August 24, 2017

#DDS IN THE SUPERIOR COURT OF COBB COUNTY STATE OF GEORGIA Re; Case 17. 1. 5863. 28 Amendment to Petition

Posted by D.A. King at 9:53 am - Email the author   Print This Post Print This Post  








                     STATE OF GEORGIA
Re; 17. 1. 5863. 28 Amendment to Petition

D.A. King

Spencer R. Moore
Commissioner, Department of Driver Services


David W. Connell

Chairman, Board of Drivers Services




a) To correct and clarify inaccuracy created by Plaintiff’s unintentional one-word typo omission in original petition.

b) To add document (now Exhibit ‘I’) intended to quantify statement in original petition regarding Defendants’ participation in and knowledge of issuance of driver’s licenses and official ID Cards to recipients of deferred action on deportation.

c) To note and correct misspelling of the word “Plaintiff” in original petition.

a) Plaintiff asks to correct a typo emission of the word ‘some’ in a sentence contained in original petition section numbered “6” with the addition of the word ‘some’ as follows:


Under federal law, some aliens in these categories do not have lawful status, which is set by congress.”

The omission of the word ‘some’ makes the sentence inaccurate. It is Plaintiff’s intention to be as accurate as possible. I regret the accidental typo error/omission.

This error does not effect the Plaintiff’s main, well-documented argument that the Defendants oversee the DDS processing and issuance of drivers licenses and official ID Cards to aliens whose deportation proceedings have been delayed because they have granted Deferred Action for Childhood Arrivals (DACA) status and to aliens who have been granted deferred action on deportation outside of the DACA executive amnesty of 2012.

As noted throughout the petition, the federal government makes it clear that “deferred action does not provide lawful status.”

b) Plaintiff requests that attached response letter dated August 16, 2017 from Defendant Spencer R. Moore to Georgia state Senator Josh McKoon be made part of the original petition and regarded as Exhibit ‘I.’

This letter contains official statements regarding the number of driver’s licenses and official ID Cards issued by the Department of Driver Services – under the direction and authority of the defendants – to aliens who have received federal deferred action on deportation. The letter was written and sent after the original petition was filed and not available to the Plaintiff at that time.

c) Plaintiff recognizes a separate typo and offers an embarrassed apology for the typo misspelling of the word ‘Plaintiff’ in the original petition.

Respectfully submitted,
D.A. King