Professional Documents
Culture Documents
1
2
3 Dr. Orly Taitz, esq
29839 Santa Margarita Parkway, STE 100
4 Rancho Santa Margarita CA 92688
Tel: (949) 683-5411; Fax (949) 766-7603
5 E-Mail: dr_taitz@yahoo.com
6 UNITED STATES DISTRICT COURT
7 FOR THE DISTRICT OF COLUMBIA
17 USC 1985
18 RICO
23
24 FIRST AMENDED COMPLAINT
25
Jurisdiction
26
The court has jurisdiction under DC statute §§16-3501- 16-3503. Federal court is
27
proper as diversity between the parties exist and the case revolves around the
28
Federal Question of eligibility of the President under Quo Warranto
Parties
Complaint Taitz v Obama District of Columbia 1
Case 1:10-cv-00151-RCL Document 16 Filed 03/22/10 Page 2 of 145
1
2
3 Plaintiff – Dr. Orly Taitz, ESQ- hereinafter “Taitz.” The plaintiff is a resident of
4 California and president of the Defend Our Freedoms foundation. She is a Doctor of
5 Jurisprudence and a Doctor of Dental Surgery. Through her foundation she has
6 popularized Constitution and fought violations of Constitution and civil liberties of
7 UC citizens. As part of her work she has filed numerous legal actions, representing
8 over 200 US citizens: State Representatives of different states, candidates on the
9 ballot and high ranked members of US military. Her clients are seeking release of
10 original vital records of Barack Hussein Obama, to see if he is eligible for US
11 presidency. As of now in spite of over 100 legal actions filed all over the Nation by
12 some 13 licensed attorneys and numerous pro se plaintiffs and in spite of 12 citizen
13 grand jury presentments and indictments, Obama refused to provide any vital records
14 that would be acceptable in any court of law.
15 Respondent/Defendant – Barack Hussein Obama, hereinafter “Obama”, Acting
16 President of the United States and Commander in Chief, who refused to present in
17 any court of law or to the public any vital records that would show his eligibility as
18 for US presidency based on Article 2, section 1 of the Constitution, as one born in
19 the United States to two citizen parents without allegiance to any other
20 sovereignties. From birth and until now Mr. Obama had citizenship and allegiance to
21 three other nations: Great Britain, Kenya and Indonesia.
22 Standing
23 Taitz is an attorney and she has submitted to Attorney General Eric Holder and
24 US Attorney for the District of Columbia Jeffrey Taylor a request to file Quo
25 Warranto, to ascertain Obama’s legitimacy for presidency . After 9 months of
26 waiting she did not receive any response from either Attorney General or US
27 attorney for the district of Columbia. She is seeking a ex-relator status to proceed
28 with Quo Warranto. As Taitz tried to ascertain Obama’s legitimacy as an attorney,
representing her clients, she was subjected to vicious attacks coming from the media
1
2
3 acting as regime official propaganda, from Obama’s supporters and from some
4 judiciary, acting as tools to silence her and intimidate her into dropping her legal
5 actions. She was subjected to numerous death threats, tampering with her car, when a
6 fumes emissions hose was disconnected and hot combustible fumes were going back
7 to the engine, as she was driving with her three children in the car. Several convicted
8 criminals and document forgers were hired by someone and used in concert to
9 submit perjured affidavits to court and to forge her signature, in an attempt to
10 influence the judiciary and undermine her in the eyes of the community and
11 undermine her law license. Her foundation web site was repeatedly hacked and
12 destroyed. Her pay-pal account was tampered with. On 01.21.09. her case Lightfoot
13 v Bowen was erased from the docket of the Supreme Court of the United States only
14 two days before it was supposed to be heard in conference by all nine justices. After
15 a year and a half of repeated complaints to law enforcement, she could not get any
16 assistance or relief. When she brought two legal actions in the Middle District of
17 Georgia on behalf of the members of the US military, as a form of intimidation and
18 retaliation, she was sanctioned $20,000. Taitz is seeking not only verification of
19 Obama’s legitimacy under Quo Warranto, but financial compensation for damages
20 suffered as well as compensation for the severe emotional distress suffered as a result
21 of the defendant’s actions.
22 Taitz has also submitted request for disclosure of pertinent information under the
23 Freedom Of Information Act from Social Security Administration under 5 USC 552
24 (b)(6), her request was denied by Dawn S. Wiggins, FOIA officer of the SSA, Taitz
25 is appealing this above denial.
26 Taitz is a Republican candidate on the ballot, running for the position of the
27 Secretary of State of CA. Based on prior legal action, it is clear, that if elected, Taitz
28 will demand from Obama all proper vital records to prove his legitimacy for
presidency. As Taitz has filed her Declaration of Candidacy, her whole family,
1
2
3 including her 3 children were subjected to vicious intimidation and harassment
4 campaign.
5
6 Here come the plaintiff Dr. Orly Taitz ESQ and alleges, that District of Columbia
7 jurisdiction allows Quo Warranto ex relator status in the name of the United States
8 against a person who within the District of Columbia usurps, intrudes into, or
9 unlawfully holds or exercises, a franchise conferred by the United States, civil and
10 military”. D.C. Code §§16-35-1-3503. Quo Warranto is the mechanism of redress of
11 grievances going back to Magna Carta.
12 The foundation of inviolability of Constitution as supreme law was codified in
13 Magna Carta (1215): “ . .we have granted all these concessions, desirous that they
14 should enjoy them in complete and firm endurance forever, we give and grant to
15 them the underwritten security,. . . so that if we, or our justiciar, or our bailiffs or any
16 one of our officers, shall in anything be at fault towards anyone, or shall have broken
17 any one of the articles of this peace or of this security, and the offense be notified . .
18 .laying the transgression before us, petition to have that transgression redressed
19 without delay. . . . And we shall procure nothing from anyone, directly or indirectly,
20 whereby any part of these concessions and liberties might be revoked or diminished;
21 and if any such things has been procured, let it be void and null, and we shall never
22 use it personally or by another.” Magna Carta 17 John § 61 (1215) (Avalon)
23
24 The supremacy and inviolability of Constitution is shown by ongoing rulings that
25 laws or actions are “void and null”, “null and void”, “void”, or “null” etc. e.g., Chief
26 Justice John Marshall affirmed this constitutional supremacy in Marbury v. Madison,
27 observing:
28 “Certainly all those who have framed written constitutions contemplate them
as forming the fundamental and paramount law of the nation, and, consequently, the
1
2
3 theory of every such government must be, that an act of the legislature, repugnant to
4 the constitution, is void.” Marbury v. Madison, 5 US 137, 176 - Supreme Court 1803
5
6 However, Magna Carta codified the supremacy and inviolability of constitution
7 over both the Executive (“We”/the King) and the Judiciary (“justiciar”/Chief
8 Justice). Thus paraphrasing Marbury at 178:
9 “So if a [doctrine] be in opposition to the constitution; if both the [doctrine]
10 and the constitution apply to a particular case, so that the court must either decide
11 that case conformably to the [doctrine], disregarding the constitution; or conformably
12 to the constitution, disregarding the [doctrine]; the court must determine which of
13 these conflicting rules governs the case. This is of the very essence of judicial duty.”
14
15 J. Marshall further emphasized the judicial oath:
16 “Why otherwise does it direct the judges to take an oath to support it? This
17 oath certainly applies in an especial manner, to their conduct in their official
18 character. How immoral to impose it on them, if they were to be used as the
19 instruments, and the knowing instruments, for violating what they swear to support!”
20 Marbury v. Madison, 5 US 137, 179 - Supreme Court 1803
21 The Plaintiff is seeking to uphold explicit Article II and Amendment XX
22 qualification requirements and grant access (“standing”) under Article VI supremacy
23 and oath. Any citizen has standing to uphold the Right to redress of grievances under
24 1st, 9th amendment. Additionally, 16-3502,3503 does not limit ex relator status to any
25 particular group and does not require any particular damages, however there is a
26 heightened right to redress of grievances for an attorney who was subjected to
27 sanctions, intimidation and harassment, while she tried to represent her clients
28 seeking to specifically redress such grievance. There is an additional heightened
standing for a Candidate on the ballot, running for the position of the Secretary of
1
2
3 State, where a big part of her campaign is legitimacy of elections, and where she and
4 her three children and her whole family are being threatened, harassed and
5 intimidated with death threats, her car is being tampered with, and she is threatened
6 with loss of her livelihood.
7 The plaintiffs have filed both with the Attorney General Eric Holder and the US
8 Attorney Jeffrey A. Taylor and his successor Channing Phillips a request for Quo
9 Warranto in March and April of 2009 respectively. Hundreds of concerned citizens
10 have called the Department of justice demanding a response to Quo Warranto
11 submission. No response was received for ten months. Letters, e-mails, faxes went
12 unanswered. Employees of the justice department were slamming phones in the face
13 of the citizens calling and urging a response, even when those calls came from high
14 ranking officers of US military. This game of hide and seek by the Attorney General
15 Holder and US attorneys played with the plaintiffs and their counselor is infantile at
16 best and treasonous at worst, as National Security is on the line. Recent near tragedy
17 of NorthWest 253, slaughter of CIA agents and tragedy at Fort Hood are only a few
18 reminders of how dangerous it is to have a Big Question Mark with numerous stolen
19 and fraudulent social security numbers sitting in the position of the President and
20 Commander in Chief.
21
22
23 WHEREFORE, the undersigned counsel respectfully requests this Honorable
24
Court to grant Leave of Court to file Quo Warranto as ex-relator in the name of
25
26 the United States of America against Barack Hussein Obama, President of the United
27 States.
28
Writ of Quo Warranto
1
2
3 QUESTIONS PRESENTED
4
5 I. What is Respondent Obama’s standard and burden of proof of his birthplace
6 under Quo Warranto and ethical duties? - Considering Obama’s first cousin Raela
7 Odinga, Prime Minister of Kenya, sealed alleged records of Obama’s birth in
8 Mombasa; while the State of Hawaii holds Obama’s “original” sealed birth records,
9 allows registration of births out of State, allows registration based on a
10 statement of one relative only without any corroborating evidence and seals
11 original birth records.
12 II. Does the State of Hawaii’s withholding Respondent’s Obama’s original birth
13 records by privacy laws breach the U.S. CONST. by obstructing constitutional rights
14 duties of the People to vote, and State and Federal election officers to challenge,
15 validate & evaluate qualifications of presidential candidates based on legally
16 acceptable and not fraudulent records and the President Elect., per U.S. CONST. art. II
17 § 1, art. VI, & amend. XX § 3?
18 III. Does the restrictive qualification for President of “natural born citizen” over
19 “citizen” include allegiance to the U.S.A. from birth without any foreign allegiance,
20 as required of the Commander in Chief in time of war to preserve the Republic,
21 including birth within the jurisdiction of the U.S.A. to parents who both had U.S.
22 citizenship at that birth, and having retained that undivided loyalty?
23 IV. Does birth to or adoption by a non-citizen father or mother incur foreign
24 allegiance sufficient to negate being a “natural born citizen” and disqualify a
25 candidate from becoming President?
26 V. Having attained one’s majority, do actions showing divided loyalty with
27 continued allegiance to the foreign nationality of one’s minority evidence foreign
28 allegiance sufficient to disqualify one from being a “natural born citizen” with
undivided loyalty to the U.S.A., such as campaigning for a candidate in a foreign
1
2
3 election, or traveling on a foreign passport?
4 VI. Does a presidential candidate or President Elect by default fail to
5 qualify under U.S. CONST., art. II § 2 and amend. XX, § 3, if they neglect their
6 burden to provide State or Federal election officers prima facie evidence of each of
7 their identity, age, residence, and natural born citizenship, sufficient to meet
8 respective State or Federal statutory standards?
9 VII. Do candidates for office disqualify themselves if they seek office under
10 a birth name differing from a name given by adoption, or vice versa, when they
11 neglect to provide election officers prima facie evidence of legal changes to their
12 name, or if they neglect to legally change their name?
13 VIII. Does a President elect fail to qualify through breach of ethical
14 disclosure duties, and obstruction of election officers’ constitutional duties to
15 challenge, validate and evaluate qualifications for President, by withholding or
16 sealing records evidencing identity, age, residency, or allegiance, or by claiming
17 privacy and opposing in court efforts by Electors, election officers, or the People to
18 obtain and evaluate such records?
19 IX. Does misprision by Federal election officers cause a President Elect to
20 fail to qualify, if they neglect or refuse to challenge, validate, or evaluate
21 qualifications of Electors or a President Elect, being bound by oath to support the
22 Constitution and laws, after citizens provided information challenging those
23 qualifications via petitions for redress of grievance, or by law suits?
24 X. To uphold its supremacy and inviolability, and to preserve the Republic, does
25 the U.S. Constitution grant standing to Citizens to bring suit or quo warranto over
26 negligence, obstruction, misprision, or breach of constitutional duties, and protect the
27 People’s rights?
28
1
2
3 Here come the plaintiffs/ ex-relators in the name of the United States of
4 America praying this Honorable Court issue Quo Warranto writ against Barack
5
Hussein Obama, President of the United States and Commander in Chief.
6
7 Ex Relators are seeking Quo Warranto under District of Columbia Codes
12 conferred by the United States or a public office of the United States, civil or
13
military”. The ex-relators assert that respondent Obama has indeed usurped the
14
15 franchise of the President of the United States and the Commander in Chief of the
16 United States Military forces due to his ineligibility and non-compliance with the
17
provision of the Article 2, Section 1, Clause 5 of the Constitution of the United
18
19 States that provides that the President of the United States has to be a Natural Born
20 Citizen for the following reasons:
21
The legal reference and legal definitions used by the framers of the
22
23 Constitution was the legal treatise “The Law of Nations” by Emer De Vattel as
24 quoted and referenced in the Article 1, Section 8. The Law of Nations defines
25
“…Natural Born Citizens, are those in the country, of parents who are citizens. As
26
27 the society cannot exist and perpetuate itself otherwise than by the children of the
28 citizens, those children naturally follow the conditions of their fathers, and succeed
1
2
3 to all their rights.” Book 1, Chapter 19, §212. In his book Dreams From my Father
4 as well as on his web site Fight the Smears respondent Obama admitted to the fact
5
that his father was never a US citizen, but rather a British citizen from a British
6
7 colony of Kenya and based on British Nationality act respondent Obama was a
8 British citizen at birth and a Kenyan citizen from age 2 on December 12, 1961 when
9
Kenya became an independent nation. As such, for the reason of his allegiance to
10
11 foreign nations from birth respondent Obama never qualified as a Natural Born
12 citizen.
13
In spite of some 100 legal actions filed and 12 Citizen Grand Jury
14
15 presentments and indictments Respondent Obama due to his ineligibility never
16 consented to unseal any prima facie documents and vital records that would confirm
17
his legitimacy for presidency.
18
19 The state of Hawaii statute 338-5 allows one to get a birth certificate based on
20 a statement of one relative only without any corroborative evidence from any
21
hospital. Respondent Obama refused to unseal a birthing file (labor and delivery file)
22
23 evidencing his birth from the Kapiolani Hospital where he recently decided, that he
24 was born. Similarly, respondent Obama refused to consent to unseal his original birth
25
certificate from the Health Department in the state of Hawaii. The original birth
26
27 certificate is supposed to provide the name of the hospital, name of the attending
28
1
2
3 physician and signatures of individuals in attendance during birth. As such there is
4 no verifiable and legally acceptable evidence of his birth in the state of Hawaii.
5
Circa 1995 Respondent Obama has made an admission in his book Dreams
6
7 from My Father that he has a copy of the original birth certificate, when describing a
8 certain article about his father he write “…I discovered this article, folded away
9
among my birth certificate and old vaccination forms…” In spite of the fact that
10
11 respondent Obama has a copy of his original birth certificate, he released for public
16 knows that he is not eligible and actively trying to obfuscate the records in order to
17
usurp US presidency. An affidavit from one of the most prominent forensic
18
19 document experts, Sandra Ramsey Lines, previously submitted to this court, states
20 that authenticity of COLB and inference of the US birth cannot be ascertained based
21
on COLB alone without examining the original birth certificate in Hawaii, that
22
23 respondent Obama refuses to unseal and present in court and to the public at large.
24 As respondents schools records from Indonesia, previously submitted, show
25
him the citizen of Indonesia under the name of Barry Soetoro, and there is no
26
27 evidence of legal name change upon his repatriation from Indonesia, there is a high
28 likelihood of the scenario whereby the respondent was sworn in as a president not
1
2
3 only illegitimately due to his allegiance to three foreign nations, but also under a
4 name that was not his legal name at the time of inauguration and swearing in as the
5
president.
6
7 Affidavits from licensed private investigators Neil Sankey and Susan Daniels,
12 egregious is the fact that the respondent has used for most of his life in Somerville
13
Massachusetts, Chicago, Illinois and currently in the White House SSN XXX-XX-
14
15 4425, which was issued in the state of Connecticut between 1976-1979 and assigned
16 to an individual born in 1890, who would have been 120 years old, if he would be
17
alive today. Respondent never resided in the state of Connecticut and he is clearly
18
19 not 120 years old. There is such a high probability of criminal acts of identity theft
20 and social security fraud committed by the respondent that the undersigned requests
21
this Honorable court to use its inherent powers to order Sua Sponte an evidentiary
22
23 hearing on this particular issue for possible criminal prosecution of identity theft and
24 social security fraud, as the respondent has submitted himself to the jurisdiction of
25
this Honorable court and can be brought to a separate evidentiary hearing to ascertain
26
27 if fraud was perpetrated upon the court by assertion of false identity, even if the
28 underlying case is not heard or closed for one reason or another. The undersigned
1
2
3 requests to bar the US attorney’s office from representing the respondent in such
1
2
3 9. Defendant committed fraud by taking an oath of president of the United
4 States.
5
10. Plaintiff represents some 200 plaintiffs and on behalf of those plaintiffs
6
7 sought release of the defendants above mentioned vital records .
16 actions.
17
Qui Tam
18
19 COMPLAINT PURSUANT TO FEDERAL FALSE CLAIMS ACT
20 Due to the fact that neither Attorney General Eric Holder nor US Attorney
21
for the District of Columbia respondent to the Quo Warranto demand, plaintiff is
22
23 seeking a leave of court for ex relator pursuant to the federal False Claims Act, 31
24 USC 3729- 3733 as well against the defendant/respondent Barack Hussein Obama
25
as further attempts to elicit respond from the Attorney General or US attorney will be
26
27 futile.
28
1
2
3 1. The relater re- alleges previously plead, incorporates by reference
8 Columbia affords the proper venue for this action in that the defendant has submitted
9
within the District of Columbia his false and wrongful claim for the payment of
10
11 monies by the United States Government and the Department of the Treasury located
1
2
3 WHEREFORE, pursuant to the procedures and remedies set forth in
4 the federal False Claims Act, relator, on his own behalf and on behalf of the
5
Government of the United States of America demands enforcement of Qui Tam
6
7 MOTION FOR RELEASE OF
8 INFORMATION UNDER 5USC 552 FREEDOM OF INFORMATION ACT
9
10 PLAINTIFF re-alleges all of the above, incorporates by reference and alleges
11
the following:
12
13 1. Plaintiff has requested information from the Social Security administration
1
2
3 4. Plaintiff is damaged and will be more damaged in the near future, if the
4 applications for the Social Security numbers listed in the above reports are
5
not disclosed, and explanation is not provided by what right, by what
6
7 warrant Defendant is using or have been those Social Security numbers.
12
VIOLATION OF COMMERCE CLAUSE AND OF PLAINTIFF’S
13
RIGHTS TO GAINFUL EMPLOYMENT AS A DOCTOR OF DENTAL
14
SURGERY UPON DEFENDANT’S IMMINENT SIGHNING OF THE
15
HEALTH BILL
16
1. Plaintiff re-alleges and incorporates by reference everything alleged
17
previously and alleges the following:
18
2. Plaintiff is a Doctor of Dental Surgery, licensed by the state of California.
19
3. Plaintiff owns and operates a dental practice at 29839 Santa Margarita
20
PKWY, Rancho Santa Margarita CA.
21
4. Currently US House of Representatives is set approve via reconciliation
22
one of two versions of the Health Bill (House Bill HR 3962 and “Senate
23
Bill” to be reconciled in the House as HR 3590 are substantially Different).
24
Defendant has repeatedly stated that if such bill is passed and reconciled as
25
early as next week, he will immediately sign it into law in spite of general
26
public outcry against such bill. This signing of the bill is imminent as
27
Defendant, his administration and Democratic party leadership have
28
engaged forceful arm twisting and de-facto bribery of US Senators in order
to push passing of such bill, whereby Senator Mary Landrieu of Louisiana
Complaint Taitz v Obama District of Columbia 17
Case 1:10-cv-00151-RCL Document 16 Filed 03/22/10 Page 18 of 145
1
2
3 got a 100 million dollar de-facto bribe (Better known as a new “Louisiana
4 Purchase”), senator Christopher Dodd of Connecticut got 300 million de-
5 facto bribe and Senator Ben Nelson of Nebraska got an infinity amount of
6 dollars de facto bribe to sign the Senate version of such bill.
7 5. Defendant has never provided any vital records to show that he is
8 legitimate to hold position of the President and sign such bill into law.
9 6. Plaintiff will be directly affected by such bill, if signed into law as early as
10 next week.
11 7. Health bill, as being prepared and reconciled, will create an enormous
12 machine of governmental burocracy which will intrude into Plaintiff’s
13 practice, will affect her doctor-patient relations, will undermine her
14 Hippocratic oath, will force her to ration medical care and de-facto deny
15 medical care to elderly, whom some committees of burocrats will deem to
16 be too old to receive such care, meaning too old to live.
17 8. Such bill will subject her to threat of multiple Medical-Dental malpractice
18 legal actions as standard of care will clearly go down.
19 9. Such bill will constitute unreasonable infringement upon her gainful
20 employment in Dental Surgery as overburdening of interstate commerce in
21 clear violation of commerce clause.
22 10.Wherefore the Plaintiff seeks a writ of Mandamus, seeking release of the
23 Defendant’s vital records, such as his original birth certificate, his college
24 and university enrollment records, social security application and passport
25 application records to verify his legitimacy to sign Health Bill HR 3590 or
26 HR 3962 or any other bill under the Natural Citizen requirement of the
27 Article 2, Section 1and seeking a declaratory relief deeming Health Bill HR
28 3590 and HR 3962 null and void as violating Commerce clause and not
signed by a legitimate President of the United States.
1
2
3 Violation of Plaintiff’s Civil rights under 42 USC 1983, 42 USC 1985.
4 Plaintiff re-alleges and incorporates by reference all of the above and alleges
5 following
6 1. Plaintiff is one of two Republican candidates on the ballot in the state of CA.
7 Democrat candidate on the ballot is an incumbent Debra Bowen.
8 2. Plaintiff’s children were intimidated and harassed with e-mails stating that
9 their mother will be thrown in prison and committed to mental institution.
10 They received paintings of their mother, depicted nude, giving birth and
11 holding a bloody placenta, titled “Birther Orly Taitz”. This was clearly done to
12 intimidate and harass not only Taitz’s children but also Taitz, herself, and
13 pressure her into dropping out of the race, as well as to cause her and her
14 whole family severe mental anguish. Plaintiff has filed a criminal complaint
15 with Orange County Registrar of Voters, Mr. Neal Kelley. (Exhibit –Criminal
16 complaint, filed with the Registrar of Voters)
17 3. Mr.Kelley has called in response to the complaint and stated that it will be
18 forwarded to the Secretary of State Debra Bowen, who has an investigative
19 unit.
20 4. In and around the time of the incidents of harassment Plaintiff has received a
21 copy of a campaign mailer sent by the campaign of Debra Bowen, Secretary of
22 State, who is a top official, would be investigating the Plaintiff’s complaint.
23 5. Bowen’s mailer states ”Please contribute today to help Debra stand against
24 right-wing ideoloques like Orly Taitz”…”…Her (Taitz) primary reason for
25 running is to challenge President Obama’s citizenship and invalidate the 2008
26 election. In Fact, Taitz has sued Debra twice to try to invalidate Obama’s
27 victory. We can’t let fringe conspiracy theories use this office to get a foot in
28 the door and undermine our democracy”..’ “please donate $25 or more today
so Debra can defeat Orly Taitz…” Exhibit Flier from Debra Bowen.
1
2
3 6. Clearly Plaintiff, Dr. Orly Taitz, cannot expect any impartiality or any
4 assistance, when the governmental official, Secretary of State, who is
5 supposed to investigate intimidation, harassment, hate crimes against Taitz and
6 her children and her whole family, as related to elections, is the one who is
7 spreading absolutely despicable defamatory, slanderous statements about
8 Taitz, is the one who is masterminding the hysteria against Taitz, which in turn
9 leads to hate crimes against Taitz and her family.
10 7. Such behavior clearly shows violation of voting rights and Plaintiff’s rights to
11 be an un-intimidated candidate on the ballot. Secretary of State Bowen acted
12 for the benefit and as a de-facto agent of the Defendant, whereby she
13 admits in her own flier, that there is a threat of invalidation of Obama’s
14 election, if Taitz is elected. This represents a violation of Plaintiff’s rights
15 under 42 USC 1983 and 42 USC 1985.
16 8. Defendant’s unwillingness to unseal any and all of his vital records only fuels
17 such attacks on Taitz and behavior of officials directed towards aiding and
18 abetting of consealment of such records obstruction of records and violation of
19 Taitz civil rights under the color of authority.
20 9. Wherefore Plaintiff seeks an adjudication in her favor and determination that
21 her civil rights under 42 USC 1983 and 42 USC 1985 were violated and she
22 seeks damages incurred as a result of such violation.
23
24 RICO
25 1. Plaintiff re-alleges and incorporates by reference all of the above and alleges
26 the following:
27 2. Fraud, as described and alleged previously constitutes a predicate act under
28 RICO
3. Violation of 42 USC 1983 and 1985 constitutes a predicate act under RICO.
1
2
3 4. On January 21st of 2009 my case Lightfoot v Bowen was erased from the
4 docket of the Supreme Court. This suggests aiding and abeting in commission
5 of fraud and a corrupt organization with a common scheme to defraud the
6 country. As further investigation is necessary, the plaintiff cannot state prior to
7 discovery, who was engaged in erasing of records.
8 5. On October 1st, 2009 Sidharth Velamoor, attorney for Perkins Coie, Obama’s
9 defense firm, where Robert Bauer, White House Chief Counsel, is a partner
10 was hired as a clerk for Judge David O. Carter. Shortly thereafter Judge Carter
11 has changed his opinion and decided that he no longer has jurisdiction to hear
12 Barnett et al V Obama et al, which dealt with Obama’s illegitimacy to
13 presidency. Those actions suggest improper influence on the Federal judge in
14 an effort to affect the outcome of the litigation, where defendant was likely to
15 be found illegitimate to presidency. Those facts suggest violation of the civil
16 rights of Taitz, an attorney on the case, and her clients under 42 USC 1983,
17 which constitutes a predicate act under RICO.
18 6. Licensed investigators Susan Daniels and Neil Sankey have provided
19 affidavits, showing Obama using multiple Social Securty numbers, none of
20 which were issued in Hawaii, which indicates violation of 42 USC 408
21 (a)(7)(b), a predicate act under RICO.(Exhibits Affidavits of Susan Daniels
22 and Neil Sankey)
23 7. John Sampson, Retired Senior Deportation Officer of the United States
24 Department of Homeland Security, Immigration and Customs Enforcement
25 (DHS ICE), recipient of advanced training from federal Law Enforcement
26 Center, currently a private investigator has provided an affidavit, showing that
27 the Defendant has used a social security number, issued in the state of
28 Connecticut, while he resided in HI. Both investigator Sampson and Sankey
were subjected to retaliation and their privileges to use National databases
1
2
3 were rescinded in retaliation, upon them providing Taitz with the information
4 showing the defendant fraudulently using Social Security numbers of others.
5 This is indicative of fraud, obstruction of Justice, Social Security Fraud and
6 Identity theft- all predicate acts under RICO.
7 8. Plaintiff is seeking to plead RICO more fully upon conducting and completion
8 of discovery, which is currently impeded due to plaintiff’s refusal to unseal
9 any and all information and due to the Fact that governmental officials,
10 currently not named, are aiding and abetting in such obfuscation of records.
11
12 Wherefore:
13
1. Plaintiff ex-relator in the name of the United States of America is
14
15 requesting this Honorable Court to issue a writ of Quo Warranto against a
20 security fraud.
21
2.Pursuant to the procedures and remedies set forth in the federal False
22
23 Claims Act, Plaintiff-ex relator, on his own behalf and on behalf of the Government
1
2
3 records to verify his legitimacy to sign Health Bill HR 3590 or HR 3962 or any other
4 bill under the Natural Citizen requirement of the Article 2, Section 1and seeking a
5
declaratory relief deeming Health Bill HR 3590 and HR 3962 null and void as
6
7 violating Commerce clause and not signed by a legitimate President of the United
8 States.
9
4. Plaintiff seeks declaratory relief and adjudication I that common law fraud
10
11 was committed by the Defendant in his declaration of Candidacy to presidency, and
12 based on this fraud Plaintiff suffered damages. Plaintiff is seeking compensation for
13
the damages suffered as well as severe emotional distress suffered due to the fraud
14
15 committed by the Defendant.
1
2
3
4
/s/ DR ORLY TAITZ ESQ
5 By:__________________________________
6 Dr. Orly Taitz, Esq. (California Bar 223433)
Attorney for the Plaintiffs
7 29839 Santa Margarita Parkway ste 100
Rancho Santa Margarita CA 92688
8
Tel.: 949-683-5411; Fax: 949-766-7603
9 E-Mail: dr_taitz@yahoo.com
10
11
12 PROOF OF SERVICE
13
I CERTIFY THAT TRUE AND CORRECT COPY OF THE ABOVE
14
PLEADINGS WAS SERVED on
15
Channing Phillips, US Attorney for the District of Columbia
16
501 3 rd str. NW
17
Washington DC
18
/s/Orly Taitz
19
20 Dr. Orly Taitz Esq
29839 Santa Margarita PKWY
21 Rancho Santa Margarita CA 92688
22 1. Exhibit 1 Affidavit from Investigator John Sampson
23 2. Exhibit 2 Affidavit from licensed Investigator Susan Daniels
3. Exhibit 3 Affidavit from the investigator Neil Sankey
24 4. Exhibit 4 Campaign flier of CA SOS Debra Bowen
5. Criminal complaint filed with the office of Neal Kelley, the Registrar of
25 Voters of Orange County
26 6. FOIA Appeal
27
28
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
January 2, 2009
I am a Private Investigator, duly licensed in the State of California and have been so
licensed for the past twenty five years. I am a Naturalized American Citizen.
I am experienced in all types of Investigation, both Criminal and Civil, having spent
twenty years in the British Police, serving as a Detective at New Scotland Yard for many
years. In the interest of our Country and in defense of our Constitution I have been
assisting with Research and Investigation wherever necessary.
During the course of the work I have been doing in the past six months, regarding the
activities and qualifications of Mr. Obama, I have kept a record of all of the addresses in
regards to which I have seen the use of his name. The records and databases I use are
many and varied being accumulated for many different reasons but all are of Public
Record and the documents I have used are available to the General Public, with, or
without the payment of fees.
I have compiled the below list which I have previously forwarded to you:
*********************************************************************************************************
*********************************************************************************************************
Page 2
Case 1:10-cv-00151-RCL Document 16 Filed 03/22/10 Page 42 of 145
*********************************************************************************************************
Page 3
Case 1:10-cv-00151-RCL Document 16 Filed 03/22/10 Page 43 of 145
Age - 52
Date of Birth - Nov 29, 1942
Deceased - Yes
Date Record Verified - Oct 94 - Jan 95
*********************************************************************************************************
Page 4
Case 1:10-cv-00151-RCL Document 16 Filed 03/22/10 Page 44 of 145
Probable Current Address - No
Telephone -
Telephone Accountholder -
Social Security - 535-40-xxxx
Age - 52
Date of Birth - Nov 29, 1942
Deceased - Yes
Date Record Verified - Jan 87
*********************************************************************************************************
*********************************************************************************************************
Page 5
Case 1:10-cv-00151-RCL Document 16 Filed 03/22/10 Page 45 of 145
Date Record Verified - Oct 08 - Dec 08
*********************************************************************************************************
Page 8
Case 1:10-cv-00151-RCL Document 16 Filed 03/22/10 Page 48 of 145
Page 13
Case 1:10-cv-00151-RCL Document 16 Filed 03/22/10 Page 53 of 145
Name - OBAMA, BARACK H
Gender - Male
Street Address - 180 N LA SALLE ST APT 2200N
City, State, Zip - CHICAGO IL 60601-2501
Probable Current Address - No
Telephone -
Telephone Accountholder -
Social Security - 042-68-xxxx
Age -
Date of Birth -
Deceased - No
Date Record Verified - Feb 07 - Jun 07
*********************************************************************************************************
Page 14
Case 1:10-cv-00151-RCL Document 16 Filed 03/22/10 Page 54 of 145
Deceased - No
Date Record Verified - Oct 86
*********************************************************************************************************
*********************************************************************************************************
Page 15
Case 1:10-cv-00151-RCL Document 16 Filed 03/22/10 Page 55 of 145
Probable Current Address - No
Telephone -
Telephone Accountholder -
Social Security - 042-68-xxxx
Age -
Date of Birth -
Deceased - No
Date Record Verified -
*********************************************************************************************************
Page 17
Case 1:10-cv-00151-RCL Document 16 Filed 03/22/10 Page 57 of 145
Date Record Verified - Jun 97 - Aug 04
*********************************************************************************************************
Page 18
Case 1:10-cv-00151-RCL Document 16 Filed 03/22/10 Page 58 of 145
Deceased - No
Date Record Verified - Nov 05 - Mar 06
*********************************************************************************************************
Page 23
Case 1:10-cv-00151-RCL Document 16 Filed 03/22/10 Page 63 of 145
Deceased - No
Date Record Verified -
*********************************************************************************************************
SANKEY INVESTIGATIONS
______________________________________
Neil Sankey, Investigator
Page 25
Case
Case4:09-cv-00082-CDL
1:10-cv-00151-RCL Document
Document 1-6
16 Filed
Filed03/22/10
07/09/2009
Page Page
65 of 1145
of 3
AFFIDAVIT
I, Neil SANKEY, of Simi Valley, California,, MAKE OATH AND SAY THAT:
If called to do so, I could and would competently testify under oath as follows.
I am a Licensed Investigator in the State of California License number P.1. 10905. I have
been so licensed for twenty five years. I am a Naturalized American Citizen.
I am experienced in all types of Investigation, both Civil and Criminal, having spent
twenty years in the British Police, serving as a Detective Sergeant at New Scotland
Yard. In the interest of our Country I have been assisting with research and
investigation wherever necessary.
2. During the course of the work that I was doing in the latter part of 2008, regarding the
activities and qualifications of Mr. Obama, I have compiled a record of all of the
addresses in regards to which I have seen the use of his name. The records and
databases which I use are many and varied having been accumulated for many
different reasons but all are Public Record and the documents I have used are available
to the General Public with, or without the payment of fees.
4. On July 6, 2009, I forwarded to Doctor Taitz an updated version of that list, accurate
as of that date and having been updated, by me, during the weekend of July 4th and 5th
Case
Case4:09-cv-00082-CDL
1:10-cv-00151-RCL Document
Document 1-6
16 Filed
Filed03/22/10
07/09/2009
Page Page
66 of 2145
of 3
2009. A true and complete copy of that document accompanies this document attached
and marked "Exhibit B"
)-----------------------
NOTARY PUBLIC ) Neil SANKEY
, ,
YSee Attached Document (Notary to cross out lines 1-6 below)
_ See Statement Below (Lines 1-5 to be completed only by document signer[sJ, not Notary)
State of California
( \ ..
County of . 've,V)'tct /) LL-
Subscribed and sworn to (or affirmed) before me on this
Lc't·~
Dale
day of _Jv..G i..~- M h
J 20cfi , by
Year
(1
Signa~' . ./
OPTIONAL-----------------------
RIGHTTHUMBPRINT
OF SIGNER #1
fraudulent document.
Further Description of Any Attached Document
©20G7 National Notary A.ssoclat,on' 9350 De . PO. Box 2402' Chatsworth. CA 91313-2402' v,ww.NatiooaNotary org I,em 45910 Reorder: Call Toll-Free 1·800·876·6827
Case 1:10-cv-00151-RCL Document 16 Filed 03/22/10 Page 68 of 145
*********************************************************************************************************
Deceased - Yes
Date Record Verified - Jan 95 - Jan 96
*********************************************************************************************************
*********************************************************************************************************
Deceased - No
Date Record Verified - Apr 93
*********************************************************************************************************
*********************************************************************************************************
Telephone -
Telephone Accountholder -
Social Security -
Age -
Date of Birth -
Deceased - No
Date Record Verified - Feb 08 - Jun 08
*********************************************************************************************************
Telephone Accountholder -
Social Security - 201-67-xxxx
Age -
Date of Birth -
Deceased - No
Date Record Verified - Jun 09 - Jul 09
*********************************************************************************************************
Telephone Accountholder -
Social Security - 282-80-xxxx
Age -
Date of Birth -
Deceased - No
Date Record Verified - Apr 08 - Nov 08
*********************************************************************************************************
Age -
Date of Birth -
Deceased - No
Date Record Verified - Apr 09 - Jul 09
*********************************************************************************************************
Deceased - No
Date Record Verified - Sep 08 - Jan 09
*********************************************************************************************************
Deceased - No
Date Record Verified - Mar 03 - Jul 03
*********************************************************************************************************
Deceased - No
Date Record Verified - Jun 05 - May 09
*********************************************************************************************************
Deceased - No
Date Record Verified - Mar 09 - Jun 09
*********************************************************************************************************
*********************************************************************************************************
*********************************************************************************************************
Gender - Male
Street Address - 1440 E 52ND ST
City, State, Zip - CHICAGO IL 60615-4131
Probable Current Address - No
Telephone -
Telephone Accountholder -
Social Security -
Age - 47
Date of Birth - Aug, 1961
Deceased - No
Date Record Verified - Apr 86
*********************************************************************************************************
Date of Birth -
Deceased - No
Date Record Verified - Nov 08 - Mar 09
*********************************************************************************************************
Deceased - No
Date Record Verified - Mar 09 - Jul 09
*********************************************************************************************************
Age -
Date of Birth -
Deceased - No
Date Record Verified - Jun 05
*********************************************************************************************************
Telephone Accountholder -
Social Security - 042-68-xxxx
Age - 119
Date of Birth - 1890
Deceased - No
Date Record Verified -
*********************************************************************************************************
Age -
Date of Birth -
Deceased - No
Date Record Verified - Dec 08 - Apr 09
*********************************************************************************************************
Deceased - No
Date Record Verified - Nov 07 - Mar 08
*********************************************************************************************************
*********************************************************************************************************
Date of Birth -
Deceased - No
Date Record Verified - Jun 09 - Jul 09
*********************************************************************************************************
Deceased - No
Date Record Verified - Jan 09 - May 09
*********************************************************************************************************
*********************************************************************************************************
Telephone -
Telephone Accountholder -
Social Security -
Age -
Date of Birth -
Deceased - No
Date Record Verified - Mar 09 - Jun 09
*********************************************************************************************************
Telephone Accountholder -
Social Security -
Age -
Date of Birth -
Deceased - No
Date Record Verified - Aug 08 - Dec 08
*********************************************************************************************************
Social Security -
Age -
Date of Birth -
Deceased - No
Date Record Verified - Oct 08 - Feb 09
*********************************************************************************************************
Telephone Accountholder -
Social Security - 578-11-xxxx
Age - 45
Date of Birth - 1964
Deceased - No
Date Record Verified -
*********************************************************************************************************
Name - OBAMA, BO
Street Address - 7363 THOMAS
City, State, Zip - MANASSAS VA 20109
Probable Current Address - No
Telephone -
Telephone Accountholder -
Social Security -
Case 1:10-cv-00151-RCL Document 16 Filed 03/22/10 Page 107 of 145
Age -
Date of Birth -
Deceased - No
Date Record Verified - Mar 09 - Jun 09
*********************************************************************************************************
Deceased - No
Date Record Verified - Jan 08 - May 08
*********************************************************************************************************
*********************************************************************************************************
Age -
Date of Birth -
Deceased - No
Date Record Verified - Nov 08
*********************************************************************************************************
Attention
714-567-7627
Via mail
Registrar of voters
Criminal Complaint regarding voter fraud and elections fraud committed by Mr. Damon Dunn,
registered voter in Orange County, CA, and a Candidate for the position of the Secretary of
State on the ballot for the Republican Primary in Orange County, CA based on CEC §8001
(a)(2), CEC §18203, §18500.
My name is Dr. Orly Taitz, ESQ. I am a candidate on the ballot for the June, 8, 2010 Republican
primary, running for the position of the Secretary of State of CA.
I demand immediate investigation of the following troubling events and suspected criminal
activity:
Case 1:10-cv-00151-RCL Document 16 Filed 03/22/10 Page 112 of 145
1. In November of 2009 Mr. Damon Dunn has officially declared his candidacy for the
position of the Secretary of State of California, and his desire to run as a Republican
Candidate in June 8 2010 election. Per §8001(a)(2) he could not be affiliated with any
other party for 12 months prior to his official declaration of candidacy.
2. About 6 months prior to his declaration of candidacy, in March of 2009 Mr. Dunn has
registered as a Republican voter in Orange County CA. Question 16 of the voter
registration card specifically asks whether the voter was registered before, in which
County, which State and which Party affiliation. Mr. Dunn did not put down any
information and it appeared as if he was never registered to vote before, that he was
never affiliated with any other party, and therefore he is eligible to run as a Republican
candidate in the next election. None of this was true.
3. Please, see Exhibit A an excerpt from the Stanford Scout, stating that Mr. Dunn was
registered to vote before.
4. Please see the following link
http://74.125.155.132/search?q=cache:gQYwJc4qldIJ:blogs.oc
weekly.com/navelgazing/the-hilarious-haters/orly-taitzs-claims-
about-damon/+ocweekly,+dunn&cd=1&hl=en&ct=clnk&gl=us
from OC Weekly which quotes Sacramento Bee as well as Damon Dunn’s own spokesperson,
Hector Barajas, confirming that Mr. Dunn indeed previously registered to vote in
Jacksonville, Duval County, FL, and he registered there as a Democrat. Mr. Barajas has tried to
justify Mr. Dunn’s behavior by saying that he was snagged by motor-voter registration drive,
however such excuse does not exonerate Mr. Dunn’s behavior. Mr. Dunn is not a minor child.
He is an adult who wants to be the Secretary of State of California, a state with population of
over 30 million. He wants to be in charge of the whole voting process of the state. His behavior
in intentionally omitting his prior voter registration and registration with the opposing party
constitutes fraud of the Republican party voters, registrar of elections and California voters in
general. CEC §18203 states “Any person who files or submits for filing a nomination paper or
declaration of candidacy knowing that it, or any part of it, has been made falsely is punishable
by fine not exceeding one thousand dollars ($1,000) or by imprisonment in the state prison for
16 months or two years or three years or both the fine and imprisonment”. Additionally CEC
§18500 states “Any person who commits fraud and any person who aids and abets fraud or
attempts to aid and abet fraud, in connection with any vote cast, to be cast, or attempting to be
cast, is guilty of felony, punishable by imprisonment for 16 months or two years or three years”.
It is imperative for you Mr. Kelley and for the District Attorney of Orange County Mr. Tony
Rackauscas , as well as the Secretary of State Ms. Debra Bowen to act in this manner, as inaction
will constitute aiding and abetting fraud in election punishable by § 18500.
5. Please see Exhibit B, an e-mail response from the Duval County FL registrar of voters,
verifying that Mr. Dunn was registered as a Democrat and did not change his party
affiliation.
Case 1:10-cv-00151-RCL Document 16 Filed 03/22/10 Page 113 of 145
Wherefore:
1. I demand removing Mr. Dunn from the ballot as inelligible to run in the Republican party
primary.
2. I demand criminal investigation of the voter fraud, elections fraud as well as voter
intimidation and investigation of the intimidation of the family of the candidate.
3. I demand to forward all of the above information to the District Attorney of Orange County,
CA Tony Rackauscas, secretary of State Deborah Bowen, as well as US attorneys for criminal
matters for the central District of CA Mr. Brent Sabel and Mr. Ken Julian, who investigated and
successfully obtained criminal conviction in previous case of public corruption of a High Rank
politician and public official Sheriff of OC Mike Caronna.
Sincerely,
Exhibit A
http://stanford.scout.com/2/936969.htm
"On non-football topics, Dunn speaks in excited and vibrant tones. Diverse political heroes include Martin
Case 1:10-cv-00151-RCL Document 16 Filed 03/22/10 Page 115 of 145
Luther King, Barack Obama and Governor Pete Wilson. He remains a political novice, having never run for
office previously. He first registered to vote as a Democrat a decade ago but never actually went to the
polls until May of 2009”
Exhibit B
E-Mail Response from Duval County FL, verifying that Damon Dunn never changed his affiliation from
Democrat to Republican
-----Original Message-----
From: Gen Rajska [mailto:rajska7@gmail.com]
Sent: Wednesday, March 10, 2010 11:46 PM
To: Holland, Jerry
Subject: Registration is Public Record
Dear Sir:
Felicito Papa
Reply
Forward
Reply
|
Holland, Jerry
to me
Good morning,
In further response to your questions Mr. Dunn was registered as a
Democrat and we do not show any change of party.
Thank you,
Jerry Holland
Exhibit C
Exhibit E
Clear flag
Case 1:10-cv-00151-RCL Document 16 Filed 03/22/10 Page 119 of 145
Proof Damon Dunn is Not Legal to Run for SOS or for any other CA this year
To:
info@cagop.org
Damon dunn.JPG
Damon Dunn also lied on his Voter Registration form. He did not
declare that he was formerly registered to vote in Florida as a
Democrat. What kind of example does this set for California's
number one Election official? Sounds like Obama Thug politics to
me.
Sincerely,
Pamela Barnett
Sacramento County
415.846.7170
"If virtue and knowledge are diffused among the people, they will never be enslaved. This will
be their great Security." Samuel Adams
Jim726@
“I was registered as Democrats by accident and almost forgot
about it. So what?”
this was sent to one of my children. It might not be from Damon Dunn himself, it could
be someone masquerading as him. This is a total garbage and slander of me. My son now
has a neurological problem, it is very bad. I can't get any help from any law enforcement
Case 1:10-cv-00151-RCL Document 16 Filed 03/22/10 Page 122 of 145
In the links there is an article by a deranged Marxist reporter Spencer Kornhaber, who
twists everything and anything.
On my blog one of the readers has written that he believes judges are being threatened,
even honorable ones, even conservative ones and even ex-Marines.
What this man referred to is Judge Carter, who is an ex-Marine, who originally stated on
the record that there is jurisdiction to hear my case Barnett et al v Obama, but who
apparently was threatened, when Obama placed one of attorneys working for his defense
firms, Perkins Coie, as a law clerk for the judge. This judge looked very scared, very
intimidated by something at the last hearing we had, on October the 5th, later he decided
that we no longer have jurisdiction.
Now judge Lamberth is supposed to provide an answer or hearing on my application for
preliminary injunction against Obama, the decision or hearing was supposed to be by
March 8, but there is no answer yet, and this reader was saying that he thinks that the
judge could've been threatened, like former Marine Judge Carter.
This Marxist scum reporter Spencer Kornhaber twisted that post, has written an article,
saying that Orly Taitz is threatening judges, some fellow Marxist scum have written in
comments that I will need to be arrested or put in a mental institution and this was
sent to one of my children through Facebook, supposedly by Damon Dunn, my
opponent in the primary, though I doubt it came from him personally, I believe someone
might be using his name.
This is a new low, this scum is attacking my children
ben taitz
"grief can take care of itself, but to get the full value of joy you must have somebody to
divide it with."
- Mark Twain
"a man who cannot reason is a fool, a man who will not reason is a bigot, and a man who
dare not reason is a slave."
Case 1:10-cv-00151-RCL Document 16 Filed 03/22/10 Page 123 of 145
- William Drummond
"insane people are always sure that they are fine. it is only the sane people who are
willing to admit that they are crazy."
-Nora Ephron
--------------------
Subject: You poor kid
Will you be visiting your mum in jail after she's sent there for approving of,
publishing and encouraging her supporters to issue death threats against the family
members (little children) of federal court judges in order to intimidate and coerce
them into ruling in her favor?
http://www.facebook.com/l/59fb9;blogs.ocweekly.com/navelgazing/the-hilarious-
haters/orly-taiz-approves-threats-aga/
--------------------
Damon has shared a link with you. To view it or to reply to the message, follow this
link:
http://www.facebook.com/n/?inbox%2Freadmessage.php&t=357838859241&mid=20281edG510ca4
4eG18d486cG0&n_m=ben_taitz%40yahoo.com
___
Find people from your Yahoo address book on Facebook! Go to:
http://www.facebook.com/find-friends/?ref=email
This message was intended for ben_taitz@yahoo.com. Want to control which emails you
receive from Facebook? Go to:
http://www.facebook.com/editaccount.php?notifications=1&md=bXNnO2Zyb209MTAwMDAwODczM
zM1NTcyO3Q9MzU3ODM4ODU5MjQxO3RvPTEzNTk3ODI5OTA=
Facebook's offices are located at 1601 S. California Ave., Palo Alto, CA 94304.
Orly,
--------------------------------------------------------------------------
--------------------
Will you be visiting your wife in jail after she's sent there for
http://www.facebook.com/l/b0667;blogs.ocweekly.com/navelgazing/t
he-hilarious-haters/orly-taiz-approves-threats-aga/
Is there some reason her family (ie you) haven't put her into some
form of
Case 1:10-cv-00151-RCL Document 16 Filed 03/22/10 Page 125 of 145
treatment centre for her full blown paranoid delusional state at this
point?
--------------------
http://www.facebook.com/n/?inbox%2Freadmessage.php&t=132969
3475895&mid=2028199G2c5f6643G44f8f8cG0&n_m=yosi%40dayligh
t.com
___
http://www.facebook.com/editaccount.php?notifications=1&md=bXN
nO2Zyb209MTAwMDAwODczMzM1NTcyO3Q9MTMyOTY5MzQ3NTg5N
Tt0bz03NDQ0NDk2MDM=
94304.
Exhibit F
03.15.10.
Baltimore, MD 21235-6401
I am in receipt of your letter from 03.03.10., reference S9H: AD2135 and I respectfully appeal
your denial of disclosure of information under FOIA 5 USC § 552 (b)(6) and I demand an
administrative hearing within 30 days for the following reasons:
1. According to affidavits, provided by licensed investigators Mr. Neil Sankey and Ms.
Susan Daniels (Exhibits A, B) Mr. Obama has used multiple social security numbers,
which indicates social security fraud and identity theft. One does not have an
expectation of privacy and right to privacy, when he uses identity of others. Moreover,
such individual is subject to criminal prosecution for such crimes. If you, as a Social
Security officer, upon receiving such information, are refusing to act and prosecute, you
become complicit and subject to criminal liability for aiding and abetting of felonies,
subornation of felonies and under RICO.
2. Social security number that Mr. Obama is using currently 042-68-4425, is a number,
fraudulently obtained by Mr. Obama, as according to affidavits of Mr. Sankey, Ms.
Daniels and former immigration officer, private investigator Mr. Sampson, this number
was assigned between 1976-1977 in CT, while Mr. Obama resided at a time in HI. As a
matter of fact, Mr. Obama never resided in CT.
3. 042-68-4425 was originally assigned to an individual born in 1890, which makes him 120
years old. It appears this individual applied for the benefits when he was older and
retired, and needed some Medicaire or Medicaid benefits. Mr. Obama is not 120 years
old.
4. Official Selective Service web site confirms Mr. Obama’s use of the SSN 042-68-4425
Case 1:10-cv-00151-RCL Document 16 Filed 03/22/10 Page 128 of 145
5. Anyone bringing forward the matter of this fraud is subjected to retaliation. Investigator
Sankey lost his privileges to use Lexis Nexis, which effectively took away his ability to
obtain livelihood as a licensed investigator. Mr. Sampson lost his privileges to use
Locator service, which effectively took away his ability to obtain livelihood. Major Stefan
Frederick Cook was fired from his $120,000 position working for defense contractor,
officer Ronald Dischler in Belleview Texas was threatened with investigation. Such
behavior by Obama administration is indicative of a need to hide incriminating evidence.
6. I am currently a Republican Party Candidate on the ballot running for the position of the
Secretary of State of California. I personally, my husband and my three children were
subjected to horrific intimidation, harassment, death threats, tampering with my car,
cyber crimes, tampering with my pay-pal account, web site, defamation of character
and other crimes.(see letter to Mr. Neal Kelley, Registrar of Voters of Orange County CA,
Exhibit C). Persecutions were so horrific, that I had to seek protection from the UN, Civil
Rights Defenders Commission in Geneva, Switzerland.
Sincerely,
Cc John J Roberts, Chief Justice Supreme Court of the United States, Associate Justices of the
Supreme Court, re 08A524 Lightfoot v Bowen
Cc 9th Circuit Court of Appeals, San Francisco, CA, re Barnett et al v Obama et al 09-c-82
Cc 11th Circuit Court of Appeals, Atlanta GA, re Rhodes v Macdonald et al 09-15418, Cook et
v Good et al 09-14698
1
2
3 Dr. Orly Taitz, esq
29839 Santa Margarita Parkway, STE 100
4 Rancho Santa Margarita CA 92688
Tel: (949) 683-5411; Fax (949) 766-7603
5 E-Mail: dr_taitz@yahoo.com
6 UNITED STATES DISTRICT COURT
7 FOR THE DISTRICT OF COLUMBIA
1
2
3 I have provided affidavits from licensed investigators, as well as official selective
4 service printout, showing him using this social security number, even though it was
5 assigned to another individual, born in 1890 and it was assigned in CT between
6 1976-1977, while Obama resided in HI, and in light of the fact that Obama was never
7 a resident of CT.
8 This evidence is so overwhelming, that it doesn’t even require additional
9 investigation.
10 Pursuant to US Code Title 18, Part 1, Chapter 1 § 4 - Misprision of Felony
Title 18, Part 1, Chapter 1 § 3. Accessory after the fact:
11 Whoever, knowing that an offense against the United States has been
12 committed, receives, relieves, comforts or assists the offender in order to hinder
or prevent his apprehension, trial or punishment, is an accessory after the fact.
13 Except as otherwise expressly provided by any Act of Congress, an accessory
14 after the fact shall be imprisoned not more than one-half the maximum term of
imprisonment or (notwithstanding section 3571) fined not more than one-half
15 the maximum fine prescribed for the punishment of the principal, or both; or if
16 the principal is punishable by life imprisonment or death, the accessory shall be
imprisoned not more than 15 years.
17
US attorney’s actions in not prosecuting this matter goes beyond mere
18
negligence, it falls within the realm of misprision of felony and aiding and abetting
19
commission of felony, predicate acts, which will tie in above US attorneys to Mr.
20
Obama and sufficient for RICO legal action.
21
22
These actions of Obama and US attorneys have exposed me to further severe
23
emotional distress, assaults, insults, death threats, and numerous hate crimes relating
24
to my legal actions, representing my clients and myself and trying to protect the
25
public at large from this massive fraud committed by Obama and currently aided and
26
abetted by US attorneys.
27
The court is entitled to obtain Defendant’s Records.
28
1
2
3 The defendant intentionally misrepresents the complaint by claiming that the
4 plaintiff is not entitled to the Defendant’s records quoting Freedom of Information
5 Act.
6 This is a case of Quo Warranto. The defendant is an attorney, who during the
7 campaign represented himself as a constitutional scholar, constitutional professor. As
8 such he is surely aware of the fact that Quo Warranto has existed for some 700 years
9 before the Freedom of Information act was ever enacted.
10 I have requested that the Attorney General and US attorney fulfill their duties
11 and verify Obama’s qualifications under Quo Warranto. As they breached their
12 duties, I am asking the court to grant me Ex Relator Status, step in the shoes of these
13 derelict US attorneys, who didn’t do their job, which we, the tax payers, have paid
14 them to do. As the court grants me Ex Relator status, I will be entitled to obtain all
15 the necessary records to prove or disprove Obama’s legitimacy. This shows that the
16 Defendants assertion that I have no Entitlement to records is an absurd and was
17 brought to confuse Your Honor.
18 Defendant’s claim that my complaint is a non-justiciable political question, is
19 a complete absurdity and was brought to mislead Your Honor.
20 About a third of the brief 4-5 pages is completely irrelevant, as those are devoted
21 to the mechanisms of the elections and removal of the president from office. I have
22 never asked your Honor to remove Mr. Obama from office. All I have asked for,
23 is discovery, and based on this discovery, a declaratory relief, declaring whether Mr.
24 Obama has indeed qualified to office or not per Quo waranto and per Article 2,
25 section one of the Constitution. Did he provide valid records or did he defraud the
26 voters, electors and Congress? This is the whole purpose of Quo Warranto. Quo
27 warranto was used for hundreds of years, it is codified in DC statutes as explained
28 in the complaint. Department of Justice and US attorneys office in the Central
District of CA argued that the District of Columbia is the proper jurisdiction and
1
2
3 Judge David O. Carter has dismissed the Quo Warranto in CA, noting that he doesn’t
4 want to “rob the District of Columbia of it’s Jurisdiction”. We are now in the correct
5 jurisdiction, I applied correct statutes. After the discovery and trial, your Honor will
6 make a Declaratory Relief, whether the defendant was qualified based on Quo
7 Warranto or whether he occupied his position based on fraud. After the declaratory
8 relief the Congress and Senate will be able to proceed with impeachment and
9 removal. I am providing, as exhibits, letters I have received from Senator McCain,
10 Mr. Obama’s opponent in 2008 general election, and a letter from senator Sessions
11 received by one of my supporters. Both letters state that they cannot get involved,
12 while the matter is being decided by the courts, as this will be seen as ethical
13 violation and interference with the work of another branch of the government. As
14 district of Columbia is a proper jurisdiction and Congress cannot get involved until
15 there is a judicial determination and declaratory relief, it is not only your right your
16 Honor to adjudicate, it is not only a justiciable issue, but as the Chief Judge for
17 the US District court for the District of Columbia, you have a duty to exercise
18 your jurisdiction, as according to undying words of Justice Marshall, not
19 exercising Jurisdiction, where it lies, is a treason to the Constitution.
20 Moreover, as I have presented evidence of felony committed by the defendant in
21 his use of multiple social security numbers, as well as clear evidence of his use of the
22 Social Security number of at least one deceased individual. Your Honor, as an officer
23 of the court, you have an obligation to proceed, as not doing so will expose Your
24 Honor to the liability of aiding and abetting commission of felony and misprision of
25 felony. Your Honor has no other choice, but to proceed with the discovery.
26
27
28
Standing
1
2
3 As I have stated previously, this complaint is a motion for leave of court for Ex
4 Relator status in Quo warranto. DC statute does not require any particular
5 standing or any damages for Quo Warranto, therefore standing and damages is
6 a mute point, brought by the defendant to simply muddy the issues.
7 Muddy the issues, is probably the operative word to characterize the opposition
8 brief, as it didn’t address any issue, didn’t address any law or any injury. It was
9 written specifically to skirt the issues, misrepresent the facts and belittle and
10 denigrate me in the eyes of the court. Very telling, is a remark on page 8,line 1,
11 calling application for preliminary injunction rambling. I have to state that the
12 opposition brief definitely goes beyond rambling, it goes into the territory of assault
13 to intelligence of each and every American, and there are millions of Americans
14 following this case. The opposition brief did not address any fact or any law
15 presented in the application.
16 The defense claims that I didn’t suffer any injury. The defense can’t find any
17 injury in Obama administration applying pressure on different agencies intimidating
18 and harassing me and my plaintiffs and investigators, they could not find any harm in
19 daily death threats, vandalism, tampering with my car and endangering my family,
20 constant assaults coming from the media, which became the regime propaganda
21 machine, from the law enforcement and US attorney’s office itself refusing to
22 investigate any crimes against me, from use of the Judiciary as a tool to intimidate
23 me and endanger my law license.
24 What exactly will it take for the Department of Justice to concede that indeed I
25 was harmed or in imminent danger of being harmed. Do I need to be actually
26 crucified? Knowing modus operandi of Holder Department of Justice, I am not sure
27 even that will be enough. They might still find some reason to state that there was no
28 harm, no injury. They probably will state that the nails were not long enough, who
knows…
1
2
3 The extent of damages and indifference and unwillingness to act by the law
4 enforcement and the Department of Justice has prompted me to file a complaint with
5 the UN commission for Human Rights defendants.
6 To summarise the issue of damages standing, I have enumerated my damages in
7 grand detail in the complaint, however I did not need to show any damages, as Quo
8 Warranto statute does not require one seeking ex relator status any particular
9 standing or damages.
10 Traceability of injury
11 The defense is stating that the injury of $20,000 sanctions is not traceable to the
12 defendant. Let’s try it again.
13 I never had any sanctions assessed against me: never before and never after.
14 I never had any reprimand against me. I have a perfect clean record. The only
15 time in my life, when I was sanctioned by the court, is where judge Land stated that
16 my representation of the members of US military questioning Barack Obama’s
17 legitimacy to presidency is frivolous, and due to that he sanctioned me.
18 Let’s see, what did he find frivolous? I forwarded to Judge Land reports from
19 licensed investigators, showing that Obama used multiple social security numbers,
20 none of which were issued in Hawaii, where he claims he was born, and where he
21 was raised. Who is usually using multiple social security numbers of others?
22 Typically people, who were not born in this country, are the people, who do not have
23 a valid social security number and need to resort to stealing the Social Security
24 numbers of others.
25 I presented information that Obama refused to unseal his original birth certificate
26 and all other vital records, and the fact that the state of Hawaii statute 338-17 allows
27 a foreign born child of Hawaiian resident to get a Hawaiian birth certificate, as well
28 as the fact that statute 338-5 allows one to get a birth certificate based on a
statement of one relative only without any corroborative evidence. This evidence
1
2
3 is at least sufficient evidence to order discovery. Clearly there is nothing frivolous in
4 bringing an action on behalf of the members of the military seeking to verify
5 Obama’s legitimacy in light of all the above facts.
6 Who sealed his original vital records, who is refusing to unseal them? Obama!
7 Who is using social security numbers of deceased individuals and numbers never
8 assigned? Obama!
9 Judge Land is a federal employee and as such works for the Chief Executive in
10 the Federal government, Obama. Does the assistant US attorney have to be Albert
11 Einstein to be able to trace the connection between Barack Obama’s social security
12 fraud, his obfuscation of all of his records, my bringing this issue to court and the
13 decision by judge Land to use $20,000 in sanctions to silence me? I believe
14 traceability is very clear and I don’t need to belabor on this any further.
15 Background of the case
16 About a third of the brief is dedicated to the background of the case, which was
17 completely bent out of shape and the truth was misrepresented. I don’t need to write
18 5-6 page of the background. I can summarize the background of the case in one
19 sentence. Obama’s legitimacy for presidency was never adjudicated on the merits, no
20 discovery was done, since no judge so far had the guts to hear the case on the merits.
21 We don’t need to go far. A year ago Attorney John Hemenway, 30 year veteran of
22 JAG and State department foreign corps have brought to this district court Obama
23 eligibility issue Hollister v Soetoro. Obama was named by the last name he used in
24 Indonesia, Soetoro, since there is no record of him legally changing his name back to
25 Obama, and there is a high likelihood that Obama was inaugurated and sworn in
26 under the name, which is not legally his. Judge James L. Robertson came up with a
27 decision, that the proper prima facia evidence should not be viewed and discovery
28 and trial should not go on, since Obama’s legitimacy for presidency “was twittered
and massaged on the blogs”. The whole country didn’t know whether to laugh or to
1
2
3 cry reading this opinion of a Federal judge. To add insult to injury Judge Robertson
4 has threatened attorney Hemenway with sanctions. Same modus operandi, as I
5 experienced with Judge Land. The only difference was, that older Judge Robertson
6 had enough life wisdom, common sense and experience to stop short of actually
7 assessing those sanctions, he stopped at repriment, which Hemenway is currently
8 appealing in the Court of Appeals. Younger and more eager to get promotions Judge
9 Land actually assessed those sanctions. Regardless of nuances both decisions are
10 upfront to basic law and Constitution and decency. Today Judge Robertson is
11 known through the blogosphere, through the Internet as a twitter judge. As I have
12 filed my complained with the UN and has given some 700 interviews all over the
13 World. Attorney, judges and public around the World are buffled and bewildered at
14 what is happening in the US. Clearly Judge Robertson knows that twittering and
15 massaging on the blogs is not a proper form of evidence, that there is a need to
16 unseal the original birth certificate and all the other vital records. So what is the
17 explanation to such indefensible decisions? The only reasonable explanation, is that
18 not only attorneys like I and Hemenway were threatened, but Federal Judges
19 themselves were threatened and intimidated by the Obama regime, by the Obama
20 administration, that there was some fear of retaliation from Holder department of
21 Justice, from Pelosi Congress.
22 Here is another example. I am forwarding a transcript of the July 13 hearing in
23 Keyes et al v Obama in front of judge David O. Carter in the Central District of CA
24 (as more plaintiffs were later added to the case, and the plaintiffs were listed in
25 alphabetical order, it was renamed as Barnett et al v Obama et al). At a time when
26 Judge Land claimed that Obama illegitimacy cases are frivolous, a more experienced
27 judge David O. Carter was stating on the record time and again that this case is very
28 important for the military and for the country as a whole, and it needs to be heard on
the merits. Judge Carter has scheduled the case for trial for January 26, 2010 in CA.
1
2
3 Later, on October 1, 2009 Obama administration was able to place as a law clerk
4 with judge Carter one Sidharth Velamoor, an attorney who is still listed as working
5 for Perkins Coie, Obama’s defense firm, the firm of Robert Bauer, Chief White
6 House Legal Counsel. From October 1 the attorney for the defense firm was doing
7 legal research for the presiding judge and drafting orders. Is it surprising to you Your
8 Honor to find out that judge Carter has suddenly changed his opinion and decided
9 that he no longer has jurisdiction, even though he was adamant he had it before. I
10 suddenly felt that I was immersed back in the nightmare of the dictatorial regime of
11 the Communist Soviet Union, from which I escaped earlier. There were other
12 interesting connections and correlations between Mr. Velamoor and Mr. Obama.
13 Both of them are officially graduates of Columbia university, however different legal
14 directories show Velamoor graduating either from Columbia law school or
15 Commenis law school in Bratislava Slovakia and some 400 students attending
16 Columbia same time as Obama and taking same courses as Obama can’t remember
17 seeing him there. Yet another interesting fact: both came from the same small
18 community of Mercer island, WA. While Obama claims, that his mother lived on HI
19 in 1961-1962, official records of the university of HI show her as dropping out at this
20 time. She was nowhere to be found for nine months from December 1960 to end of
21 August 1961, when she reappeared on Mercer island and enrolled as a student in
22 University of Seattle Washington for Fall and winter quarters of 1961-1962. Nothing
23 about Mr. Obama seems to be true. A lot about Mr Obama is questionable an a
24 reason for deep concern. What I am doing today is equal to a new civil rights
25 movement, a movement to reassert civil rights of the US citizens to have their cases
26 heard in the court of law based on the Constitution, based on clear evidence, proper
27 original valid records, not based on twittering, not based on intimidation of judges
28 and attorneys. If Obama regime is successful in silencing attorneys like me, working
1
2
3 pro bono to uphold the constitutional freedoms, then we don’t have a Constitution,
4 then we have a dictatorship, a tyranny.
5 Your Honor the choice is clear: you can be one of those judges who summarily
6 dismissed each and every pleading by Thurgood Marshall, not willing to rock the
7 boat and the establishment, or you can be Judge Earl Warren of the 21 st Century and
8 uphold the system of Justice and the Constitution.
9 Fraud is a fraud, regardless of who perpetrates it, whether it is perpetrated by one
10 forging documents to get a deed to a house or a lease to the White House. No one is
11 above the law. The Nation is watching and the Nation is waiting. UN committee for
12 Defenders of the Human Rights is watching and waiting for your decision. After I
13 have done over 700 interviews all over the World, the World is watching and waiting
14 for your decision. Your decision can be one of obfuscation of all of vital records of
15 one sitting in the White House, it can be a decision of aiding and abeting Social
16 Security Fraud and Misprision of Felony of Social Security Fraud and Identity theft
17 by Mr. Obama, or it can be a decision of upholding the law. Your decision can
18 signify further persecutions of me, as a decedent fighting Obama regime, or it can be
19 a decision putting an end to persecutions. The decision is yours and the Nation is
20 watching and the World is watching.
21 Wherefore the plaintiff respectfully requests this Honorable court to deny the
22 defendant’s motion to dismiss and grant her application for injunctive relief as stated
23 above.
24
25
26
27
/s/ DR ORLY TAITZ ESQ
28 By:__________________________________
Dr. Orly Taitz, Esq. (California Bar 223433)
1
2
3 Attorney for the Plaintiffs
29839 Santa Margarita Parkway ste 100
4 Rancho Santa Margarita CA 92688
Tel.: 949-683-5411; Fax: 949-766-7603
5 E-Mail: dr_taitz@yahoo.com
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21 PROOF OF SERVICE
22
I CERTIFY THAT TRUE AND CORRECT COPY OF THE ABOVE
23
PLEADINGS WAS SERVED on 03.19.10 by Electronic Mail
24
Alan Burch, Assistant United States Attorney for the District of Columbia
25
555 4th str.,N.W.
26
Washington D.C. 20530
27
/s/Orly Taitz
28
Dr. Orly Taitz Esq
29839 Santa Margarita PKWY
Taitz v Obama. Opposition to motion to dismiss. 11
Case 1:10-cv-00151-RCL Document 16 Filed 03/22/10 Page 140 of 145
1
2
Rancho Santa Margarita CA 92688
3
4
5 Proposed Order
6 Plaintiff’s Application for preliminary injunction is granted.
7 Defendant’s motion to dismiss is denied.
8
9 Defendant is ordered to release by March 26,2010 his original birth certificate,
10 which was allegedly obtained based on the defendant’s birth in Kapiolani hospital in
11 Hawaii on 08.04.61.
12 Defendant is ordered to release his birthing (live birth or labor and delivery) file
13 from Kapiolani Hospital by March 26, 2010.
14 Defendant is ordered to release by March 26 his school enrolment records and
15 financial aid application records from Occidental college, Columbia University,
16 Harvard University and Punahoa High School.
17 Defendant is ordered to release by March 26, 2010 any and all of his passport
18 applications.
19 Defendant is ordered to release by March 26, 2010 his Social Security application
20 and explain why Social Security number, used by him for most of his life, including
21 Selective Service application shows 042- ,the code of the State of CT, even though
22 the defendant never resided there, and why this number shows as being assigned to
23 an individual born in 1890, even though the defendant was not born in 1890 and is
24 not 120 years old.
25 Defendant is ordered to provide an explanation by March 26, 2010, why National
26 databases Choice Point and Lexis –Nexis show him using as many as 39 different
27 Social Security numbers, none of which were issued in the state of Hawaii.
28 Mr. Michael Astrue, Director of the Social Security Administration, is ordered to
provide by March 26, 2010 an original Social Security application for Barack
1
2
3 Hussein Obama and an explanation why is he using a Social Security number issued
4 in the state of Ct, to an individual born in 1890, even though the Defendant never
5 resided in the state of CT and was not born in 1890, as well as access to the original
6 Social Security application of the Defendant to be granted to the Plaintiff’s forensic
7 document expert.
8 Secretary of State Hillary Clinton is ordered to release by March 26, 2010
9 Defendant’s passport application and access to such application to be granted to the
10 Plaintiff’s forensic document expert.
11 It is so ordered and adjudged
12
13 Honorable Royce C. Lamberth
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28