Case 3:12-cv-00280-HTW-LRA Document 27

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IN THE UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF MISSISSIPPI JACKSON DIVISION DR. ORLY TAITZ, ESQ., BRIAN FEDORKA, LAURIE ROTH, LEAH LAX, and TOM MacLERAN VS.

DEMOCRAT PARTY OF MISSISSIPPI, SECRETARY OF STATE MISSISSIPPI, BARAK HUSSEIN OBAMA, OBAMA FOR AMERICA, NANCI PELOSI, DR. ALVIN ONAKA, LORETTA FUDDY, MICHAEL ASTRUE, JOHN DOES, JOHN DOES 1-100

MISSISSIPPI DEMOCRATIC PARTY EXECUTIVE COMMITTEES MOTION TO STRIKE PLAINTIFFS MOTION FOR SANCTIONS PURSUANT TO FEDERAL RULE OF CIVIL PROCEDURE 5.2. COMES NOW the Mississippi Democratic Party, through its governing entity, the Mississippi

hereby moves the Court to strike from the record Plaintiffs Motion for Sanctions and all attached exhibits (Exhibits) pursuant to Federal Rule of Civil Procedure 5.2 and states the following: 1. Federal Rule of Civil Procedure 5.2 (a) provides, in relevant part, that [u]nless the court orders

number . . . a party or nonparty making the filing may include only . . . the last four digits of the

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social-security number.

2. Plaintiffs Exhibits contains numerous unredacted and/or improperly redacted social-security numbers, along with allegations as to individual(s) to whom such numbers have been assigned.

3. Plaintiff Taitz has a long history of flouting Rule 5.2, despite being admonished and threatened with sanctions for doing so. See, e.g., Barnett Keyes et al v Obama et al, No. 8:09-cv-00082-DOC-AN,

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otherwise, in an electronic or paper filing with the court that contains an individuals social-security

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Democratic Party Executive Committee (MDEC), and by and through its undersigned counsel, and

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PLAINTIFFS

CIVIL ACTION NO. 3:12-cv-280 HTW-LRA DEFENDANTS

Case 3:12-cv-00280-HTW-LRA Document 27

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Order Sealing Document Requiring Plaintiffs to Refile Opposition to Motion to Dismiss to Comply with Fed. R. Civ. P. 5.2 (C.D. Cal. Sept. 29, 2009) (Exhibit 1)(ordering that Taitz pleading be removed from public record for Rule 5.2 violation and that Taitz must refile properly redacted

document); Taitz v. Astrue, CIV.A. 11-402 RCL (D.D.C.), June 2, 2011 Order (Exhibit 2) (ordering that Taitzs pleadings be removed from public record and placed under seal due to Rule 5.2 violation); July 21, 2011 Order (Exhibit 3) (granting motion to strike Taitzs pleading filed in violation of Rule 5.2); July 25, 2011 Memorandum & Order (2011 WL 3039167) (Exhibit 4) (finding that [Taitz] is either toying with the Court or displaying her own stupidity [because] [t]here is no logical explanation she can provide as to why she is now wasting the Court's time, as well as staff's time, with these

documents); July 25, 2011 Order (Exhibit 5) (requiring that two versions of a document submitted by Taitz not be docketed or placed in public record due to Rule 5.2 violation but that documents be kept for consideration of possible sanctions against Taitz).

4. The MDEC requests that the Court dispense with the requirement of filing a separate Memorandum of Authorities under the Local Rules in support of this opposition as the reasons and authorities supporting this opposition are fully set forth above.

hereby moves the Court to grant its Motion to Strike Plaintiffs Motion for Sanctions and assess to the

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Plaintiff all costs for bringing the instant motion. THIS the 16th day of May, 2012. Respectfully submitted, THE MISSISSIPPI DEMOCRATIC PARTY EXECUTIVE COMMITTEE

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WHEREFORE, PREMISES CONSIDERED, the Mississippi Democratic Party Executive Committee

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improper redactions, and denying Taitzs motion for reconsideration or prior order striking

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Case 3:12-cv-00280-HTW-LRA Document 27

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OF COUNSEL: BEGLEY LAW FIRM, PLLC P. O. Box 287 Jackson, MS 39205 (601)969-5545 (Telephone) (601)969-5547 (Facsimile) Email: sbegley1@bellsouth.net SCOTT J. TEPPER GARFIELD & TEPPER 1801 Century Park East, Suite 2400 Los Angeles, CA 90067-2326 (310) 277-1981 (310) 277-1980 Email: scottjtepper@msn.com

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By: /s/ Samuel L. Begley Samuel L. Begley (MSB No. 2315) By: /s/ Scott J. Tepper Scott J. Tepper (Admitted pro hac vice)

Case 3:12-cv-00280-HTW-LRA Document 27

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CERTIFICATE OF SERVICE

The undersigned hereby certifies that on the date set forth hereinafter, a true and correct copy of the above and foregoing document was electronically filed with the Clerk of the Court using the ECF system which sent notification of such filing to the following: Harold E. Pizzetta, Esq. Justin L. Matheny, Esq. Office of the Attorney General 550 High Street, Suite 1200 P.O. Box 220 Jackson, MS 39205 Scott J. Tepper Garfield & Tepper 1801 Century Park East, Suite 2400 Los Angeles, CA 90067-2326 scottjtepper@msn.com

And to the following persons by email: Brian Fedorka Bfedorka82@gmail.com Laurie Roth drljroth@aol.com

Leah Lax Leahlax1234@aol.com Tom MacLeran mac@macleran.com

THIS the 16th day of May, 2012.

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/s/ Samuel L. Begley_________ SAMUEL L. BEGLEY

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Orly Taitz, Esq. 29839 Santa Margarita Parkway, Suite 100 Rancho Santa Margarita, CA 92688

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