OFFICE OF STATE ADMINISTRATIVE BEARINGS

CARL SWENSSON,
Plai.ntiff
v.
BARACK OBAMA,
D.fendant
STATE OF GEORGIA





DOCKET NO . : OSAB-SECSTATE-CE-
1216218-60-MALIBI
OFFICE OF STATE ADMINISTRATIVE HEARINGS
KEVIN RICHARD POWELL,
Plaintiff
v.
BARACK OBAMA,
Defendant
STATE OF GEORGIA





DOCKET NO ., OSAB-SECSTATE-CE-
1216823-60-MALIBI
CITATION FOR CONTEMPT
Now come Plaintiffs Carl Swensson and Kevin Richard Powell ,
by and through undersigned counsel , and move the Court , pursuant
to O.C . G.A. 50 - 13- 13(b) and OSAH Rule 616- 1- 2-. 22 (5), to
certify to the Superior Court o f Fulton County certain facts ,
relative to the contemptuous behavior oI the Dexendant before
t hi s Court , for a determination o f appropri ate action, including
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a finding .of In support of this Citation For Contemp.t ,
Plaintiffs show to the Court the following facts-:
1 . On or aboQt January 19, 2012 , undersigned counsel
Plaintiffs served upon defense counsel a "Notice to Produce, "
requiring Oeendant BaLack Obama to appear at the January 26 ,
2012 trial of this matter and to bring with him into Court
certain documents and other items to be used as evidence by the
Plaintiffs at
2 . Defense counsel made no response to PlaintiIfs ' Notice
to Produce. Defense counsel filed no motion for protective
order , motion to quash the Notice to Produce , or any other
pleading objecting to the Notice to
3. Despite being timely served with the aforesaid _Notice
to Produce, Defendant Obama failed to appear for the trial of
these matters on January 26 , 2012. Likewise , Defendant ' s
attorney also failed to appear for trial. None of the documents
or other evidence sought by Plaintiffs wa s produced as required
by Plaintiffs ' Notice to Produce .
4. The failure of Defendant Obama (and defense couns_ell to
appear for trial on January 26 , 2012 was knowing, intentional,
and deliberate, as demonstrated by Exhibit 12, a
January 25 , 2012 letter written by defense counsel to Georgia
Secretary of State Brian Kemp.
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54 Defendant Ohama ' s behavior in failing to comply w_i-th
Plaintiffs ' Notice to Produce by appearing for trial with the
requested documentary and other evidence demonstrates Defendant's
contempt for this Court and for the judiciary generally.
6.. OSAH Rule 6 ~ 6 - 1 - 2 - . 2 2 (5) provides , in p.ertinent part ,
that the Administrative Law Judge , upon application of a party,
shall certify the facts to the superior court of the county in
which a party, agent , or employee of a party: disobeys or resists
any lawful order or process ; neglects to produce, after having
been ordered to do so, any pertinent book, paper , or document ; or
refuses to appear after having been subpoenaed, for a
determination of the appropriate action, including a finding of
contempt.
7. Plaintiffs hereby request that this Court certify the
foregoing facts to the Superior Court of Fulton County for a
determination of the appropriate action to be taken with regard
to Defendant ' s contemptuous conduct.
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WHEREFORE, Plaintiffs pray that the relief %eguested herein
be granted .
This 1st day of February, 2012 .
201 Albany Avenue
P . O. Box 1361
Waycross , Georgia 31502
(912) 283-3820
HATFIELD & HATFIELD, P.C.
J .
Att
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P aintiffs
No . 337509
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CERTIFICATE OF SERVICE
I, J. Mark Hatfield, Attorney f or Plaintiffs , do hereby
certify that , pursuant to the Order entered in the above-
captioned matters regarding electronic service , I have this day
served the foregoing Citation For Contempt upon:
Michael Jablonski
michael.j abloo ski@coIDcast . net
by email addressed thereto in order to insure proper delivery .
This 1st day of February, 2012.
201 Albany Avenue
P.O. Box 1361
Waycross , Georgia 31502
(912) 283-3820
HATFIELD & HATFIELD, P. C.
Att rney for
Georgia Bar No.
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