Blank Pleading Template with Line Numbering -- Word

Blank Pleading Template with Line Numbering -- Word

1 SUPERIOR COURT OF CALIFORNIA 2 COUNTY OF SACRAMENTO 3 ) Case No.34-2012-80001048 4 Edward C. Noonan, Pamela Barnett, ) Sharon Chickering, George Miller, ) 5 Tony Dolz, Neil Turner, Gary Wilmott ) [PROPOSED] ) PEREMPTORY WRIT/ 6 Petitioners, ) ALTERNATIVE WRIT FOR A ) EXPEDITED EVIDENTIARY HEARING 7 v. ) ON THE MERITS OF EVIDENCE AND ) FOR CONTINUANCE IN 8 Debra Bowen individually and officially ) SCHEDULING IN RESPONSE TO as The California Secretary of State ) BARACK HUSSEIN OBAMA II, OBAMA 9 at 1500 11th Street, 5th 18 Floor ) FOR AMERICA DEMURRER TO 10 Sacramento, CA, 95814; ) PETITIONERS’ PETITION FOR A Barack Hussein Obama II; OBAMA ) WRIT OF MANDATE and RESTRAINT 11 FOR AMERICA (CALIFORNIA) at ) OF FUND RAISING NORTHERN CALIFORNIA HQ 3225 ) 12 Adeline Street, Berkeley, CA 94703; John ) Date: March ____, 2012 and Jane Does and XYZ Entities. ) Time: 9:00 a.m. 13 ) Dept: 31 Respondents. ) Judge: Hon. Michael P. Kenny 14 ______________________________ ) ) Action Filed: January 6, 2012 15 ) 16 17 TO: Debra Bowen, The California Secretary of State, Barack Hussein Obama II; 18 OBAMA FOR AMERICA (CALIFORNIA), The California Attorney General, Edward C. 19 Noonan, Sharon Chickering, George Miller, Tony Dolz, Neil Turner, and Gary Wilmott, 20 Respondents 21 WHEREAS it is alleged by the Ex Parte Petitioner Pamela Barnett, self represented 22 without an attorney, having affirmed an application on March 14, 2012 with exhibits 23 annexed and Memorandum of Points and Authorities in support of an Peremptory Writ for 24 25 stay and interim discovery with Alternative Writ for an Expedited evidentiary hearing 26 before March 29, 2012 on the merits of the evidence and a continuance in scheduling in 27 response to the Demurrer and Memorandum of Respondent Barack Obama et al. signed 28 1 1 February 15, 2012, that this Alternative Writ is required because on January 6, 2012 2 Petitioner’s evidence that Barack Obama was at least “Born a Citizen” under the 14th 3 Amendment definition rather than a “natural-born Citizen”, with a British subject father 4 already established, and on March 1, 2012 is proven wrong by the COLD CASE POSSE 5 Preliminary Report that the same 2012 CoLB is forged that raises suspicion that Barack 6 Obama is not even “Born a Citizen” in the USA per se, and further alleged supported by 7 8 evidence of falsification, spoliation, concealment of records, admissions against interest 9 under Barack Obama’s control that substantiates need for ordering expedited interim 10 discovery for expedited evidentiary hearing on the merits by March 26, 2012 as printing of 11 ballots starts on March 29, 2012, and to eliminate the calendar for such purpose in its 12 entirety; 13 WHEREAS it appears that petitioner is a party beneficially interested in this 14 proceeding; and 15 16 WHEREAS it appears from the affirmed application that Petitioner has no plain, 17 speedy, and adequate remedy in the ordinary course of law and that an alternative writ of 18 mandate should issue; 19 20 NOW THEREFORE, you are commanded, immediately on the receipt of this writ: 21 1. That the Court issue an alternative writ in the first instance commanding Respondents 22 23 to court to conduct a hearing in open court on Barack Obama’s ballot access at the 2012 24 Election cycle, and to consider all requests by the Petitioners and Respondents as to 25 ballot access of Barack Obama and to continue as been filed. 26 1A. That the court alternatively issue an alternative writ commanding Respondent to Court 27 to conduct a hearing in open court on Barack Obama release of the August 1, 1961 28 2 1 though August 7, 1961 travel microfilm evidence and the Barack Obama release of 2 evidence as to why he should not be barred from the ballot proving that he is actually a 3 “natural-born Citizen” born in the U.S.A. of U.S. Citizen parents; and 4 2. That the court issue a Peremptory Writ for Temporary Stay of CA SOS ballot 5 printing until further order become permanent as to Barack Obama; 6 2A. That the Court issue an alternative writ instance commanding Respondents to 7 8 court to conduct a hearing in open court That the court deny the Respondent Obama et 9 al. Demurrer filed February 16, 2012 in its entirety in regards to the January 6, 2012 10 Prerogative Writ of Mandamus Petition. 11 2B. That the court grant a continuance for CA SOS opportunity to amend the 12 demurrer or answer to the Prerogative Writ of Mandamus Petition subsequent to this 13 Alternative Writ evidentiary hearing on the merits or about March 26, 2012 is decided; 14 2C. That the court grant a continuance in scheduling on the January 6, 2012 15 16 Petition for prerogative writ of mandamus with stay and injunction hearing subject to the 17 Alternative writ. 18 2D. That the court grant a continuance in scheduling with sufficient reason that 19 would require an amended Petition filed nunc pro tunc. 20 2E. That the court grant for further and different relief that the Court deems 21 necessary for speedy justice herein. 22 23 24 The writ shall be served on Respondent and Real Party in Interest before 25 ___________, 2012. 26 [The written return, if any, to this writ shall be filed and served by Respondent or Real 27 Party in Interest on or before __________, 2012.] 28 3 1 DATED: _________________________________ 2 Clerk of the Court 3 4 By ____________________________ Deputy Clerk 5 ORDER 6 Let the foregoing writ issue. 7 8 IT IS FURTHER ORDERED that a copy of this alternative writ (and a copy of the 9 petition) be served at least _______ days before the hearing on the above order to show cause. 10 11 DATED: ___________________________________ 12 Judge of the Superior Court 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 4 1 SUPERIOR COURT OF CALIFORNIA 2 COUNTY OF SACRAMENTO 3 ) Case No.34-2012-80001048 4 Edward C. Noonan, Pamela Barnett, ) Sharon Chickering, George Miller, ) ORDER for EX PARTE PAMELA 5 Tony Dolz, Neil Turner, Gary Wilmott ) BARNETT’S PEREMPTORY WRIT ) WITH ALTERNATIVE WRIT FOR A 6 Petitioners, ) ) EXPEDITED EVIDENTIARY HEARING 7 v. ) ON THE MERITS OF EVIDENCE AND ) FOR CONTINUANCE IN 8 Debra Bowen individually and officially ) SCHEDULING IN RESPONSE TO as The California Secretary of State ) BARACK HUSSEIN OBAMA II, OBAMA 9 at 1500 11th Street, 5th 18 Floor ) FOR AMERICA DEMURRER TO PETITIONERS’ PETITION FOR A 10 Sacramento, CA, 95814; ) Barack Hussein Obama II; OBAMA ) WRIT OF MANDATE and RESTRAINT OF FUND RAISING 11 FOR AMERICA (CALIFORNIA) at ) NORTHERN CALIFORNIA HQ 3225 ) Date: March ____, 2012 12 Adeline Street, Berkeley, CA 94703; John ) Time: 9:00 a.m. and Jane Does and XYZ Entities. ) 13 ) Dept: 31 Respondents. ) Judge: Hon. Michael P. Kenny 14 ______________________________ ) ) Action Filed: January 6, 2012 15 ) 16 17 That Ex Parte Petitioner Pamela Barnett, self represented without an attorney, 18 having affirmed an application on March 14, 2012 with exhibits annexed and 19 Memorandum of Points and Authorities in support of an Peremptory Writ for stay and 20 interim discovery with Alternative Writ for an Expedited evidentiary hearing before March 21 29, 2012 on the merits of the evidence and a continuance in scheduling in response to the 22 Demurrer and Memorandum of Respondent Barack Obama et al. filed February 15, 2012, 23 and there being sufficient reason with additional evidence provided hereby, that this 24 25 Alternative Writ is required because on January 6, 2012 Petitioner’s evidence that Barack 26 Obama was at least “Born a Citizen” under the 14th Amendment definition rather than a 27 “natural-born Citizen”, with a British subject father already established, and on March 1, 28 1 1 2012 is proven wrong by the COLD CASE POSSE Preliminary Report that the same 2012 2 CoLB is forged that raises suspicion that Barack Obama is not even “Born a Citizen” in the 3 USA per se; and further alleged supported by evidence of falsification, spoliation, 4 concealment of records, admissions against interest under Barack Obama’s control that 5 substantiates need for ordering expedited interim discovery for expedited evidentiary 6 hearing on the merits by March 26, 2012 as printing of ballots starts on March 29, 2012. 7 8 It is ORDERED that Debra Bowen, The California Secretary of State, Barack Hussein 9 Obama II; OBAMA FOR AMERICA (CALIFORNIA) by its agents, are hereby stayed from 10 printing or placing on the primary ballot of the respective party to be held on June 5, 2012 11 any of the names of the electors slates for the purported candidates for the office of 12 POTUS for BARACK OBAMA, until a hearing and appearance of Respondents or by his / 13 her attorney to show cause why the stay should be lifted. 14 It is ORDERED that Debra Bowen, The California Secretary of State, Barack Hussein 15 16 Obama II; OBAMA FOR AMERICA (CALIFORNIA) by its agents, are hereby to respond to 17 a subpoena Barack Obama to release the August 1, 1961 though August 7, 1961 travel 18 microfilm and that Barack Obama release evidence why he should not be barred from the 19 ballot proving that he is actually a “natural-born Citizen” born in the U.S.A. of U.S. Citizen 20 parents for interim discovery in preparation for the Hearing on ________________ 21 It is ORDERED that a continuance is granted for CA SOS opportunity to amend the 22 23 demurrer or answer to the Prerogative Writ of Mandamus Petition subsequent to this 24 Alternative Writ evidentiary hearing on the merits or about March ___, 2012 is decided.

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