Motion for Leave to Take Depositions 30 Dec 2011
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MOTION FOR LEAVE TO TAKE DEPOSITIONSNow come Plaintiffs Carl Swensson and Kevin Richard Powell, by and through undersigned counsel, and respectfully move the Court, pursuant to O.C.G.A. §§ 50-13-41 (a) (2) and 50-13-13 (a) (6); OSAH Rules 616-1-2-.15 and 616-1-2-.20; and other applicable law, for leave to take depositions in each of the above-styled cases, and Plaintiffs show to the Court the following:1. The above-captioned cases are actions in which Plaintiffs are challenging the qualifications of Defendant Barack Obama to appear on the voting ballot in Georgia as a candidate for the Presidency of the United States.