Broe v. Reed: Motion for Expedited Discovery, Subpoenas
December 16th, 2008
Yesterday, DecaLogosIntl.org reported that James Broe, one of 13 Plaintiffs in Broe v. Reed, has filed a motion for expedited discovery and authority to issue subpoenas in Washington State Supreme Court:
Names and Designation of Persons Filing Motion
COMES NOW, James E. Broe, Kenneth R. Seal, Robert Baker, Mark Sussman, Stan Walter, Bill Wise, Andy Stevens, Ed Crawford, Jason Lagen, Louise Workman, Jocelyn Murcelli, Mike Murcelli and Kevin McDowell, by and through counsel of record Stephen Pidgeon, pursuant to RAP 17.3(a), the Rules of Discovery, CR 26-37, and CR 45 governing the issuance of subpoenas, and Move this Honorable Court for an order allowing the issuance of two subpoenas for the purpose of obtaining admissible evidence in this case, and expediting discovery pursuant to the proposed schedule.
Relief Requested
Plaintiffs seek an Order allowing plaintiffs expedited discovery by means of two subpoenas, one to be served on the Secretary of State of the State of Washington, to discover the following items: I) the Declaration of Candidacy of Barack Obama as filed in the State of Washington; 2) all records concerning the candidacy and disallowance of Socialist Worker’s Party candidate Frank Colero within the Secretary of State’s office; and one to be served upon the Director of the Department of Health in the State of Hawaii, to discover the following items: 3) the Birth Certificate of Barack Obama in Hawaii, and 4) all supporting documentation regarding the registration of the birth of Barack Obama in Hawaii. Plaintiffs seek an order which establishes the following schedule.
Plaintiffs are to serve the Secretary of State of the State of Washington with a Subpoena in the form attached hereto as approved by the Court no later than the close of business on Friday, December 19, 2008, and responses shall be served upon Plaintiffs’ counsel Stephen Pidgeon no later than the close of business on December 28, 2008.
Plaintiffs are to serve the State of Hawaii Department of Health with a Subpoena in the form attached hereto as approved by the Court no later than the close of business on Monday, December 22, 2008, and responses shall be served upon Plaintiffs’ ‘counsel. no later than the close of business on December 28, 2008.
Associated PDF documentation:
MOTION FOR EXPEDITED DISCOVERY AND FOR AUTHORITY TO ISSUE SUBPOENAS
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