but the superior

court shall grant continuances be necessary the appeal."

and enter such other orders as may determination of

to perrlit a just and expeditious

·CONCLUSION

For the above 2lnd foregoing requests that Respondent's

reasons,

Petitioner

respectfully

Motion to Dismiss be denied. 2012. P.C.

Respectfully

s1.:bmitted,this 2nd day of March, HATFIELD & HATFIELD,

201 Albany Avenue P.O. Box 1361 Waycross, Georgia (912) 283-3820

31502

Page -12-

CERTIFICATE I, J. Mark Hatfield, certify Response Attorney

OF SERVICE for Petitioner, do hereby Petitioner's

that I have this day served the foregoing to Respondent's Motion to Dismiss upon:

Mr. Michael K. Jablonski Attorney at Law 2221-D Peachtree Road NE Atlanta, Georgia 30309 Honorable Brian P. Kemp Secretary of State State of Georgia 214 State Capitol Atlanta, Georgia 30334 by placing addressed a copy of same in the United States Mail in a properly envelope "ith sufficient postage affixed thereto in

order to insure proper delivery, Jablons ki at to Secretary

and by emailing

same to Mr. same

michae::~.'jablonski@comcast.net
Kemp at vrusso@sos.qa.qov. 2012. HATFIELD

and by emailing

This 2nd day of March,

& HATFIELD,

P.C.

201 Albany Avenue P.O. Box 1361 Waycross, Georgia (912) 283-3820

3I502

r age; I VI I

Mark Hatfield
From: Sent: To: Cc: Subject: Mark Hatfield UmarkI1atfield@yahoo.com]
Friday, March 02, 2012 6:52 AM

elizabeth.baum@fultoncountyga.gov michael.jablonski@c:omcast.net;vrusso@sos.ga.gov
** Court Filing ** Powell v. Obama / Fulton Superior CAFN: 2012CV211528

Attachments: powellkr1res.pdf Please see attached Petitioner's Re:3ponseto Respondent's Motion to Dismiss. As per the Court's permission, please accept this Response as filed with the Court today. I am forwarding the original to the Clerk for filing by UPS overnight mail to arrive Monday.

J. Mark

Hatfield, Esq. Hatfield & Hatfield, P.C. 201 Albany Avenue P.O. Box 1361 Waycross, Georgia 31502 (912) 283-3820 (912) 283-3819 Fax mhatfield@wayxcable.com CONFIDENTIALITY NOTICE: This; e-mail transmission and the attachments accompanying it contain information from the lawl)ffice of Hatfield & Hatfield, P.C. which is protected by the attorney-client communication priivilege or the work product privilege. The information is intended only for the use of the irltended recipient. If you are not the intended recipient, be aware that any disclosure, copying, distlribution, or use of the contents of this transmission is prohibited. If you have received this transmission in error, please promptly notify the sender by reply e-mail and then destroy all (::opies of the transmission.

3/2/2012

ragt: Mark Hatfield
From:
Baum, Elizabeth [Elizl3beth.Baum@fultoncountyga.gov] Friday, March 02, 201'2 8:30 AM mhatfield@wayxcabIEi.com; codyjudy@hotmai/.com; michael.jablonski@comcast.net; Vincent; David Farrar; van@libertylegalfoundation.org; cale@sos.ga.gov White, Connie RE: Farrar, et a!. v. Obama, et a!.: 2012CV211398; Welden v. Obama: 2012CV211537, v. Obama: 2012CV211527, Powell v. Obama: 2012CV211528 High Russo,

1 Ul .)

Sent:
To;

Cc:
Subject:
Importance:

Swensson

Counsel/Parties: The Court is in receipt of the courtesy copies of your Responses to Respondent Barack Obama's Motion to Dismiss. The Court will consider same in ruling on Respondent's Motion to Dismiss. The Court intends to issue that ruling today. Again, please note that the Order will be entered before your responses are officially filed of record with the Clerk of Court. I assume all responses will be promptly mailed or delivered to the Clerk for filing purposes. Thank you for submitting these Responses to us within the timeframe articulated doing so by email as requested. and for

Elizabeth Baum Staff Attorney to the Honorablle Cynthia D. Wright
Chief Judge, Superior Court of Fulton 136 Pryor Street, SW, Suite C92 7 Atlanta, GA 30303 Phone: (404) 613-4187 Fax: (404) 893-6610 elizabeth. ba um({7)fultoncoun tvga"go

County

Baum, Elizabeth Thursday, March 01, 2012 10:32 AM To: 'mhatfield@wayxcable.com'; coc:yjudy@hotmail.com; michael.jablonski@comcast.net; Russo, Vincent; David Farrar; van@libertyleqalfoundation.org; cale@sos.ga.gov Subject: RE: Farrar, et al. v. Obama, et al.: 2012CV211398; Welden v. Obama: 2012CV211537, Swensson v. Obama: 2012CV21152'j', Powell v. Obama: 2012CV211528 Importance: High

From:

Sent:

In light of these circumstances, [he Court will consider a copy of your response submitted by email or fax. Please submit il:by email (even if you fax it, as well) as, occasionally, faxes do not go through, and I want to ensure we receive it. You may send your original response to the Clerk tomorrow with the understanding that the Court may issue its ruling on the Motion to Dismiss before your original response is actually filed with the Clerk. All parties/counsel may proceed in this manner.

3/2/2012

rag\:: L

Ul)

Thank you,

Elizabeth Baum Staff Attorney to the Honorab:le Cynthia D. Wright
Chief Judge, Superior Court ofFlllton County 136 Pryor Street, SW, Suite C927 Atlanta, GA 30303 Phone: (404) 613-4187 Fax: (404) 893-6610 eli zabeth. ba \ Ull (a! tlll toncoun tyga: g'o

Related Interests

J. Mark Hatfield [mailto:mha1;field@wayxcable.com] Thursday, March 01, 2012 1025 AM To: Saum, Elizabeth; codYiudy@hotmail.com; michael.iablonski@comcast.net; Russo, Vincent; David Farrar; van@libertvlegalfoundation.orC!; cale:@sos.qa.qov Subject: Re: Farrar, et al. v. Obama, et al.: 2012CV211398; Welden v. Obama: 2012CV211537, Swensson v. Obama: 2012CV211527, Powell v. Obama: 2012CV211S28
From:

Sent:

Ms. Baum, Would the Court please accept my responses (for Plaintiffs Swensson and Powell) as filed with the Court by tomorrow's deadline by email or fax, with a hard copy to be delivered to the Clerk thereafter? The reason for this request is that I am leaving Atlzmta this morning to drive home to Waycross, a four hour drive. It would not be possible for me to get back to my law office in Waycross, complete work on my responses, and get my resp0ll:';es to UPS in time for overnight delivery. Thus, I would respectfully request that the Court accept my responses for Plaintiffs Swensson and Powell as filed with the Court by email (or fax) with the hard copy being delivered to the Clerk after tomorrow's deadline. I appreciate the Court's consideraljon of this request.

J. Mark Hatfield
"Sent from my Verizon Wireless BlackBerry" From: "Baum, Elizabeth" <Elizabeth.Ballm0ifultoncollntvga.gov> Date: Thu, 1 Mar 201209:31 :37,·0500 To: codyi lldv@,hotmail.com<codvjudy(([1,hotmail.com>; mi chad. iablonski(a),comcast.net<michael. iablonski@comcast.net>; Russo, V incent<vrusso(evsos. ga.gOY>;David Farrar<david. is.farrarra~gmail.com>; 111 hatf!e I d((i)wayxcabIe.com <mhatfield(lvwayxcab Ie .com>; van(QJ.li bertv Iegalfoundation.org<:vanrCi}libertvlegalfoundation. org>; cale{{V,sos. ga.gov<cale@sos.,Qa.gov> Subject: Farrar, et a1. v. Obama, et a1.: 2012CV211398; Welden v. Obama: 2012CV211537, Swensson v. Obama: 2012CV211527, Powell v. Obama: 2012CV211528 Respondent Barack Obama filed a Motion to Dismiss in each of the above matters on February

27.

3/2/2012

J. a!:,,,,,

J

vJ.

J

2012. If you wish to file a response to the Motion to Dismiss, Counsel/Parties are hereby given
until tomorrow morning, Friday. March. 2. 2012 at 9:30 a.m. to do so. The Court is shortening the time period for response due to the time-sensitive nature of certain of your allegations. The Court will issue its ruling on the Motion to Dismiss as soon as possible. Thank you, Elizabeth Baum Staff Attorney to the Honorable Cynthia D. Wright
Chief Judge, Superior Court of Fulton County 136 Pryor Street, SW, Suite C9~~7 Atlanta, GA 30303 Phone: (404) 613-4187 Fax: (404) 893-6610 elizabeth. baum((7J,ful toneo un tvga. gO###BOT_TEXT###quot;

3/2/2012

I

I

Michael Jablonski
Atto rney-at -law
260 Brighton Road, NE Atlanta, Georgia 30309 404.290.2977 815.846.0719 (fax)
m icha e I.ja b Ions ki@comcast.net

January 25, 2012

Hon. Brian P. Kemp Georgia Secretary of State: 214 State Capitol Atlanta, Georgia 30334 via email to Vincent R. Russo Jr .. Esq. (vrusso@sos.ga.gov)

Re: Dear Secretary Kemp:

Georgia Presidential Preference Primary Hearings

This is to advise yo u of serious problems that have developed in the conduct of the hearings pending before the Office of State Administrative Hearings. At issue in these hearings are challenges that allege that President Obama is not eligible to hold or run for re-election to his office, on the now wholly discredited theory that he does not meet the citizenship requirements. As you know, such allegations have been the subject of numerous judicial proceli~dingsaround the country, all of which have concluded that they were baseless and, in wme instances - including in the State of Georgia - that those bringing the challenges have engaged in sanctionable abuse of our legal process. Nonetheless, the Administrative Law Judge has exercised no control whatsoever over this proceeding, and it threatens to degenerate into a pure forum for political posturing to the detriment (If the reputation of the State and your Office. Rather than bring this matter to a rapid ,wnclusion, the ALJ has insisted on agreeing to a day of hearings, and on the full pmticipation of the President in his capacity as a candidate. Only last week, he denied a Motion to Quash a subpoena he approved on the request of plaintiff s counsel for the personal appearance of the President at the hearing, now scheduled for January 26. For these reasons, and as discussed briefly below, you should bring an end to this baseless, costly and unproductive hearing by withdrawing the original hearing request as improvidently issued. PLAINTIFF'S EXHIBIT

"

~

I

It is well establishecl. that there is no legitimate issue here--a conclusion validated time and again by courts around the country. The State of Hawaii produced·official records documenting birth there; the President made documents available to the general public by placing them on bis website. "Under the United States Constitution, a public record of a state is required to be given 'full faith and credit' by all other states in the country. Even if a state wel~eto require its election officials for the first time ever to receive a 'birth certificate' as a requirement for a federal candidate's ballot placement, a document certified by another state, such as a 'short form' birth certificate, or the certified long form, would be required to be accepted by all states under the 'full faith and credit' clause of the Urlited States Constitution." Maskell, "Qualifications for President and the "Natural Born" Citizenship Eligibility Requirement, " Congressional Research Service (November 14, 2011), pAl. Nonetheless, the ALJ has decided, for whatever reason, to lend assistance through his office--and by extension, yours-to the political and legally groundless tactics of the plaintiffs. One of the attomeys for the plaintiffs has downloaded form subpoenas which she tried to serve around thl~country. Plaintiff's attorney sent subpoenas seeking to force attendance by an office mal;:hine salesman in Seattle; seeking to force the United States Attorney to bring an unnamed "Custodian of Records Department of Homeland Security" to attend the hearing with immunization records; and asking the same U.S. Attorney to bring the same records allegedly possessed by "Custodian of Records of U.S. Citizenship and Immigration Services.''' She served subpoenas attempting to compel the production of documents and the attendance of Susan Daniels and John Daniels, both apparently out of state witnesses, regarding Social Security records. She is seeking to compel the Director of Health for the State of Hawaii to bring to Atlanta the "original typewritten 1961 birth certificate #106~lil for Barack Obama, II, issued 08.08.1961 by Dr. David Sinclair ...," even though Hawaii courts had dismissed with prejudice the last attempt to force release of confidential records on November 9, 2011. Taitz v. Fuddy, CA No. 11-11731-08 RAN. In Rhodes v. McDonald, 670 F. Supp. 2d 1363, 1365 (USDC MD GA, 2009), Judge Clay Land wrote this of plaintiff's attorney:

I

I I I I I

I I I I I

I

I

When a lawyer files complaints and motions without a reasonable basis fOr believing that they are supported by existing law or a modification or extension of existing law, that lawyer abuses her privilege to practice law. When a lawyer uses the courts as a platform for political agenda disconnected from any legitimate legal cause of action, that lawyer abuses her privilege to practice law.... As a national leader in the so-called 'birther movement.' Plaintiff's counsel has attempted to use litigation to provide the 'legalfoundation' for her political agmda. She seeks to use the Court's power to compel discovery in her efforts force the President to produce a 'birth

2

certificate' that is satisfactory to herself and her followers:~ 670 F.
Supp. 2d at 1366. All issues were pres,ented to your hearing officer-the clear-cut decision to be on the merits~ and the flagrantly unethical and unprofessional conduct of counsel-and he has allowed the plaintiffs~ counsel to run amok. He has not even addressed these issues--choosing to ignore them. Perhaps he is aware that there is no credible response; perhaps he appreciates that the very demand made of his office-that it address constitutional issues-is by law not within its authority. See, for example, Flint River Mills v. Henry, 234 Ga. 385, 216 S.E.2d 895 (1975); Ga. Compo R. & Regs. r. 616-1-2.22(3). The Secretary of StlJlteshould withdraw the hearing request as being improvidently issued. A rellerring agency may withdraw the request at any time. Ga. Compo R. & Regs. r. 616-1-2-.17(1). Indeed, regardless of the collapse of proceedings before the ALJ~ the original hearing request was defective as a matter oflaw. Terry v. Handel~ 08cv158774S (Superior Court Fulton County, 2008), appeal dismissed, No. S09D0284 (Ga. Supreme Court), reconsiderationdenied, No. S09A1373. ("The Secretary of State of Georgiia is not given any authority that is discretionary nor any that is mandatory to refuse to aillow someone to be listed as a candidate for President by a political party because she believes that the candidate might not be qualified.") Similarly, no law gives the Secretary of State authority to determine the qualifications of someone named by a political party to be on the Presidential Preference Primary ballot. Your duty is determined by the statutory requirement that the Executive Committee of a political party name presidential preJlerence primary candidates. a.C.G.A. § 21-2-193. Consequently, the attempt to hold hearings on qualifications which you may not enforce

I

j

I
J

I
I

I I I I I I I I I

I

is ultra vires.
We await your taking the requested action, and as we do so, we will, of course, suspend further participation in these proceedings, including the hearing scheduled for January 26.

Very truly yours,

L:Ju : J,.a /J( {/~t
MICHAEL JABLONSKI

Georgia State Bar ]~umber 385850 Attorney for President Barack Obama

cc:

Hon. Michael Malihi (c/o Kim Beal (kbeal@osah.ga.gov)) Van Irion, Esq. (van@libertylegalfoundation.org) 3

Orly Taitz, Esq. (orly.taitz@gmail.com) Mark Hatfield, .Esq. (mhatfield@wayxcable.com) Vincent R. Russo Jr., Esq. (vrusso@sos.ga.gov) Stefan Ritter, EBq. (sritter@law.ga.gov) Ann Brumbaugh, Esq. (abrumbaugh@law.ga.gov) Darcy Coty, Esq, (darcy.coty@usdoj.gov) Andrew B. Flake, Esq. (andrew.flake@agg.com)

,
01

4

Related Interests

County

Baum, Elizabeth Thursday, March 01, 2012 10:32 AM To: 'mhatfield@wayxcable.com'; coc:yjudy@hotmail.com; michael.jablonski@comcast.net; Russo, Vincent; David Farrar; van@libertyleqalfoundation.org; cale@sos.ga.gov Subject: RE: Farrar, et al. v. Obama, et al.: 2012CV211398; Welden v. Obama: 2012CV211537, Swensson v. Obama: 2012CV21152'j', Powell v. Obama: 2012CV211528 Importance: High

From:

Sent:

In light of these circumstances, [he Court will consider a copy of your response submitted by email or fax. Please submit il:by email (even if you fax it, as well) as, occasionally, faxes do not go through, and I want to ensure we receive it. You may send your original response to the Clerk tomorrow with the understanding that the Court may issue its ruling on the Motion to Dismiss before your original response is actually filed with the Clerk. All parties/counsel may proceed in this manner.

3/2/2012

rag\:: L

Ul)

Thank you,

Elizabeth Baum Staff Attorney to the Honorab:le Cynthia D. Wright
Chief Judge, Superior Court ofFlllton County 136 Pryor Street, SW, Suite C927 Atlanta, GA 30303 Phone: (404) 613-4187 Fax: (404) 893-6610 eli zabeth. ba \ Ull (a! tlll toncoun tyga: 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J. Mark Hatfield [mailto:mha1;field@wayxcable.com] Thursday, March 01, 2012 1025 AM To: Saum, Elizabeth; codYiudy@hotmail.com; michael.iablonski@comcast.net; Russo, Vincent; David Farrar; van@libertvlegalfoundation.orC!; cale:@sos.qa.qov Subject: Re: Farrar, et al. v. Obama, et al.: 2012CV211398; Welden v. Obama: 2012CV211537, Swensson v. Obama: 2012CV211527, Powell v. Obama: 2012CV211S28
From:

Sent:

Ms. Baum, Would the Court please accept my responses (for Plaintiffs Swensson and Powell) as filed with the Court by tomorrow's deadline by email or fax, with a hard copy to be delivered to the Clerk thereafter? The reason for this request is that I am leaving Atlzmta this morning to drive home to Waycross, a four hour drive. It would not be possible for me to get back to my law office in Waycross, complete work on my responses, and get my resp0ll:';es to UPS in time for overnight delivery. Thus, I would respectfully request that the Court accept my responses for Plaintiffs Swensson and Powell as filed with the Court by email (or fax) with the hard copy being delivered to the Clerk after tomorrow's deadline. I appreciate the Court's consideraljon of this request.

J. Mark Hatfield
"Sent from my Verizon Wireless BlackBerry" From: "Baum, Elizabeth" <Elizabeth.Ballm0ifultoncollntvga.gov> Date: Thu, 1 Mar 201209:31 :37,·0500 To: codyi lldv@,hotmail.com<codvjudy(([1,hotmail.com>; mi chad. iablonski(a),comcast.net<michael. iablonski@comcast.net>; Russo, V incent<vrusso(evsos. ga.gOY>;David Farrar<david. is.farrarra~gmail.com>; 111 hatf!e I d((i)wayxcabIe.com <mhatfield(lvwayxcab Ie .com>; van(QJ.li bertv Iegalfoundation.org<:vanrCi}libertvlegalfoundation. org>; cale{{V,sos. ga.gov<cale@sos.,Qa.gov> Subject: Farrar, et a1. v. Obama, et a1.: 2012CV211398; Welden v. Obama: 2012CV211537, Swensson v. Obama: 2012CV211527, Powell v. Obama: 2012CV211528 Respondent Barack Obama filed a Motion to Dismiss in each of the above matters on February

27.

3/2/2012

J. a!:,,,,,

J

vJ.

J

2012. If you wish to file a response to the Motion to Dismiss, Counsel/Parties are hereby given
until tomorrow morning, Friday. March. 2. 2012 at 9:30 a.m. to do so. The Court is shortening the time period for response due to the time-sensitive nature of certain of your allegations. The Court will issue its ruling on the Motion to Dismiss as soon as possible. Thank you, Elizabeth Baum Staff Attorney to the Honorable Cynthia D. Wright
Chief Judge, Superior Court of Fulton County 136 Pryor Street, SW, Suite C9~~7 Atlanta, GA 30303 Phone: (404) 613-4187 Fax: (404) 893-6610 elizabeth. baum((7J,ful toneo un tvga. gO###BOT_TEXT###quot;

3/2/2012

I

I

Michael Jablonski
Atto rney-at -law
260 Brighton Road, NE Atlanta, Georgia 30309 404.290.2977 815.846.0719 (fax)
m icha e I.ja b Ions ki@comcast.net

January 25, 2012

Hon. Brian P. Kemp Georgia Secretary of State: 214 State Capitol Atlanta, Georgia 30334 via email to Vincent R. Russo Jr .. Esq. (vrusso@sos.ga.gov)

Re: Dear Secretary Kemp:

Georgia Presidential Preference Primary Hearings

This is to advise yo u of serious problems that have developed in the conduct of the hearings pending before the Office of State Administrative Hearings. At issue in these hearings are challenges that allege that President Obama is not eligible to hold or run for re-election to his office, on the now wholly discredited theory that he does not meet the citizenship requirements. As you know, such allegations have been the subject of numerous judicial proceli~dingsaround the country, all of which have concluded that they were baseless and, in wme instances - including in the State of Georgia - that those bringing the challenges have engaged in sanctionable abuse of our legal process. Nonetheless, the Administrative Law Judge has exercised no control whatsoever over this proceeding, and it threatens to degenerate into a pure forum for political posturing to the detriment (If the reputation of the State and your Office. Rather than bring this matter to a rapid ,wnclusion, the ALJ has insisted on agreeing to a day of hearings, and on the full pmticipation of the President in his capacity as a candidate. Only last week, he denied a Motion to Quash a subpoena he approved on the request of plaintiff s counsel for the personal appearance of the President at the hearing, now scheduled for January 26. For these reasons, and as discussed briefly below, you should bring an end to this baseless, costly and unproductive hearing by withdrawing the original hearing request as improvidently issued. PLAINTIFF'S EXHIBIT

"

~

I

It is well establishecl. that there is no legitimate issue here--a conclusion validated time and again by courts around the country. The State of Hawaii produced·official records documenting birth there; the President made documents available to the general public by placing them on bis website. "Under the United States Constitution, a public record of a state is required to be given 'full faith and credit' by all other states in the country. Even if a state wel~eto require its election officials for the first time ever to receive a 'birth certificate' as a requirement for a federal candidate's ballot placement, a document certified by another state, such as a 'short form' birth certificate, or the certified long form, would be required to be accepted by all states under the 'full faith and credit' clause of the Urlited States Constitution." Maskell, "Qualifications for President and the "Natural Born" Citizenship Eligibility Requirement, " Congressional Research Service (November 14, 2011), pAl. Nonetheless, the ALJ has decided, for whatever reason, to lend assistance through his office--and by extension, yours-to the political and legally groundless tactics of the plaintiffs. One of the attomeys for the plaintiffs has downloaded form subpoenas which she tried to serve around thl~country. Plaintiff's attorney sent subpoenas seeking to force attendance by an office mal;:hine salesman in Seattle; seeking to force the United States Attorney to bring an unnamed "Custodian of Records Department of Homeland Security" to attend the hearing with immunization records; and asking the same U.S. Attorney to bring the same records allegedly possessed by "Custodian of Records of U.S. Citizenship and Immigration Services.''' She served subpoenas attempting to compel the production of documents and the attendance of Susan Daniels and John Daniels, both apparently out of state witnesses, regarding Social Security records. She is seeking to compel the Director of Health for the State of Hawaii to bring to Atlanta the "original typewritten 1961 birth certificate #106~lil for Barack Obama, II, issued 08.08.1961 by Dr. David Sinclair ...," even though Hawaii courts had dismissed with prejudice the last attempt to force release of confidential records on November 9, 2011. Taitz v. Fuddy, CA No. 11-11731-08 RAN. In Rhodes v. McDonald, 670 F. Supp. 2d 1363, 1365 (USDC MD GA, 2009), Judge Clay Land wrote this of plaintiff's attorney:

I

I I I I I

I I I I I

I

I

When a lawyer files complaints and motions without a reasonable basis fOr believing that they are supported by existing law or a modification or extension of existing law, that lawyer abuses her privilege to practice law. When a lawyer uses the courts as a platform for political agenda disconnected from any legitimate legal cause of action, that lawyer abuses her privilege to practice law.... As a national leader in the so-called 'birther movement.' Plaintiff's counsel has attempted to use litigation to provide the 'legalfoundation' for her political agmda. She seeks to use the Court's power to compel discovery in her efforts force the President to produce a 'birth

2

certificate' that is satisfactory to herself and her followers:~ 670 F.
Supp. 2d at 1366. All issues were pres,ented to your hearing officer-the clear-cut decision to be on the merits~ and the flagrantly unethical and unprofessional conduct of counsel-and he has allowed the plaintiffs~ counsel to run amok. He has not even addressed these issues--choosing to ignore them. Perhaps he is aware that there is no credible response; perhaps he appreciates that the very demand made of his office-that it address constitutional issues-is by law not within its authority. See, for example, Flint River Mills v. Henry, 234 Ga. 385, 216 S.E.2d 895 (1975); Ga. Compo R. & Regs. r. 616-1-2.22(3). The Secretary of StlJlteshould withdraw the hearing request as being improvidently issued. A rellerring agency may withdraw the request at any time. Ga. Compo R. & Regs. r. 616-1-2-.17(1). Indeed, regardless of the collapse of proceedings before the ALJ~ the original hearing request was defective as a matter oflaw. Terry v. Handel~ 08cv158774S (Superior Court Fulton County, 2008), appeal dismissed, No. S09D0284 (Ga. Supreme Court), reconsiderationdenied, No. S09A1373. ("The Secretary of State of Georgiia is not given any authority that is discretionary nor any that is mandatory to refuse to aillow someone to be listed as a candidate for President by a political party because she believes that the candidate might not be qualified.") Similarly, no law gives the Secretary of State authority to determine the qualifications of someone named by a political party to be on the Presidential Preference Primary ballot. Your duty is determined by the statutory requirement that the Executive Committee of a political party name presidential preJlerence primary candidates. a.C.G.A. § 21-2-193. Consequently, the attempt to hold hearings on qualifications which you may not enforce

I

j

I
J

I
I

I I I I I I I I I

I

is ultra vires.
We await your taking the requested action, and as we do so, we will, of course, suspend further participation in these proceedings, including the hearing scheduled for January 26.

Very truly yours,

L:Ju : J,.a /J( {/~t
MICHAEL JABLONSKI

Georgia State Bar ]~umber 385850 Attorney for President Barack Obama

cc:

Hon. Michael Malihi (c/o Kim Beal (kbeal@osah.ga.gov)) Van Irion, Esq. (van@libertylegalfoundation.org) 3

Orly Taitz, Esq. (orly.taitz@gmail.com) Mark Hatfield, .Esq. (mhatfield@wayxcable.com) Vincent R. Russo Jr., Esq. (vrusso@sos.ga.gov) Stefan Ritter, EBq. (sritter@law.ga.gov) Ann Brumbaugh, Esq. (abrumbaugh@law.ga.gov) Darcy Coty, Esq, (darcy.coty@usdoj.gov) Andrew B. Flake, Esq. (andrew.flake@agg.com)

,
01

4

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