OFFICE OF STATE ADMINISTRATIVE BEARINGS

Ii!! .J 7 2 '0 1 ' ,f .., ;.; ;- 1

STATE OF GEORGIA

*
I ,
CARL SWENSSON,
-------.-------. -7-.---"----
Kc.:'. !;1 \\"\.'''-trava .\"\)l,,,fJr',t
Plaintiff
v.
BARACK OBAMA,
Defendant
*
*
*
*
DOCKET NO.: OSAH-SECSTATE-CE-
1216218-60-MALIBI
OFFICE OF STATE ADMINISTRATIVE BEARINGS
STATE OF GEORGIA
KEVIN RICHARD POWELL,
*
Plaintiff
v.
BARACK OBAMA,
Defendant
*
*
*
*
DOCKET NO.: OSAH-SECSTATE-CE-
1216823-60-MALIBI
NOTION FOR EXTENSION OF TIME
TO RESPOND TO MOTIONS TO DISMISS
Now come Plaintiffs Carl Swensson and Kevin Richard Powell,
by and through undersigned counsel, and respectfully move the
Court for an extension of time to file Plaintiffs' Responses to
Defendant's Motions to Dismiss in each of the above-styled cases,
and Plaintiffs show to the Court the following:
Page -1-
F
r
i
e
n
d
s

o
f

T
h
e
F
o
g
B
o
w
.
c
o
m

1.
The above-captioned cases are actions in which Plaintiffs
are challenging the qualifications of Defendant to appear on the
voting ballot in Georgia as a candidate for the Presidency of the
United States.
2.
On December 15, 2011, counsel for Defendant filed in each of
the above-referenced cases a pleading styled as a to
Dismiss," with an Affidavit of Michael R. Berlon and a
of Material Facts Not in Dispute" included therewith.
3.
It appears to undersigned counsel for Plaintiffs that the
aforesaid to Dismiss" are in actuality motions for
summary determination pursuant to OSAH Rule 616-1-2-.15 and that
Plaintiffs would have twenty (20) days after December 15, 2011,
or until Wednesday, January 4, 2012, within which to respond to
Defendant's aforesaid Motions. In that regard, opposing counsel
Jablonski has heretofore indicated to undersigned counsel his
(opposing counsel's) opinion that the twenty (20) day response
period under the summary adjudication rule is applicable.
4.
Undersigned counsel anticipates the need to take certain
depositions in order to respond to Defendant's Motions, including
the deposition of Michael R. Berlon and perhaps the deposition of
Page -2-
F
r
i
e
n
d
s

o
f

T
h
e
F
o
g
B
o
w
.
c
o
m

Georgia Secretary of State Brian Kemp. Undersigned counsel would
seek to conduct depositions during the first week of January
2012.
5.
In light of the foregoing, undersigned counsel seeks an
extension of time within which to respond to Defendant's "Motions
to Dismiss" until and including Friday, January 13, 2012.
WHEREFORE, Plaintiffs respectfully request that Plaintiffs
be granted an extension of time within which to respond to
Defendant's Motions to Dismiss in each of the above-styled cases
until and including Friday, January 13, 2012.
Respectfully submitted, this 22nd day of December, 2011.
201 Albany Avenue
P.O. Box 1361
Waycross, Georgia 31502
(912) 283-3820
HATFIELD & HATFIELD, P.C.
ney for P
Georgia Bar No.
Page -3-
F
r
i
e
n
d
s

o
f

T
h
e
F
o
g
B
o
w
.
c
o
m

CERTIFICATE OF SERVICE
I, J. Mark Hatfield, Attorney for 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 Motion For Extension of Time to Respond to
Motions to Dismiss upon:
Michael Jablonski
michael.jablonski@comcast.net
by email addressed thereto in order to insure proper delivery.
This 22nd day of December, 2011.
201 Albany Avenue
P.O. Box 1361
Waycross, Georgia 31502
(912) 283-3820
HATFIELD & HATFIELD, P.C.
ark Hatfi ld
rney for 'ntiffs
Georgia Bar No. 337509
F
r
i
e
n
d
s

o
f

T
h
e
F
o
g
B
o
w
.
c
o
m