DC – Sibley v Obama – Quo Warranto I – US COA – Doc 2 – Reply in Support Summary Affirmance

REPLY IN SUPPORT OF APPELLEES’ MOTION FOR SUMMARY AFFIRMANCE

Appellees respectfully reply to appellant Montgomery Blair Sibley’s opposition to their motion for summary affirmance.

In his opposition, Sibley principally argues that this Court’s summary affirmance procedures are unlawful, see Opp. at 2-5, and that he has an “inalienable right” to full briefing and oral argument, see id. at 20. As Sibley does not dispute, however, under the law of this Circuit, summary affirmance may be granted “when the merits of the parties’ positions are so clear,” Gray v. Poole, 243 F.3d 572, 575 (D.C. Cir. 2001), that “no benefit will be gained from further briefing and argument of the issues presented,” Taxpayers Watchdog, Inc. v. Stanley, 819 F.2d 294, 297-98 (D.C. Cir. 1987) (per curiam); see also D.C. Circuit Handbook of Practice and Internal Procedures § VIII.G (2011) (discussing summary disposition and citing authorities).

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DC – Ex Rel. Sibley v Obama – Quo Warranto I – Doc 5 – Amended Complaint

After send a letter to the US Attorney Machen to request that he be heard by the Grand Jury

I write to request pursuant to 18 U.S.C. §3332 that you inform the grand jury of the following alleged offense committed by President Barack Obama, my identity, and your action or recommendation. Moreover, pursuant to 18 U.S.C. §1504, I request that you communicate to the Grand Jury my request to appear before the Grand Jury.

Sibley added some additional items to his complaints.

[5] AMENDED COMPLAINT against JOHN DOE #1, JOHN DOE #2, ERIC H. HOLDER, JR, RONALD C. MACHEN, JR, BARACK HUSSEIN OBAMA, II filed by MONTGOMERY BLAIR SIBLEY.(dr) (Entered: 01/31/2012)

Read the amended complaint below the fold.

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DC – Sibley v Obama – Quo Warranto I – US COA – Doc 1 – Motion for Summary Affirmance

IN THE UNITED STATES COURT OF APPEALS FOR THE DISTRICT OF COLUMBIA CIRCUIT

MONTGOMERY BLAIR SIBLEY, Petitioner/Plaintiff-Appellant,

v. No. 12-5198 BARACK OBAMA, et al.,

Respondents/Defendants-Appellees.

APPELLEES’ MOTION FOR SUMMARY AFFIRMANCE

Appellees respectfully move for summary affirmance of the district court’s order dismissing an amended petition and complaint filed by pro se appellant Montgomery Blair Sibley. See Memorandum Opinion (“Op.”), Sibley v. Obama, No. 12-CV-1 (D.D.C. June 6, 2012) (attached as Exhibit A). Summary affirmance is appropriate where, as here, the merits of a case are so clear that expedited action is justified and no benefit will be gained from further briefing or argument of the issues presented. Gray v. Poole, 243 F.3d 572, 575 (D.C. Cir. 2001); Taxpayers Watchdog, Inc. v. Stanley, 819 F.2d 294, 297-98 (D.C. Cir. 1987) (per curiam).

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