“Berg’s amended complaint makes mention of Obama’s bogus birth certificate and failure to produce the real thing.” Phil Berg v Barack Obama


Are they fake or real?


Following is an excerpt fromthe response:


Plaintiff, Philip J. Berg, Esquire [hereinafter “Plaintiff”] files the within Response in Opposition to Defendants, Barack H. Obama [hereinafter “Obama”] and the Democratic National Committee [hereinafter “DNC’] Motion for Protective Order Staying Discovery Pending Decision on Defendants Dispositive Motion on the following grounds:

1. Defendants’ pending Motion to Dismiss does not entitle them to a Protective Order under Federal Rule of Civil Procedure 26(c) [hereinafter F.R.C.P. 26(c];

2. Defendants have failed to show “good cause” and are therefore not entitled to a protective order under F.R.C.P. 26(c);

3. Defendants have not pointed to any legitimate privacy concerns. Defendants have failed to point out any substantiated specific examples demonstrating that disclosure will cause a defined and serious injury;

4. Plaintiff does not seek access to the requested information for any improper purpose;

5. Defendants have not shown any risk that particularly serious embarrassment will result from the requested documents;

6. The requested information is extremely important for public safety; and “Good Cause” requires a particular need for the protection sought;

7. The sharing of information will promote fairness and efficiency so as not to delay this action;

8. Barack Obama, as U.S. Senator of Illinois and the Democratic Nominee for President of the United States, is a public person, and his citizenship status is a matter of significant public concern and is subject to legitimate public scrutiny. The Democratic National Committee is a public entity and is also subject to public scrutiny; and 9. The public interest in access to the requested information under the Freedom of Information Act 5 U.S.C. § 552 is a strong factor in favor of not granting a protective order which would prevent disclosure of such information.



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To: pissant

From Berg’s amended complaint that makes mention of his bogus birth certificate, and failure to produce the real thing:

In response to all the requests for Obama to produce proof of his citizenship, Obama allowed the Daily Kos to post on their website http://www.dailykos.com. an image of a Certification of Live Birth with Obama’s name on it purporting to be Obama’s birth certificate.

This same image was also placed on Obama’s website, http://fightthesmears.com and on another website located at http://factcheck.org.

The image placed on these websites is of a Hawaiian document which is provided for children’s births in Hawaii as “natural born”, as well as births abroad, which have been registered in Hawaii, whether the citizenship status was “natural born” or “naturalized.”

Thus, the image did not prove Obama’s citizenship status as a “natural born” United States Citizen. The images placed on these three (3) websites were later discovered by Independent Graphic Specialists to be altered and forged images.

Defendants have not demonstrated that the first factor of the Pansy test applies because they fail to point to any legitimate privacy concern. Obama waived any privacy and/or confidentiality concern with regard to his birth certificate when he allowed a document purporting to be “his” Certification of Live birth on the internet at three (3) different websites. Obama also wrote in his book “Dreams from my father” about his Indonesian life and therefore waived any privacy and/or confidentiality issues with regard to his citizenship status in Indonesia. In addition, in interviews with newspapers and news stations, Obama openly talked about his trip to Pakistan, India and Indonesia, and waived any privacy and/or confidentiality concern with respect to that trip. Therefore, Defendants have failed to demonstrate that the first factor of the Pansy test favors a protective order.

Soetoro, M.A. a citizen of Indonesia. Signed a Government “Acknowledgement” form legally acknowledging you as his son. Admissions,

Request No. 7. Admit you are an Indonesian citizen. Admissions,

Request No. 8. Admit you are currently not a “natural born” United States citizen. Admissions,

Request No. 9. Admit you are not eligible to serve as the President of the United States pursuant to Article II, Section I of the United States Constitution. Admission,

Request No. 10. Admit you are unable to prove your citizenship status. Case 2:08-cv-04083-RBS Document 18 Filed 10/09/2008 Page 18 of 22 Plaintiff

Requests the Court to Order the DNC to Serve upon Plaintiff Answers to the following Admissions by October 15, 2008: Admissions,

Request No. 1. Admit you have not verified Barrack Hussein Obama’s eligibility to serve as President of the United States. Admissions,

Request No. 2. Admit Barrack Hussein Obama was born in Kenya. Admissions,

Request No. 3. Admit Barack Hussein Obama’s citizenship status was changed to a “natural” citizen of Indonesia when his stepfather, Lolo Soetoro, M.A. legally “acknowledged” Obama as his son. Admissions,

Request No. 4. Admit Barack Hussein Obama’s name was legally changed to Barry Soetoro, an Indonesian citizen. Admissions,

Request No. 5. Admit Barrack Hussein Obama is not currently a “natural born” United States citizen. Admissions,

Request No. 6: Admit you have not inquired into Barrack Hussein Obama’s citizenship status. Admissions,

Request No. 7. Admit the United States Constitution does not allow for a Person to hold the office of President of the United States unless that person is a “natural born” United States citizen. Admissions,

Request No. 8. Admit you collected donations on behalf of Barack Hussein Obama for his Presidential campaign. Admissions,

Request No. 9. Admit the DNC has promised Plaintiff and all American citizens that the DNC will ensure Open and Honest Government and uphold the United States Constitution to protect the United States citizens.. Admissions,

Request No. 10. Admit Barack Hussein Obama is not a legal citizen of the United States

You can download the complete filing at


56 posted on Thursday, October 09, 2008 10:32:25 PM by Polarik

See also:


Phil Berg Barack Obama Ron Polarik Jeff Schreiber

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