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FIRST JUDICIAL DISTRICT Circuit Clerk's Office P.O.

BOX 327 Jackson, MS 39205 Phone: (601) 968-6628

) FIRST AMENDED COMPLAINT DR. ORLY TAITZ, ESQ )PETITION FOR AN EMERGENCY BRIAN FEDORKA ) INJUNCTION FROM GENERAL LAURIE ROTH ) ELECTION, PERMANENT LEAH LAX ) INJUNCTION, DECLARATORY TOM MacLERAN ) RELIEF, TREBLE DAMAGES IN ) RICO V ) Hon R Kenneth Coleman DEMOCRAT PARTY OF MISSISSIPPI, ) presiding SECRETARY OF STATE OF MISSISSIPPI ) BARACK HUSSEIN OBAMA ) CASE#2012-107 OBAMA FOR AMERICA ) NANCI PELOSI ) DR. ALVIN ONAKA ) LORETTA FUDDY ) MICHAEL ASTRUE ) JANE DOES, JOHN DOES 1-100 ) EMERGENCY MOTION/ PETITION FOR A MISSISSIPPI SUBPOENA TO SUPPORT CALIFORNIA SUBPOENA
Plaintiff Orly Taitz is a pro se plaintiff in MS and a licensed attorney in California. As the defendants Secretary of State of Mississippi and the Democratic Party of Mississippi filed an answer, the parties are in the discovery phase. Plaintiff, as a licensed California attorney, served two Plaintiff's witnesses with a California subpoena for deposition and production of documents. Witnesses: Producer Bettina Sofia Viviano and director Gigi Gaston are creators of a documentary movie "We Will Not Be Silenced" and they personally gathered a large amount of evidence crucial in this case,

specifically evidence of Barack Obama lacking valid identification papers and an ongoing intimidation of witnesses and whistleblowers, who aware of this information. As both the Plaintiff, the witnesses and one of the defense attorneys are residents of California, it is the most convenient and cost effective to hold the deposition in California. As the deposition was scheduled, Plaintiff is asking in this emergency motion for a Mississippi subpoena to support the California subpoena. Declaration of Orly Taitz is attached. /s/ Dr. Orly Taitz, ESq

SWORN DECLARATION OF ORLY TAITZ


I Orly, Taitz, am over 18 years old, have personal knowledge of the fact below and will competently testify to following: 1. I am a pro se plaintiff in MS and a licensed attorney in California. 2. as the defendants Secretary of State of Mississippi and the Democratic Party of Mississippi filed an answer, the parties are in discovery phase. 3. I, as a licensed California attorney served two Plaintiff's witnesses with a California subpoena for deposition and production of documents to appear in my office in rancho Santa Margarita, Ca on April 20, 2012 4. Witnesses: Producer Bettina Sofia Viviano and director Gigi Gaston are creators of a documentary movie "We Will Not Be Silenced" and they personally gathered a large amount of evidence crucial in this case, specifically evidence of Barack Obama lacking valid identification papers and an ongoing intimidation of witnesses and whistleblowers, who aware of this information. a lot of information gathered by Ms. Viviano and Ms. Gaston was not included in the movie. 5. I, as a Plaintiff , have been a victim of similar intimidation and retaliation and the time is of the essence. 6. As both the Plaintiff, the witnesses and one of the defense attorneys are residents of California, it is the most convenient and cost effective solution to hold the deposition in California. 7. as the deposition was scheduled for April 20, 2012, Plaintiff is asking in this emergency motion for a Mississippi subpoena to support the California subpoena. I declare under penalty of perjury that all of the above is true and correct. /s/ Orly Taitz 04.15.2012 I, Orly Taitz, attest that I served all parties in the case with above motion petition on 04.15.2012 /s/ Orly Taitz