I decided this time to visit the four for one combination outdoor world/ BASS Pro shop. Divers Direct/International Fishing Hall of Fame in Hollywood which I had wound up bypassing on my Seminole Hard Rock cafe hotel casino complex (all built on the proceeds of decades of bingo) trajectory the day before.  First however I had to cover my tracks and visit the gardens and greenhouse of the American Orchid Society (where I discovered the Bottle Nose Palm from Madagascar and the Chenille plant from Malaysia with a hot dark pink fuzzy streamer of a blossom among other varieties of flora too numerous to mention ).

When i got to the everything about the great outdoors complex tucked behind a Tri-rail station and adjacent to a Marriot Courtyard Hotel I chose to go to the International Fishing Hall of Fame where I caught the feature legnth documentary 'Sharkwater" by the young Canadian Diver, photographer, adventurer, and shark savior Rob Stewart (who is in tip top no body fat shape and does a mean athletic free dive into the depths to swim with great predators).

Here I saw what seemed funny in Hong Kong (shark fin soup everywhere) unmasked as tragic (ninety percent of the worlds' sharks have been killed in the last few years to provide this delicacy which the Chinese believe has curative properties).  Only two real havens for sharks remain (the Cocos Islands off of Costa Rica and the Galagapos) and even these are threatened.  This movie presents the evidence and the information and has begun to help to turn things around.

Afterwards this itinerant blogger had dinner at the Islamorada fish company restaurant (fried tuna in wasabi sauce), tried on a couple of thick wetsuits, saw a magnificent sunset, and turned around to watch the presidential debate between Barack Obama and John McCain.

Made it back in time to watch the debate saw the opening slavos and fell asleep.  Then stayed up for Dancing with the Stars night three and then was off (as I have failed to mention) as I had at every morning and evening oppurtunity to loosen up my back muscles and thus breathing with the pulsating jets of the the hot tub and starlight as I did yoga moves in the aquatic atmosophere of the  swimming pool gazing up at the heavenly bodies.

http://elections.foxnews.com/2008/10/07/acorn-vegas-office-raided-voter-fraud-investigation/

ACORN Vegas Office Raided in Voter Fraud Investigation

ACORN's Las Vegas headquarters has been raided by Nevada authorities looking for evidence of voter fraud. 

Nevada state authorities seized records and computers Tuesday from the Las Vegas office of an organization that tries to get low-income people registered to vote, after fielding complaints of voter fraud. 

Bob Walsh, spokesman for the Nevada secretary of state's office, told FOXNews.com the raid was prompted by ongoing complaints about "erroneous" registration information being submitted by the Association of Community Organizations for Reform Now, also called ACORN. 

The group was submitting the information through a voter sign-up drive known as Project Vote. 

"Some of them used nonexistent names, some of them used false addresses and some of them were duplicates of previously filed applications," Walsh said, describing the complaints, which largely came from the registrar in Clark County, Nev. 

Secretary of State Ross Miller said the fraudulent registrations included  forms for the starting lineup of the Dallas Cowboys football team. 

"Tony Romo is not registered to vote in the state of Nevada, and anybody trying to pose as Terrell Owens won't be able to cast a ballot on Nov. 4," Miller said.

Walsh said agents from both the secretary of state's office and Nevada attorney general's office conducted the raid at 9:30 a.m. local time, and "took a bunch of stuff." 

ACORN spokesman Charles Jackson confirmed the group's Nevada office was raided. He would not comment further to FOXNews.com. 

Neither the group, which hires canvassers to register voters, nor any employees have been charged or arrested for fraud or other crimes, said Miller, a Democrat. 

But it's not the first time ACORN's been under investigation for registration irregularities. The raid is the latest of at least nine investigations into possible fraudulent voter registration forms submitted by ACORN -- the probes have involved ACORN workers in Wisconsin, New Mexico, Indiana and other states. 

In 2006, ACORN also committed what Washington Secretary of State Sam Reed called the "worse case of election fraud" in the state's history. 

In the case, ACORN submitted just over 1,800 new voter registration forms, and all but six of the 1,800 names were fake. 

More recently, 27,000 registrations handled by the group from January to July 2008 "went into limbo because they were incomplete, inaccurate, or fraudulent," said James Terry, chief public advocate at the Consumers Rights League.

FOX News' Eric Shawn, Judson Berger and Cristina Corbin and The Associated Press contributed to this report. 

Since many people are saying that it is fair game to talk about Obama's associations with religious zealots saying politically unpopular (and just plain destructive) things, I think its fair game we talk about Palin's associations with said figures.

The Politico has an article about Palin's presence at a sermon at her hometown church of Wasilla Bible Church. It was a day when the pulpit was given to the executive director of Jews for Jesus, David Brickner.

Brickner then explained that Jesus and his disciples were themselves Jewish.

“The Jewish community, in particular, has a difficult time understanding this reality,” he said.
Brickner’s mission has drawn wide criticism from the organized Jewish community, and the Anti-Defamation League accused them in a report of “targeting Jews for conversion with subterfuge and deception.”

Brickner also described terrorist attacks on Israelis as God's "judgment of unbelief" of Jews who haven't embraced Christianity.

"Judgment is very real and we see it played out on the pages of the newspapers and on the television. It's very real. When [Brickner's son] was in Jerusalem he was there to witness some of that judgment, some of that conflict, when a Palestinian from East Jerusalem took a bulldozer and went plowing through a score of cars, killing numbers of people. Judgment — you can't miss it."

Palin was in church that day, Kroon said, though he cautioned against attributing Brickner’s views to her.

Politico also provides a link to the transcript of the sermon, provided by the church itself.

I like that Kroon is careful enough to say that just because Palin was present at that sermon, doesn't mean she was approving of his stances on the Jews. Unfortunately, this lovely courtesy which Palin herself enjoys is being denied to Obama. Hypocrisy much?

I'm not doing this in the spirit of mud-slinging but to illustrate a point: Politicians of all kinds have worrisome friends and relations. These relationships cannot be taken at face value. I believe in the ability of the American people to look at these relationships for what they are, strategic moves, and move past them.

I am done posting about this issue. It was fun while it lasted, but I have to move on to bigger and less/more interesting things.

http://www.wnd.com/index.php?fa=PAGE.view&pageId=77268

 

---

---

DISPATCH FROM KENYA
Kenya detains Corsi during Obama probe
Officials scuttle WND reporter's news conference on investigation

---

Posted: October 07, 2008
7:26 am Eastern

© 2008 WorldNetDaily

 

WND senior staff writer Jerry Corsi

NAIROBI, Kenya – The government of Kenya is holding WND senior staff reporter Jerome Corsi in custody at immigration headquarters after police picked him up at his hotel just prior to a scheduled news conference in which he planned to announce the findings of his investigation into Barack Obama's connections in the country.

Corsi, the author of the No. 1 best-selling book "The Obama Nation," was picked up by authorities at his hotel at 9:45 a.m. and detained at Nyayo House, the provincial headquarters for Nairobi.

"Just as we were about to start the 10 a.m. press conference at the Grand Regency Hotel in Nairobi, Kenyan immigration approached us and detained us," Corsi told WND by telephone this morning. "Tim Bueler, my publicist, and I are now in the immigration offices, with our passports taken. The immigration officer told the press, 'There is no problem, and Dr. Corsi is a friend of Kenya.'"

"There are unconfirmed reports from on the ground in Nairobi that Jerome Corsi and his traveling partner and publicist, Tim Bueler, have left Kenya," said Joseph Farah, editor and chief executive officer of WND who was in touch with Corsi by telephone and email until 9:30 a.m. Eastern today. "However, we have not been able to reach either Corsi or Bueler for several hours, and we are concerned. Officials in Kenya have not been responsive to our requests for information. We also hear unconfirmed reports from the government claiming it has 'deported' Corsi. Since Corsi was scheduled to leave the country today, this would seem to be a strange action from a government that was well aware of Corsi's presence, his travels and his activities in the country for the last week."

Corsi had extensive meetings with top Kenyan officials upon his arrival. His visit and his activities during his stay have been well-known to authorities at the highest levels.

(Story continues below)

A senior immigration official in charge of investigations, Carlos Maluta was quoted by the Associated Press as saying: "We still haven't decided what to do with him."

Despite reports elsewhere to the contrary, Corsi has not been arrested or charged with any offense.

An official with the Embassy of Kenya in Washington said he was unaware of Corsi's detention. The Ministry of Immigration in Nairobi could not be reached for comment. WND tried again, later, to contact a spokesman for the embassy and was told by a receptionist the official word is that Corsi was not detained. "He's enjoying his holiday in Kenya," she said.

Get the book that started it all – Jerome Corsi's "The Obama Nation," personally autographed, for only $4.95, only from WND and only today!

Obama has a long history of connections in Kenya, where his father worked as a government economist. Corsi documented this history in his book and went to Kenya to find answers to lingering questions – particularly about the links between the presidential candidate and Kenya Prime Minister Raila Odinga.

Corsi had promised a news conference today that would "expose details of deep secret ties between U.S. Democratic presidential candidate Barack Obama and a section of Kenya government leaders, their connection to certain sectoral groups in Kenya and subsequent plot to be executed in Kenya should Senator Obama win the American presidency."

Meanwhile, the management of the hotel where Corsi was scheduled to hold the press conference has repudiated its plans to provide the facility.

In a press release, the hotel said: "We would like to assure our business partners and the public at large that Laico Regency Hotel is a law-abiding institution and does not condone any smear campaigns. The management cannot allow such activities to take place."

Sen. Barack Obama with Raila Odinga

Corsi told WND he has been assured he will be released soon. He had planned to leave the country tomorrow, arriving in London first and the U.S. Friday.

A hotel worker in Nairobi told Reuters Corsi was picked up as soon as he walked into the hotel for the scheduled press conference: "He was walking in and then some immigration officers who were following him snatched him. It happened so fast, they just vanished with him."

"Obama is revered in Kenya for his paternal roots here and as a flagbearer for Africa on the international stage," explained the Reuters dispatch.

Kenyan TV station KTN said Corsi may be sent home due to lack of a work permit. However, Corsi met with top officials in Nairobi earlier this week explaining in detail the purpose of his visit and sharing copies of his news releases and books.

Corsi told WND Editor Joseph Farah by telephone that Kenyan authorities claimed they were holding him because the immigration forms his party filled out for customs had been lost.

Corsi was set to show Obama and Odinga have been in direct contact since the senator's visit to Kenya in 2006. He was to claim Obama advised Odinga on campaign strategy and helped him raise money in the U.S. for the Kenya presidential campaign.

Corsi was to report Odinga's 2007 presidential campaign strategy called for exploiting anti-Kikuyu tribal sentiments, claiming victory and charging voter fraud even if the campaign knew the election had been legitimately lost. Odinga, Corsi said, also was willing to fan the flames of ethnic tribal tensions and use violence as a last resort by calling for mass action that led to the destruction of properties, injuries, loss of life and the displacement of over 500,000 Kenyans. The purpose was to compel the Electoral Commission of Kenya to declare him the winner or enable him to declare himself the winner by force.

Even though Odinga has not fulfilled his campaign promises to the Muslims who voted for him, he continues to cause concern among Kenyans because he has not declared his position on Shariah law, Corsi said.

Corsi said Obama remained in active phone contact with Odinga through the New Hampshire Democratic Party primary in January. The Illinois senator continued to support Odinga, he said, turning a blind eye to an agreement signed with Muslims and the post-election violence instigated as part of the campaign strategy.

I hope Mr. Corsi makes it out of Kenya in one piece and with even more damning information on Obama!

CQ

Once again we see Elisabeth Hasselbeck making a right fool of herself and being none the wiser when called to task for her ignorance. Even Sherri Shepard stepped off of her Republican pedestal to admit that William Ayers is a non-issue for an attack on Obama. It is this sort of blind ignorance that really makes me ashamed of our culture.

My favorite part of this You Tube clip was found in the comments. There a user named utubeyonkers made the statement, "Patriotism is the new racism." I must admit the statement seems to ring true. For those cowards who still harbor racist sentiments and can't come out and say that they don't want to support Obama because he is black, need only to call him a terrorist or unpatriotic. By doing so they show their prejudice and exhibit just how low we can sink as a culture.

When someone in the crowd yelled "terrorist" in response to McCain asking the question of who the "real" Obama is; we sunk another fathom deeper.  Here is the footage, listen closely at 3:14.

Why didn't McCain correct the racist zombie in the audience?  His facial expression seemed to indicate that he heard it and didn't know what to say in response.  Well silence and inaction are on the same level as condoning such ignorant hate speech.

At the Sarah Palin rally in Clearwater, FL a man in the audience yelled out "Kill Him" in response to the connection between once terrorist Bill Ayers and Barrack Obama.  Funny enough, Palin was quick to douse the flames of a heckler speaking ill of the Iraq war, but when someone suggests killing either a Senator or a respected college educator; well that's just American. Gosh darn it.

This latest call and response hate mongering rally tactics are below McCain and are truly anti-American.  I guess history and social issues weren't strong subjects for John McCain and Sarah Palin.  And Gov. Palin, just because you took time to read the New York Times article, doesn't mean you comprehended it.  It seems like you highlighted a few buzz words to use in your speeches and forgot to do any research or real thought on the issues.

Sad.

Case 2:08-cv-04083-RBS Document 15 Filed 10/06/2008 Page 1 of 10

IN THE UNITED STATES DISTRICT COURT
FOR THE EASTERN DISTRICT OF PENNSYLVANIA
PHILIP J. BERG, :
:
Plaintiff :
:
v. : Civ. Action No. 2:08-cv-04083-RBS
:
BARACK OBAMA, et al., :
:
Defendants :

ORDER

AND NOW, THIS ___ DAY OF ___________, 2008, upon consideration of the
Motion of Defendants Democratic National Committee and Senator Barack Obama for
Protective Order Staying Discovery Pending Decision On Dispositive Motion, and of the
submissions of the parties relating thereto, it is hereby ORDERED that said Motion is
GRANTED.

Surrick. J.

DMEAST #10127194 v1
Case 2:08-cv-04083-RBS Document 15 Filed 10/06/2008 Page 2 of 10

IN THE UNITED STATES DISTRICT COURT
FOR THE EASTERN DISTRICT OF PENNSYLVANIA
PHILIP J. BERG, :
:
Plaintiff :
:
v. : Civ. Action No. 2:08-cv-04083-RBS
:
BARACK OBAMA, et al., :
:
Defendants :

MOTION OF DEFENDANTS
DEMOCRATIC NATIONAL COMMITTEE AND
SENATOR BARACK OBAMA FOR A PROTECTIVE ORDER
STAYING DISCOVERY PENDING DECISION ON DISPOSITIVE MOTION
Pursuant to Fed. R. Civ. P. 26(c)(1), defendants Democratic National Committee
and Senator Barack Obama respectfully move the Court for a protective order staying all
discovery in this action pending the Court’s decision on defendants’ motion to dismiss
the action for lack of subject matter jurisdiction and for failure to state a claim upon
which relief can be granted.

Pursuant to Fed. R. Civ. P. 26(c)(1), on October 6, 2008, counsel for defendants
conferred with plaintiff about agreeing to stay or defer discovery, including deferring
responses to the discovery requests already served by plaintiff (attached as Exhibit A
hereto). Plaintiff refused to consent to any such stay or deferral.

DMEAST #10127157 v1
Case 2:08-cv-04083-RBS Document 15 Filed 10/06/2008 Page 3 of 10

Pursuant to Local Rule 7.1, accompanying this Motion is a Brief in Support of

Motion for Protective Order and a proposed Protective Order.

Respectfully submitted,

/s/ John P. Lavelle, Jr.

Dated: October 6, 2008
John P. Lavelle, Jr.
Attorney I.D. PA 54279
BALLARD SPAHR ANDREWS & INGERSOLL,
LLP
1735 Market Street, 51st Floor
Philadelphia, PA 19103

(215) 864-8603
(215) 864-9125 (Fax)
lavellej@ballardspahr.com

Of counsel:

Joseph E. Sandler
General Counsel, Democratic National Committee
SANDLER, REIFF & YOUNG, P.C.
300 M Street, S.E. #1102
Washington, D.C. 20003
Telephone: (202) 479-1111
Fax: (202) 479-1115

Robert F. Bauer
General Counsel, Obama for America
PERKINS COIE
607 Fourteenth Street, N.W.
Washington, D.C. 20005-2003
Telephone: (202) 628-6600
Facsimile: (202) 434-1690

RBauer@perkinscoie.com

Attorneys for Defendants
Senator Barack Obama and
Democratic National Committee

DMEAST #10127157 v1

2
Case 2:08-cv-04083-RBS Document 15 Filed 10/06/2008 Page 4 of 10

IN THE UNITED STATES DISTRICT COURT
FOR THE EASTERN DISTRICT OF PENNSYLVANIA
PHILIP J. BERG, :
:
Plaintiff :
:
v. : Civ. Action No. 2:08-cv-04083-RBS
:
BARACK OBAMA, et al., :
:
Defendants :

BRIEF OF DEFENDANT DEMOCRATIC NATIONAL COMMITTEE
AND DEFENDANT SENATOR BARACK OBAMA
IN SUPPORT OF MOTION FOR PROTECTIVE ORDER
STAYING DISCOVERY PENDING DECISION ON
DISPOSITIVE MOTION
Defendants Democratic National Committee and Senator Barack Obama submit
this Brief in support of their Motion for Protective Order Staying Discovery Pending
Decision on Dispositive Motion. Plaintiff has served extensive discovery requests on
defendants. As noted in Defendants’ Brief in Support of their Motion to Dismiss, this
lawsuit is entirely without merit and plaintiffs’ allegations are patently false. Defendants
have moved to dismiss this action for lack of subject matter jurisdiction and failure to
state a claim. That motion presents solely issues of law; no discovery is needed in order
to resolve the motion. If the motion is granted, it will dispose of the entire action,
obviating the need for the burdensome discovery sought by plaintiff. A protective order
staying discovery is therefore warranted.

DMEAST #10127159 v1
Case 2:08-cv-04083-RBS Document 15 Filed 10/06/2008 Page 5 of 10

I. Procedural Background
In his Complaint, plaintiff Berg alleges that Senator Barack Obama, the
Democratic Party’s nominee for President of the United States, is not eligible to serve as
President under Article II, section 1 of the Constitution because, Mr. Berg alleges
(falsely), Senator Obamais purportedly not a natural-born citizen. Complaint ¶3. Mr.
Berg seeks a declaratory judgment that Senator Obama is ineligible to run for President;
an injunction barring Senator Obama from running for that office; and an injunction
barring the DNC from nominating him.

On September 15, 2008, plaintiff Berg served on Senator Obama’s office a
request for production of seventeen different categories of documents, including copies of
all of the Senator’s college and law school applications, requests for financial aid, college
and law school papers, and “a copy of your entire presidential file pertaining to being
vetted.” Plaintiff also served 56 requests for admission on Senator Obama. On that same
date, plaintiff served on the DNC 27 requests for admission and requests for production
of five categories of documents, including all documents in the possession of the DNC
relating to Senator Obama.1

On September 24, 2008, defendants filed a motion to dismiss the complaint for
lack of subject matter jurisdiction and failure to state a claim, on the grounds that, as a
matter of law, plaintiff has no standing to challenge the qualifications of a candidate for
President of the U.S. and has no federal cause of action.

True and correct copies of these discovery requests are attached as Exhibit A hereto.

DMEAST #10127159 v1

2
Case 2:08-cv-04083-RBS Document 15 Filed 10/06/2008 Page 6 of 10

II. Discussion
Rule 26(c)(1) authorizes the Court to enter a protective order to protect a party
“from annoyance, embarrassment, oppression, or undue burden or expense,” including an
order forbidding the discovery or specifying terms for discovery. “While the court should
not automatically stay discovery because a motion to dismiss has been filed, ‘a stay is
proper where the likelihood that such motion may result in a narrowing or an outright
elimination of discovery outweighs the likely harm to be produced by the delay.’” 19th
St. Baptist Church v. St. Peters Episcopal Church, 190 F.R.D. 345, 349 (E.D. Pa. 2000),
quoting Weisman v. Mediq, Inc., 1955 WL 273678, 1995 U.S. Dist. LEXIS 5900 *2 (E.D.
Pa. 1995). “Where a pending motion to dismiss may dispose of the entire action and
where discovery is not needed to rule on such motion, the balance generally favors
granting a motion to stay.” Weisman, 1995 U.S. Dist. LEXIS at *5.

In Weisman, in which this Court found that a motion to dismiss could be decided
on the pleadings, and could be decided in a relatively short time period, the Court granted
a stay of discovery. Similarly, in Norfolk Southern Rwy Co. v. Power Source Supply,
Inc., 2007 U.S. Dist. LEXIS 15306 (W.D. Pa. 2007), defendant filed a motion to dismiss
based on lack of subject matter jurisdiction; plaintiff served interrogatories and document
requests while that motion was pending. The court granted defendant’s motion for a
protective order staying discovery, ruling that, “where, as here, an objection to the
Court’s jurisdiction made under Rule 12 might compel the dismissal of an entire action,
the Court finds that considerations of fairness and efficiency suggest the prudence of
limiting discovery to those facts necessary to resolve the motion. Because the Parties in
this matter have fully briefed the jurisdiction issue and await only the Court’s ruling,

DMEAST #10127159 v1

3
Case 2:08-cv-04083-RBS Document 15 Filed 10/06/2008 Page 7 of 10

discovery in this case shall be stayed and Defendant protected from the requests that
Plaintiff has already propounded.” Id. at *4.

In this case, as in Weisman and Norfolk Southern Rwy., defendants’ pending
motion to dismiss for lack of subject matter jurisdiction would dispose of the entire
action. The motion does not involve any disputed issues of fact: defendants contend that,
as a matter of law, plaintiff lacks standing to challenge the qualifications of a candidate
for President and that there is no federal cause of action that could serve as a means for
such a challenge. Thus, discovery is not needed in order to rule on the motion. In these
circumstances, a stay of discovery is warranted and appropriate.

DMEAST #10127159 v1

4
Case 2:08-cv-04083-RBS Document 15 Filed 10/06/2008 Page 8 of 10

CONCLUSION
For the reasons set forth above, the Court should grant the motion of defendants
DNC and Senator Barack Obama for a protective order staying discovery pending a

decision on their motion to dismiss.
Respectfully submitted,
/s/ John P. Lavelle, Jr.
Dated: October 6, 2008 John P. Lavelle, Jr.
Attorney I.D. PA 54279
BALLARD SPAHR ANDREWS & INGERSOLL,
LLP
1735 Market Street, 51st Floor
Philadelphia, PA 19103
(215) 864-8603
(215) 864-9125 (Fax)
lavellej@ballardspahr.com
Of counsel:
Joseph E. Sandler

PLEASE TAKE NOTE: EMPHASIS ADDED TO POINT OUT THE ATTY FOR THE DNC AND OBAMA IS ALSO THE SAME ATTY WHO REPRESENTS LOUIS FARRAKKAN AND THE NATION OF ISLAM AMONG OTHER QUESTIONABLE CLIENTS! COINCIDENCE?? DOUBTFULL!

General Counsel, Democratic National Committee
SANDLER, REIFF & YOUNG, P.C.
300 M Street, S.E. #1102
Washington, D.C. 20003
Telephone: (202) 479-1111
Fax: (202) 479-1115  (Emphasis added)

Robert F. Bauer
General Counsel, Obama for America
PERKINS COIE
607 Fourteenth Street, N.W.
Washington, D.C. 20005-2003
Telephone: (202) 628-6600
Facsimile: (202) 434-1690

RBauer@perkinscoie.com

Attorneys for Defendants
Senator Barack Obama and
Democratic National Committee

DMEAST #10127159 v1

5
Case 2:08-cv-04083-RBS Document 15 Filed 10/06/2008 Page 9 of 10

IN THE UNITED STATES DISTRICT COURT
FOR THE EASTERN DISTRICT OF PENNSYLVANIA
PHILIP J. BERG, :
:
Plaintiff :
:
v. : Civ. Action No. 2:08-cv-04083-RBS
:
BARACK OBAMA, et al., :
:
Defendants :

CERTIFICATION PURSUANT TO LOCAL RULE 26.1(F)

Undersigned counsel for Defendants Democratic National Committee and Senator

Barack Obamahereby certifies pursuant to Local Rule 26.1(f) that the parties, after reasonable

effort, are unable to resolve the dispute that is the subject matter of Defendants’ Motion for

Protective Order Staying Discovery Pending Decision On Dispositive Motion.

/s/ John P. Lavelle, Jr.

Dated: October 6, 2008
John P. Lavelle, Jr.
Attorney I.D. PA 54279
BALLARD SPAHR ANDREWS & INGERSOLL, LLP
1735 Market Street, 51st Floor
Philadelphia, PA 19103

(215) 864-8603
(215) 864-9125 (Fax)
lavellej@ballardspahr.com

DMEAST #10127199 v1
Case 2:08-cv-04083-RBS Document 15 Filed 10/06/2008 Page 10 of 10

CERTIFICATE OF SERVICE

I hereby certify that on this day, a true and correct copy of the foregoing
Defendant Democratic National Committee’s and Defendant Senator Barack Obama’s
Motion for a Protective Order Staying Discovery Pending Decision on Dispositive Motion
and Brief in Support thereof was served by First Class U.S. Mail, postage prepaid, upon the
following:

Philip J. Berg, Esquire
555 Andorra Glen Court, Suite 12
Lafayette Hill, PA 09867

Plaintiff

Dated: October 6, 2008 /s/ John P. Lavelle, Jr.
John P. Lavelle, Jr.

DMEAST #10127407 v1

Jeez! Am I the only one who thinks it's getting too deep here? I mean instead of just showing the proof Obama and the DNC filed a motion to dismiss and then when Berg filed for discoverey ect. they request an order to delay any and all discovery until after the motion to dismiss has been ruled on. In other words ( I'm no lawyer) they don't want to respond or show proof. They filed to dismiss on grounds they don't think Berg has a case (yeah right) and when berg filed to force discovery (in other words show the documents) they ask the court to protect them from having to show proof until they get the judge to dismiss the case so they won't have to.

BULLSHIT! Show us the proof you fucking cowards! All this posturing and begging the court to do his bidding is just too much! They are wasting time and resources instead of simply digging out the documents requested and putting his money where his mouth is so to speak! For crying out loud! He wants the top job in the country and he gets insulted and asks for special treatment, special protection from the rules and laws the rest of us have to live by every time anyone questions him on qualifications, experience, eligibility, specific definitions of his "Hope" and "Change" you know little things like that.

I recently read a comment about how we should all just fall on our knees and worship the "great leader" instead of wasting time on such tiny, little technicalities. I suppose the Constitution is just a technicality then?

-how can you afford to be member at a prestigious country club AND pay for a caddy EVERY time you play?

I should have known better. It was all a house of cards.

Knowing what I have to do to "earn" what I do as a teacher. Albeit one who holds a second job as a caddy (weekends during the school year and full-time during the summers when I'm "off").

I should have known it was all a charade. Nick was right. Nick from Lehman Bros. that is. "It's all b.s., Mike." That's what he confided to me not so long ago.

I'm so glad to see someone finally call him out on this stuff! Mac hit hard with a dose of truth and I'm pretty sure we'll see a plethora of "news" articles claiming that his remarks were "racially tinged" tomorrow. it was worth it! That's the McCain that will fight tooth and nail to protect this country and it's citizens, ALL of them! Go john!

I'm sure everybody already heard and/or watched Sarah Palin making comments about Obama "pallin' around with terrorists" this weekend and saw that she may as well be an honorary PUMA now as the media immediately labeled her remarks as racist.

Then we have Dianne Feinstien constantly repeating the word assassination to Bob Schiffer Sunday morning. Apparently telling the truth about Obama is racist and means you are plotting his demise. or at least that seems to be the newest, sinister talking point of the Obamacrats. Well, you have to distract the voters somehow I guess.

I guess next they'll start talking about natzisms from GOP operatives and all the while handing out the brown shirts and sizing jack-boots!

CQ

   ¹⁷ But the wisdom from above is first of all pure. It is also peace loving, gentle at all times, and willing to yield to others. It is full of mercy and good deeds. It shows no favoritism and is always sincere. ¹⁸ And those who are peacemakers will plant seeds of peace and reap a harvest of righteousness.  James 13-18

Since my last post I have been asking God for direction on what would be a good topic to write about. In this time of elections and the economic stress the world is facing I believe it fitting this blog is about leadership.  In our world of abundant information this topic seems to be saturated with materials in areas of who is the most successful leader of our time as well what leadership style will lead a person to overwhelming control. 

A key element for an impactful leader is someone who has a listening ear. This person must hear in details that allow for the digestion of information in a concise manner.  Not only must the person be able to ingest rapidly flowing information, but must be able to store this information in the proper area so it can be of value when needed. Listening in detail provides the opportunity for the person speaking to feel the listener is engaged and values their thoughts.

One of the most dangerous aspects of being a leader is how we control our words. I must tell you that my train of thought is to tell truth and not to mince words.  My wife continues to inform me that it is ok to not mince words, but my delivery could be better.  Words can be destroyer or builders! Here is a place we need to find ourselves if we are leaders or not.   Understand this, my dear brothers and sisters: You must all be quick to listen, slow to speak, and slow to get angry. James 1:19.  Speaking is powerful and creates a deeper insight to us and individuals so let what we speak ring true to who God wants us to be seen as.

A servant heart is needed to be a leader who can intermingle with others.  Many times leaders remain a safe distance for others who they are leading. Using my experience as a current leader I find myself remaining in contact with people who I lead, but not close enough to the situation for all involved.  I do find it works well for some people, but others need more contact and connection while looking for nothing in return. With a servants heart we must use our leadership role to help others.  True servant leaders’ finds people are attracted to them not because they have to tell everyone they are a leader, but because people can feel the emotions a servant leader radiates.  Once we are in a leadership role with a serving heart we have to be prepared to place others lives before our own.

Reverting to one earlier thought about our economic situation and the election bring this part of leadership into full view.  We must be a humble  leader! Why do I say this… to be in a role of responsibility is truly a blessing for the Lord? Do leaders need to be people whose decisions are swayed by other opinions without careful contemplation? No! We have to be humble in the manner knowing that God is in control of all things and he is allowing us the opportunity to be a leader.  Therefore we must be clear in how be speak, how we interact and react to situations so we are not seen as a person who thinks they are in this alone.  By having a humble spirit in leadership we can empower others to support you as well as provide the confidence to others whereby they become leaders.

In closing in order for us to be the ultimate leader we must be patient in all things.  When there is an uprising against you and all the people you trusted have turned away, remember to patient because the Lord has the answer.  Patience will allow you trust the Lord and rejoice in all things.  The employee is struggling completing the task you felt should have been completed some time ago be patient for the Lord will reward you in your dealing with this person. Therefore being patient will lead you away from harshly judging of others.  We must all keep in mind that we can view this great leader exhibit all the attributes of being a model leader, but at any time they can fall.  So pray for your leaders at all times!! 

Grace and Peace to you,

Rod

To Sarah Palin
Another one bites the dust. When you arrived on the scene, you were interesting, dynamic, exciting. After only two months in the public eye, you're a soundbite. There was nothing more disappointing than to watch the VP debates and see the canned responses, the constant pounding away at the same points and the CLEARLY rehearsed performances by both candidates. I have watched as Barrack Obama, who I saw in 2004 and said "I wish HE was running for president", as national politics has changed him into a puppet head with the same crap flowing from him just like all the rest. I've watched so many candidates over the last twenty years who begin with "change" in their rhetoric and end up the same old, same old. Whoever coached you for the debate? Can them. Get rid of 'em. Stop telling us you're a hockey mom and a maverick and BE one. What is it about National politics that forces politicians to "follow the mold" and divide us by class, race and gender? I'm beginning to get a little cynical.
Just Sayin'

To Joe Biden
I began the debate prepared to dislike you. After all these years, Joe, I know what I'm going to get with you. I'll tell you a secret. You did well. I figured you'd toe the party line. After all, for the most part, you have for thirty-five years. But I was impressed that you managed to sound sincere. I haven't changed my mind about you, but I wanted to say "Good Job'.
Just Sayin'

To The Folks On Twitter
Especially the "2008 Election Twitter". I followed along with you during the first debate with Mcain and Obama, but I won't again. I was appalled at the animosity, the acrimonious responses to the candidates and the nasty comments. And it was BOTH sides. The absolute hatred for Sarah Palin is disturbing. The borderline comments about Obama were scary. And the feeling that if you said something that didn't follow the majority you'd be piled on was uncomfortable. I have NEVER understood the constant ugliness that seems to accompany politics online. To me, both sides have valid points for whoever they're trying to represent. I don't agree with certain things, to be sure. But I am NOT going vilify and sneer at the candidates who are running for higher office. I just don't get that.
Just Sayin'

To The Boys In The Back Room
Better pull out a miracle and fix the economy, boys. We go down, they ALL go down.
Just sayin'

To Loribelle Hunt and Jodi Henley
I have to give you credit for getting me a little closer to having an agent. Without you, Cup, I might not have met Jessica Faust at all. Without you, Lori, I might not have submitted a query to Ms. Faust last week. Apparently, I need kicks in the ass to move forward. Get your boots on, ladies.
Just sayin'

To Jonah
What the hell is this story you're giving me? You've been a pervy voice in my head for weeks and I'd REALLY like to move on now. Can we just finish this damn thing? And this whole alien sex thing? Not happy about it.
Just sayin'

To Kevin
The wrong heroine? Really? I swear I'll dump you off another crab fishing boat and you'll be "Lost at Sea" for ANOTHER eight years.
Just sayin'

To the Redneck
Thank you. For taking the dirt faced okie boys away for a couple of days and giving me some peace and quiet. Now, about those pictures.....
Just sayin'

America is a country that is searching for our all new rising star to razzle dazzle us.  It is time for us to search for an all new hero and leader.  Hopefully not like the last one.

Things to consider when voting...  Katie Couric Interview, Presidential Debate, Amount of money spent in iraq and money spent abroad. Do we have health care, jobs, and a stable social security for our future.  Due to Reganomics era of republican thinking, Now we have a bailout to the tune of 700 billion dollars and where is the money coming from and what will be the benefits to us.  (we really need to think through theses issues.

Every state is a swing state so everyone must get out and vote.  We need the election polls working overtime and we need every vote to count.

So what will the voters take from all of this?  With all the negativity coming from Washington and Wall Street, is it a good idea to start maliciously calling names and attacking loosely connected associates?  America needs solutions and leaders.  We have enough to be angry about from the past 7 years, why does John McCain think that giving America one more political ulcer will do anything more than hurt the so-called Maverick platform of "unity" and reform?  Seems to me that someone needs to tell the RNC that employing the same Rovian strategists that once cut down McCain in 2000, isn't a mode of reform, it is actually near pathologically destructive behavior.  This sort of poor judgment is conceptually on par with John McCain hiring his North Vietnamese torturers to  head up his cabinet on interrogation reform.

You can't call something reform if the form it takes is the same as before.

I am glad to see the Obama campaign calling the McCain camp on this series of attacks and hope to see them fight back with real leadership.  If the world has not yet seen how unimaginably unprepared Palin is to be a part of the national government, they need to step back and look again.  Now before someone lashes back at me about "her experience,"  I just want to say that I wouldn't give a pair of scissors to my infant to run around with anymore than they should have supplied Palin with cutting words such as terrorist.

When the Muslim Hussein brings up that lie about the lack of regulation on the Republicans part causing the "mortgage melt down" --- counter with the following:

Fuck you, Mr. Present (that's how he voted about 150 times on important legislation); it was "LIBERALSCUM regulation," that pushed, and pressured and sued (Obama sued Citibank to force them to make subprime loans) lending institutions to change the borrowing paradigm that I, my father, and his father followed to make this country great...plenty of people in this confused nation deserve to be homeless, and many are darkies based on their habits and own behavior.
___________________________________________________________________________
ORIGINAL POST:

During the next debate with the mulatto Muslim Hussein Obama, this coming Tuesday; I give you my permission to use the following wisdom and counter arguments on the Muslim, Barack Obama.

When Hussein brings up that lame brained idea, wherein he "claims" his desire to pull out of the Middle East and then use the freed up military resources in Afghanistan and Pakistan --- counter with the following:

One of the essential success elements of the Iraqi surge, has been the emboldened cooperation of freedom seeking Muslims with the "Coalition of the Free."

Early on during the second invasion of Iraq; freedom thinking Iraqis were extremely reluctant to cooperate with American forces. They were reluctant based on what happened to the Kurds after the first Iraqi War. America encouraged the the Kurds to rise up against Saddam, and when they did, America, a la Bush (the senior), Powell and Swartzcoff abandoned them. The abandonment of the Kurds by America lead to many Kurds being slaughtered by Saddam.

It took years and the stick-to-it-ness of George W Bush to bring the freedom minded Iraqis around to start informing on the Jihadists.

Pulling out of Iraq and then expecting the cooperation of the Afghanis and the Pakistanis to combat the Jihadists flies in the face of human self preservation. It is also foolish, naive and reeks of inexperience on Hussein Obama's part.

When Hussein Obama lies through his teeth and says he is only going to raise the taxes of the people in America making over $250,000 --- look in the camera and say:

The last time a Democrat candidate for president promised not to raise taxes, and then won the White House --- within days of moving in he said he could not do so.

Raising taxes is what Democrats do, and Hussein will do the same. Clinton called taxes a contribution; Hussein calls paying more taxes patriotic. Same ole shit; different day (clean that up John).

Hussein will also follow in Bill Clinton's leftist shoes, by trying to mainstream corn holers and muff divers in our military (John you may want to clean that up too).

NOW THAT I THINK ABOUT IT MY FRIENDS --- THE HUSSEIN ADMINISTRATION WILL BE A CONTINUATION OF THE CLINTON ADMINISTRATION --- Besides, my wife is a hell of a lot easier to look at than the angry negress Michelle.

P.S. Bring up the warning from the British Ambassador (HERE), pertaining to Hussein's inexperience.

Here they are:

BARACK HUSSEIN OBAMA, a/k/a

BARRY SOETORO, a/k/a

BARRY OBAMA, a/k/a

BARACK DUNHAM, a/k/a

BARRY DUNHAM

Of course no one in the media will ask the first term ingenue Senator about his many aliases, any more than they will press the hapless candidate about his associations with Bill Ayres, Tony Rezko, the Reverend Jeremiah Wright, Father Flager, the Chicago political machine, The Nation of Islam, the lawyers of CAIR etc., etc. And neither, apparently, will the McCain campaign.

We're on our own, friends and well wishers. Here is what all of this feels like.

N.

Credit: Right Truth.

Alpabetfiend is Dia VanGunten -- a writer & wanna be circus freak living in Austin, Texas.

WTF Friday: After the Debate? Angry & Frustrated.

Obama' Heroin Appears On Pa. Streets

Ring Operated Out Of Home With McCain Signs

KINGSTON, Pa. -- An illegal drug ring in Pennsylvania was selling 'Obama' printed packets of heroin out of a home with John McCain campaign signs on its porch, police said.

Click on the link for the rest. Now we know why Bots are so cranky! They need their Obama heroine! The Kool-Aide just isn't the same without it!

CQ

From the You Tube page where this is posted.

From: keepitwildtv
Added: October 02, 2008

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THE DEAN OF THE SCHOOL LIED! The kids chant, "Obama'...

THE DEAN OF THE SCHOOL LIED! The kids chant, "Obama's speech on race to America!" THAT WAS MARCH OF THIS YEAR!!!!!!!!!!

Category:  News & Politics

Tags: 

Obama  youth  sing  for  change  dear  leader  brownshirts 

This was pulled after the school was contacted. Watch it...it's sick. I DID NOT MAKE THIS VIDEO, BUT I DID SAVE A COPY YESTERDAY WHEN IT HAD ONLY 250 VIEWS. I'M JUST REPOSTING SO EVERYONE CAN SEE IT. MR.L GETS THE CREDIT FOR CALLING THE SCHOOL...NOT ME.

This from Mr. L's Tavern

MR.L on SINGING FOR CHANGE *MORE UPDATES*
Category: News and Politics

There's an update regarding the video with the African American teens shown on YouTube in the video below. This morning, I received a message from a friend named Dan who gave me the address of the school where this video was filmed. This is the name:

URBAN COMMUNITY LEADERSHIP ACADEMY
1524 PASEO BLVD
18th & Vine District, Kansas City, MO
Educational Organization

I called and spoke to Bernard, who said he was the assistant Dean. He was very gentlemanly and when I voiced my concerns about the video, he told me that this was taken at the school last year when Obama was beginning his campaign. He assured me that they stopped this "regiment" because they felt the person who was organizing it was pushing his political agenda.

Duh.

He assured me that he didn't know it was on YouTube. I gave him the link to where to go for this video and when he found it he said, "Oh this is not good. I had no idea" I told him I'd take his word for it. He then asked me, nicely, "what's the main concern? Because I want to understand where you're coming from so that I can figure out how to handle this."

Nicely, I told him that the video looked militant. I told him about the Colburn School video and how it resembles propaganda films from Communist dictatorships. I told him that the US military is frowned upon for going to high schools trying to recruit potential grads into joining their ranks. Why shouldn't we frown upon those who come to a school like yours to encourage kids to worship a politician? One who is not even a president.

I also said that if this was done to make kids feel better about themselves, why do it in the name of Obama? Why not encourage kids to believe in the power of themselves?

He assured me that he would get to the bottom of the situation, thanked me for my call and we hung up.

That's all for now.

So from this one would expect that Sarah Palin might have sounded more intellectual, but the flaw in their system is seen when looking at one of her closing sentences:

But higher grade level doesn't necessarily mean better sentence, Payack said. He pointed to Palin's second-to-last sentence in the debate, which the formula put at a grade level of 18.3:

"What I would do, also, if that were ever to happen, though, is to continue the good work he is so committed to of putting government back on the side of the people and get rid of the greed and corruption on Wall Street and in Washington," Palin said.

"When she said it, it sounded good, but on paper it's a completely different animal," Payack said. "It's like, what is that?"

I remember several other sentences. constructed by Palin, that cast a wide net over diverse and tenuously related topics.  So basically we have an analysis that has almost as much real intellectual value as the term "hockey mom" or by the findings of the Ig Noble scientists.

Somehow I am always reminded of Otto from A FIsh Called Wanda.  No this isn't because of the co-starring role of Michael Palin, but instead of Otto's insistance on appearing intelligent through publically reading and quoting lines from Nietzche.  Strangely enough, Palin also has the habit of harvesting lines from past politicians in order to make her lines look more eloquent than her points can support.  If the McCain campaign isn't borrowing lines from Herbert Hoover, Teddy Roosevelt, or an anti-Semite activist who once called for the assassination of Robert Kennedy; and they are borrowing the campaign slogans of George W. Bush and even Barrack Obama, they might want to start looking for a place to crash come election day.