Berg response in oppostion to Obama / DNC protective order

Thursday, 09 October 2008 21:38 administrator

Attached is Philip J. Berg's Opposition to Defendants, the DNC and Obama's Motion for Protective Order Staying Discovery pending Decision on their Motion to Dismiss. If the Protective Order were granted, discovery could not occur until the standing issue has been resolved and only if it is in favor of the plaintiff.

Following is an excerpt from the response:

PLAINTIFF’S RESPONSE IN OPPOSITION TO DEFENDANTS BARACK H. OBAMA AND THE DEMOCRATIC NATIONAL COMMITTEE’S MOTION FOR A PROTECTIVE ORDER STAYING DISCOVERY PENDING DECISION ON DISPOSITVE MOTION

Plaintiff, Philip J. Berg, Esquire [hereinafter “Plaintiffâ€