on august 21, 2008, pennsylvania attorney philip j. berg, a democrat and former deputy state attorney general, filed a complaint alleging that obama was born in kenya, not hawaii, and was therefore a citizen of kenya or possibly indonesia, where he lived as a child. he alleged that the "certification of live birth" on obama's website is a forgery. u.s. district judge r. barclay surrick dismissed the complaint in october 2008, finding that berg lacked standing to bring the case and that his attempts to gain standing to pursue his claim were "frivolous and not worthy of discussion."