Linda Jordan Files General Election Ballot Access Challenge to Obama in State of Washington - Filed...

7/31/2019 Linda Jordan Files General Election Ballot Access Challenge to Obama in State of Washington - Filed 27Aug2012

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PlaintiffsMotionForOrderToShowCause LindaJordan, PlaintiffProSe

AffidavitOfLindaJordan;Memorandum

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Standing

RCW 29A.68.011 (1) (3)1

provides for the prevention and correction of election frauds, errors

and wrongful acts, including a failure to perform a duty. Challenges may be brought by an

elector before ballots are printed. Any justice of the supreme court, judge of the court of

appeals, or judge of the superior court in the proper county shall, by order, require any person

charged with error, wrongful act, or neglect to forthwith correct the error, desist from the

wrongful act, or perform the duty and to do as the court orders or to show cause forthwith why

the error should not be corrected, the wrongful act desisted from, or the duty or order not

performed, whenever it is made to appear to such justice or judgeby affidavit of an elector that:

(1) An error or omission has occurredor is about to occur in printing the name of any

candidate on official ballots; or (2) An error other than as provided in subsections (1) and (3) of

this section has been committed or is about to be committed in printing the ballots; or (3) The

name of any person has been or is about to be wrongfully placed upon the ballots; and that,

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An affidavit of an elector under subsections (1) and (3) of this section when relating to a37

general election must be filed with the appropriate court no later than three days following the38

official certification of the primary election returns and shall be heard and finally disposed of by39

the court not later than five days after the filing thereof. (Emphasis added)40

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The Superior Court, Thurston County, Is A Proper Venue For This Election Challenge

5. RCW 29A.68.011 requires election contests to be brought before, Any justice of the supreme

court, judge of the court of appeals, or judge of the superior court in the proper county .

(Emphasis added) County superior courts have concurrent original jurisdiction over actions

against the Secretary of State concerning statewide election challenges. The wrongful acts

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1RCW29A.68.011(1)(3)

Copy provided courtesy of: ProtectOurLiberty.org


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Plaintiff wants to prohibit would occur in every Washington County, including the one Plaintiff

lives and votes in, King County. The acts originate out of Thurston County.

Wrongful Acts, Duty to Perform

1. Plaintiff is contesting the Secretarys placement of the name Barack Hussein Obama II aka

Barack Obama on the 2012 General Election ballot as a candidate for the Office of President of

the United States (RCW 29A.68.011 (1) (3)) and alleges that the identity document Obama has

proffered as proof, to the Secretary and every Washington State elector, that he is eligible to be a

presidential candidate, is forged. A forged document can not be used to prove anything. The

Secretary would be aiding and abetting fraud if he were to place a candidates name on the ballot

who is using a forged identity document to prove eligibility. This assist would certainly help

Candidate Obama.2

2. Plaintiff alleges that the Secretary is violating WAC 434-215-1653

by certifying the names of

major party political candidates for President and Vice-President to the General Election Ballot

before their conventions are held and before receiving from the major parties a Certificate of

Nomination and list of electors4

for said candidates. In 2008 the Secretary did not certify Obama

to the General Ballot until 3-9 days after receiving the Nomination from the DNC, after their

convention.5

2ConstructiveFraud:Anybreachofdutywhich,withoutactualfraudulentintent,gainsanadvantagetotheperson

infault3WAC434215165Presidentialnominationsbymajorpoliticalparties.Nominationsforpresidentandvice

presidentbymajorpoliticalpartiesareconductedateachparty'snationalconvention.Immediatelyfollowingthe

convention,eachpartymustsubmitacertificateofnominationandlistofelectorstothesecretaryofstatein

ordertoplacethenomineesonthepresidentialgeneralelectionballot.4Ex1AppearingonWashingtonStateBallotinWashingtonState5Ex2KitsapCounty2008ElectionCalendar,DNCNomination,DNC2008Conventiondates.



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3. Plaintiff alleges that the Secretary has a legal duty to carry out elections in a uniform manner6,

to treat candidates equally where it concerns the eligibility oath. The Secretary requires Write In

candidates for President and Vice President to swear an eligibility oath or their declaration as a

candidate will not be considered.7

The Secretary has placed the names of Major Party candidates

on the General Election ballot before receiving an eligibility oath from them.

4. The filing officer for state and federal offices is required by the Secretary to verify eligibility

information provided by the candidate and should also do so for major party president and vice-

presidential candidates.8

Courts Have Upheld Eligibility Requirements And Equal Treatment For Candidates

1.Treating candidates equally is, as a matter of law, an important state interest. (See, e.g.,

Council of Alternative Political Parties v. Hooks, 179f3d. 64, 78 (3d Cir.1999))9

Candidate

Obama should be held to the same instruction that the Secretary holds Write In Candidates for

President and Vice-President to: they have to swear an eligibility oath and if they dont swear the

oath their declaration will not be accepted.State and other federal candidates have their

eligibility information verified by the Secretary.10

The Secretary has the authority to verify the

eligibility claims of Candidate Obama.

2. The eligibility assertions of major party president and vice-president candidates are initially

presumed by the Secretary, however, the Washington State Supreme Court has found that while

6RCW29A.04.611Rulesbysecretaryofstate.Thesecretaryofstateaschiefelectionofficershallmake

reasonablerulesinaccordancewithchapter34.05RCWnotinconsistentwiththefederalandstateelectionlaws

toeffectuateanyprovisionofthistitleandtofacilitatetheexecutionofitsprovisionsinanorderly,timely,and

uniformmannerrelatingtoanyfederal,state,county,city,town,anddistrictelections.Tothatendthesecretary

shallassistlocalelectionofficersbydevisinguniformformsandprocedures.7Ex3EmailfromSOSElectionsDepartmenttoLindaJordan8Ex42012KingCountyCandidateManuelTheofficerwithwhomdeclarationsarefiledshallrevieweach

declarationforcompliancewiththislaw.9CouncilofAlternativePoliticalPartiesv.Hooks,179f3d.64,78(3dCir.1999)10

Ex42012KingCountyCandidateManuel



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it is an unqualified right for an eligible person to aspire to public office, that if there is any

doubt as to a candidates eligibility, that doubt must be resolved. In State v. Schragg, 158

Wash. 74, 78, 291 P. 321 (1930), we stated: Since the right to participate in the government is

the common right of all, it is the unqualified right of any eligible person within the state to aspire

to any of these offices, and equally the unqualified right of the people of the state to choose from

among those aspiring the persons who shall hold such offices. It must follow from these

considerations that eligibility to an office in the state is to be presumed rather than to be denied,

and must further follow that any doubt as to the eligibility of any person to hold an office must88

be resolved against the doubt. (Emphasis added) (GERBERDING v. MUNRO No. 65059-4.

Washington State Supreme Court, En Banc)

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The Secretary Can and Does Check Candidates for Eligibility But Is Failing To Do So With

Candidate Obama

1. From the King County 2012 Candidate Manuel: Declarations of candidacy and filings (RCW

29A.24, WAC 434-215) A candidate who desires to have his or her name printed on the ballot

for election to an office other than President of the United States and Vice President of the

United States, shall complete and file a Declaration of Candidacy. A person filing a Declaration

of Candidacy for an office shall, at the time of filing, possess the qualifications specified by law

for persons who may be elected to the office. The candidate must be properly registered to vote

in the geographic area, district and/or division represented by the office at the time of filing.

The officer with whom declarations are filed shall review each declaration for compliance100

with this law.12

(Emphasis added) The major party candidates for President and Vice-President101

11GERBERDINGv.MUNRONo. 650594

12Ex4 KingCounty2012CandidateManuel



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are exempt from filing a Declaration of Candidacy because their party files a Certificate of

Nomination on their behalf. However, this does not make them exempt from satisfying

established eligibility requirements. Just like candidates for every other office, federal offices

included, major party presidential and vice-presidential candidates are not exempt from meeting

the eligibility requirements established by the Constitution and Washington State law.13

The

Secretary oversees every countys election department. Under the direction of the Secretary the

filing officer is obligated to review each declaration for compliance with the law, it is a

ministerial duty.14

2. The Secretary instructs filing officers to review candidate declarations for eligibility. From

SOS publication, CAN YOU REJECT A DECLARATION?15

Yes, if the declaration is defective as to face. For example, if a candidate lists an address

outside the district, it must be rejected, or if the form is submittedand the candidate is not

registered to vote. The filing officer, under instruction from the Secretary, is performing a

ministerial duty to verify the candidates eligibility. While this direction says declarations can be

rejected if, on the face of it, the officer sees a defect, the two examples given are not obvious on

the face of it and can only be verified if the officer checks to see if the address is in the required

boundary or checks to verify if the candidate is a registered voter. It is legal for the Secretary to

order filing officers to check to see if information provided by candidates is true, including

candidates for federal office. It is legal and should be required for filing officers to check the

eligibility information provided by major party presidential and vice presidential candidates.

Supporting Documents

13Ex5SOSPresidentialeligibilityrequirements

14ministerialactn.anact,particularlyofagovernmentalemployee,whichisperformedaccordingtostatutes,

legalauthority,establishedproceduresorinstructionsfromasuperior,withoutexercisinganyindividualjudgment.15Ex6 SOSCanyourejectaDeclaration?



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Plaintiff attaches to this Motion 1. The Affidavit of Linda Jordan with exhibits. 2. A

Memorandum In Support with Appendix of Law.

Prayer For Relief

For the reasons stated above and for those stated in the supporting Memorandum and Affidavit,

Plaintiff requests that the Court order the Secretary of State;

1. To stop or prohibit the printing of ballots until disposal of this challenge. 2. To prohibit the

Secretary from placing the name of Candidate Barack Hussein Obama II aka Barack Obama on

the 2012 General Election ballot in Washington State as a candidate for the Office of the

President of the United States. 3. To prohibit the Secretary from continuing to exempt major

party President and Vice-President Candidates from eligibility checks by filing officers. 4. To

prohibit the Secretary from certifying the names of Major Party President and Vice-President

Candidates to the counties for a General Election until a Certificate of Nomination and list of

electors is received after the Major Partys Convention nomination process. 5.To require all

Major, Minor and Independent candidates, for President and Vice-President, to be held to the

same Eligibility Oath and instructions that Write In Candidates for President and Vice President

are in Washington State.

Plaintiffs Motion And Attached Affidavit Alleged With Sufficient Certainty

RCW 29A.68.030 provides that "no statement of contest may be dismissed for want of form if

the particular causes of contest are alleged with sufficient certainty."16

In re Election Contest

Filed by Coday ( 497 156 Wn.2d 485, March 2006)17

the Washington State Supreme Court

stated that, "Sufficient certainty" is not defined in the statute, nor have we had occasion to

16RCW29A.68.030

17ElectionContest FiledbyCoday



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andAppendixOfLaw 8

LindaJordanv.SecretaryofState,SamReed

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define that particular term. However, in previous election contest cases, this court has utilized

generally applicable, liberal pleading rules. In Dumas, .we observed that [a]though

Respondent's petition did not cite specific subsections of the [election contest] statute, sufficient

facts and law were stated concerning the nature of the claim to bring the petition under the

statute. Although the petition is not a model of pleading, it is nevertheless adequate so long as it

is sufficient to satisfy necessary legal requirements. Lightner, 59 Wn.2d at 858 (quoting

Sherwood v. Moxee Sch. Dist. No. 90, 58 Wn.2d 351, 353, 363 P.2d 138 (1961) (quoting Conley

v. Gibson, 355 U.S. 41, 45, 78 S. Ct. 99, 2 L. Ed. 2d 80 (1957).18

Dated this _______ day of August, 2012 in Seattle Washington

________________________________________________

Linda Jordan, Plaintiff Pro Se

18Lightner,59Wn.2dat858(quotingSherwoodv.MoxeeSch.Dist.No.90,58Wn.2d351,353,363P.2d138

(1961)(quotingConleyv.Gibson,355U.S.41,45,78S.Ct.99,2L.Ed.2d80(1957)



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ExhibitList/LawCitationsPlaintiffsMotionForOrderToShowCauseLindaJordanvSecretaryofState,SamReed

Exhibits1.Ex1AppearingonthePresidentialBallotSOS2012

2.Ex2KitsapCounty2008ElectionCalendar,2008DNCNominationformforObama,DNC2008

conventiondates

3.Ex3EmailfromSOStoJordan:Writeincandidatesforpresidentmustsweareligibilityoath

4.Ex4

2012

King

County

Candidate

Manuel

5.Ex4

6.Ex4

7.Ex5SOSpresidentialeligibilityrequirements

8.Ex6SOStrainingmaterial,Canyourejectacandidate?

Laws1.RCW29A.68.011(1)(3)

2.ConstructiveFraud..Anybreachofdutywhich,withoutactualfraudulentintent,gains

advantagetothepersoninfault

3.WAC434215165

4.RCW29A.04.611

5.Gerberdingv.MunroNo.650594

6.Ministerialactdefinition

7.RCW29A.68.030

8.ElectioncontestfiledbyCoday

9.Lightner,59Wn.2dat858(quotingSherwoodv.MoxeeSch.Dist.No.90,58Wn.2d351,353,

363P.2d138(1961)(quotingConleyv.Gibson,355U.S.41,45,78S.Ct.99,2L.Ed.2d80

(1957)



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PLAINTIFFSMOTIONFORORDERTOSHOW 1OF18 LINDAJORDAN,PLAINTIFF PROSE

CAUSE;AFFIDAVITOFLINDAJORDAN;

MEMORANDUMANDAPPENDIXOFLAW

LINDAJORDAN V.SECRETARYOFSTATESAMREED

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x Expedite

Nohearingset

XHearingisset

Date:September7,20129:00AM

Judge/Calendar:LisaSutton

IN THE SUPERIOR COURT OF THE STATE OF WASHINGTON

FOR THURSTON COUNTY

Linda Jordan ) No. 12-2-01763-5

)

Plaintiff ) PLAINTIFFS AFFIDAVIT WITH EXHIBITS

) IN SUPPORT

v. ) OF MOTION FOR ORDER TO SHOWCAUSESecretary of State Sam Reed )

)

Defendant )

___________________________________________________________________________

I, Linda Jordan, am over the age of 18 years old; I have personal knowledge of the facts listed

below and declare before God and under penalty of perjury, 1. I am a registered voter and a

resident of King County Washington. 1 2. I have researched the 2; a. the Constitutional

1Ex1ProofofVoterRegistration

2RuleER602PersonalKnowledge



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requirements that must be met in order to be eligible to be President of the United States, b. the

eligibility oath Write In Presidential Candidates take in Washington State, c. the identity

documents the Social Security Administration (SSA) uses to verify citizenship and age, d. what

the SSA looks for in forged documents and e. the birth document posted on the White House

Website on April 27th, 2011 purported to be a scanned photocopy of Barack Obamas original

1961 long form Certificate of Live Birth.

3. I am contesting the placement of the name Barack Hussein Obama II aka Barack Obama on

the 2012 General Election ballot as a candidate for the Office of President of the United States.

(RCW 29A.68.011 (1) (3))3

and allege that the identity document Obama has proffered as proof

that he is eligible to be a presidential candidate, is forged.

4. Evidence is offered in this Affidavit.4

5. The Secretary of State (SOS) processes all applications and documents submitted in

Washington State on behalf of candidates for the offices of President and Vice President of the

United States and is the Filing Officer for those offices.5

The Secretary submits candidate

names that will be on the General Election ballot to every county in Washington State.

6. The SOS booklet, Appearing on the Presidential Ballot in Washington State says that, In

order to appear on the Washington State General Election Ballot, major political parties submit

the names of nominees selected at the national conventions.6

The law requires candidates to be

3RCW29A.68.011(1)(3)4RuleER401RelevantEvidenceRuleER601RuleofCompetencyER904AdmissibilityofDocumentsRuleER902

SelfAuthentication5RCW29A.56 RCW29A.04.0676Ex2SOSBookletAppearingonPresidentialBallot(pg.4)



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eligible7 and the Secretary instructs Write-In Candidates for President to make sure they are

eligible.

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7. The DNC Convention will be held September 4th

-7th

2012. Barack Obama is acknowledged

by the national media as the presumptive Democrat presidential candidate and would accept the

nomination on September 7th, 2012. The DNC did not proffer any other candidate names for

President in the 2012 General Election. The Republican National Committee Convention (RNC)

will be held the week of August 27, 2012.9

8. The Secretary has been given the authority to determine who the presidential candidates for a

major political party are in a Presidential Primary. RCW 29A.56.030 Ballot Names

included. The name of any candidate for a major political party nomination for president of the

United States shall be printed on the presidential preference primary ballot of a major political

party only: (1)By direction of the secretary of state, who in the secretary's sole discretion has

determined that the candidate's candidacy isgenerally advocated or is recognized in national

news media; 10

(emphasis added)

9. For financial reasons the Presidential Primary in Washington State was suspended for 2012.11

10. RCW 29A.68.011 (1)(3) provides for the prevention and correction of election frauds,

errors and wrongful acts. The RCW says that the challenge shall be filed within, three days

following the official certification of the primary election returns and shall be heard and finally

disposed of by the court not later than five days after the filing thereof.12

7WAC4342151708Ex3SOSWriteInCandidateform&Instructions9Ex4ConventionSchedule10

RCW29A.56.03011

Ex2SOSbooklet,pg.412

RCW29A.68.011(1)(3)



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11. The Secretary certified the Primary Election Results to the Counties on August 24, 2012.13

The names of major party Presidential Candidates, even though their Conventions had not yet

been held, are now included on the 2012 General Election Voters Guide.

12. Ballots in Washington State for the 2012 General Election could be ordered for printing

beginning August 24th, 2012.14

As of June 6, 2012, Washington has 3,698,955 active registered

voters.15

13. This time frame, dictated by law and combined with the printing schedule established by the

Secretary, does not allow for an RCW 29A.68.011 (1)(3)16

challenge to be brought and disposed

of before the printing of General Election ballots is allowed to begin.

Standing

14. RCW 29A.68.011 gives an elector standing to ask for the removal of and/or challenge to

the placement of a candidates name on the Washington State General Election ballot.

The Eligibility Oath Is Given Substantial Weight for Presidential Candidates In The

Washington State Election Process

15. The qualifications to be President of the United States are found in the United States

Constitution. Article II, Section 1 Clause 5,No person except a natural born Citizen, or a Citizen

of the United States, at the time of the Adoption of this Constitution, shall be eligible to the Office

of President; neither shall any Person be eligible to that Office who shall not have attained to

the Age of thirty-five Years, and been fourteen Years a Resident within the United States.17

13Ex5SOSCertifiedPrimaryReturnsforPresident

14Ex6SOSEmailtoLindaJordanwhenballotscanbeprinted

15http://www.sos.wa.gov/elections/vrdb/VRDBFaq.aspx

16RCW29A.68.011threedaysfollowingtheofficialcertificationoftheprimaryelectionreturnsandshallbe

heardandfinallydisposedofbythecourtnotlaterthanfivedaysafterthefilingthereof.17

Ex7ArticleIIU.S.Constitution



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16. Two of the three Constitutional qualifications are affirmed on the Washington State Secretary

of State website under Descriptions of Elected Offices: President/Vice President it states: The

President must be at least 35 years of age and a natural born U.S. citizen.18

17. Washington Administrative Code (WAC) requires that a candidate possess all

qualifications of the office at the time of candidate filing, a candidate must satisfy this

requirement at the time of candidate filing and can not rely on possessing the qualifications at a

later time19

18. The Secretary of State as chief election officer shall make reasonable rules in accordance

with chapter 34.05 RCW not inconsistent with the federal and state election laws to effectuate

any provision of this title and to facilitate the execution of its provisions in an orderly, timely,

and uniform manner relating to any federal, state, county, city, town, and district elections. To

that end the secretary shall assist local election officersby devising uniform forms and

procedures.20

(Emphasis added)

19. The Secretary devised a Declaration of Write-In Candidacy form for President or Vice

President. That form contains an oath. The oath on the Write In Declaration for President or Vice

President states; I declare that the above information is true, thatI am a natural born citizen of

the United States residing at the address listed above, that I am a write-in candidate for the

office as indicated above, and that,at the time of filing this write-in declaration, I am legally

qualified to assume office.21

(Emphasis added) The Washington State Constitution describes

that the mode of administering an oath, shall be such as may be most consistent with and

18Ex8SOS Presidenteligibilityqualifications

19WAC434215170

20RCW29A.04.611

21Ex9SOSWriteInPresidentialCandidateform



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binding upon the conscience of the person to whom such oath, or affirmation, may be

administered.

22

20. On the Write In form the Secretary instructs Write-In Candidates for President or Vice

President that, before they sign the oath, You must ensure that you meet all qualifications of the

office. The Secretary has acknowledged those qualifications to be; that they are at least 35 years

of age, are a natural born citizen of the United States and are otherwise legally qualified to

assume the office.23

21. The Write In Presidential Candidacy Oath is given substantial weight by the Secretary.

Plaintiff received a response from the SOS Election Department wherein they state they would

not accept a Write In Declaration of Candidacy for President or Vice President without signing

the oath, If a candidate submits any type of declaration of candidacy form without signing the

oath, the declaration is not deemed valid.24

Original Birth Certificate Is The Primary And Preferred Level of Evidence For

Establishing Citizenship Status And Age: Two of the Eligibility Requirements To Be A

Presidential Candidate In Washington State

22. The Social Security Administration (SSA) establishes proof of U.S. citizenship status by

viewing the authentic, original birth certificate (or an authentic certified copy thereof) which

confirms the place and time of birth along with the parents age and place of birth.25

23. When applying for a Social Security Number (SSN) an original birth certificate is considered

by the SSA as the primary and preferred level of evidence of age and citizenship. The SSA

22Ex10WashingtonStateConstitution,Oath

23Ex9SOSWriteinPresidentialCandidateform

24Ex11SOSApril17,2012emailtoLindaJordan

25Ex12SSAProgramOperationsManagementSystem(POMS)RM10210.505,SSAHandbook1705Proofofage,

1725ProofofU.S.citizenship



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stipulates that they require an original birth certificate or a U.S. hospital record of your birth

(created at the time of birth).

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24. To establish identity27

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and the authenticity29

of documents, the SSA cross checks the data

tied to a persons SSN to information from their birth certificate, and visa versa, which has been

placed on the SSA Numident file. Program Operation Management System (POMS) GN

00203.020 Identity of Claimants, 2. Establishing the identity of the claimant, The purpose of the

identification of the claimant is to establish that he or she is the person alleged. Verify the

claimants identity by confirming the information on the Numident. Obtain the following

information using open-ended questions: claimants name (What is your name?). Social

Security Number (SSN) (What is your social security number?). (Emphasis added)

25. Plaintiff read an Affidavit by Private Investigator Susan Daniels who provided credible

evidence that the SSN Candidate Obama is using was never issued to him. This would make

verification of data on Obamas original birth certificate, using his SSN through the SSA

process, which is also used by Homeland Security, problematic.30

26. Alvin T. Onaka, the Hawaii Vital Records Registrar, who did not or could not verify the data

on Obamas long form Certificate of Live Birth31

, acknowledged the importance of

authenticating birth certificates in order to verify the age of Little League baseball players,

[Onaka] said he is also working with passport offices and even the Little League Association

26Ex13SSAPOMSGN00302.530,GN00302.057

27Ex14SSAPOMSRM10210.270,GN00203.020

28Ex15POMSRM10210.210

29Ex16SSAPOMSRM10210.260

30Ex17PlaintiffattainedanAffidavitfromSusanDaniels

31Ex18HawaiiVerificationofBirth,May22,2012



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on a systemto verify birth certificates of the players to prove they are in the right age

brackets.

32

(Emphasis added)

27. The SSA and Immigration and Naturalization Service (INS) rely on two fundamental

principles in order to establish citizenship status: jus soli, or right of birthplace, and jus

sanguineous, or right of blood (deriving citizenship through parents citizenship).33

An original

birth certificate is needed in any attempt to prove jus soli or jus sanguineous.

Candidate Obama Acknowledged the Importance Of An Original Birth Certificate In

Order To Establish Citizenship Status and Eligibility As A Presidential Candidate

28. In 2008 Obama made public his purported birth certificate, a short form computer generated

Certification of Live Birth from Hawaii (posted again on the White House Website 4/27/11)34

29. On April 27, 2011 Candidate Obama held a press conference wherein he and White House

General Counsel Bob Bauer detailed how two certified photocopies of Obamas original 1961

long form Certificate of Live Birth35

were attained from the Hawaii Department of Health

(Hawaii DOH) and then one of them was posted on the White House website.36

37

The Press

Conference was covered by the national media.38

30. The motivation expressed at the Press Conference by Obama and Bauer, for revealing what

they said was Obamas original 1961, long form Certificate of Live Birth, was to assure the

American public, including our Secretary of State, that Obama has an authentic original birth

32Ex19StarBulletin,Statreportingearnshonor:AlvinOnakaguidesstatevitalstatistics,July14,2008

33Ex20SSAandINScitizenshipcriteria

34Ex21ObamapurportedShortformCertificationofLiveBirthposted2008andApril27,2011

35Ex22ObamapurportedlongformCertificateofLiveBirthpostedApril27,2011

36Ex23ObamaApril27,2011PressStatement

37Ex24BauerApril27,2011WhiteHousePressGaggleQuestions/Answers

38Ex25LasVegasSun(4/27/11),StarAdvertiser(4/27/11),WestHawaiiToday(4/27/11)



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certificate that confirms his age, Hawaiian birth place, and citizenship status proving that he is

eligible to be a Presidential candidate. (Ex 23) (Ex 24)

31. The Seattle Times reported that since 2008 Obama continued to face repeated questions

about the controversy surrounding his birth place and had grown incredulous over it. The

decision to release the original birth certificate now, not one, two or three years earlier, was the

result of Obamas impatience at people who kept questioning his nativity story.39

32. This motivation, to prove Obamas citizenship status, birth place and eligibility, by releasing

the original birth certificate, was reiterated in January 2012 by Georgia attorney Michael

Jablonski representing Obama in David Farrar v. Barack Obama. In his Motion To Quash

Subpoenas Jablonski writes, The President made the documents [birth certificates] available

to the general public by placing it on his website.the President took the extraordinary step of

acquiring a copy of the record of birth, informally known as the long form, making it

available to anyone who cares to check the [White House] website.the birth certificates

[Obama] made available to the public prove citizenship.40

(Emphasis added)

33. At the April 27th, 2011 Press Conference Obama specifically addressed the concerns the

public still had about his eligibility, As many of you have been briefed, we provided additional

information today about the site of my birth. Now this situation [allegations about Obamas

citizenship status and birth certificate] has been going on for two, two and a half years nowWe

do not have time for this kind of silliness. (Ex 23)

34. These facts demonstrated to Plaintiff that Obama showed a sufficiency of intention to use the

Certificate of Live Birth, posted on the White House Website on April 27, 2011, as proof to

39Ex26SeattleTimesBirthcertificate:WhyNow?ObamadecidedenoughwasenoughApril28,2011

40Ex27JablonskiMotiontoQuashpg.12OSAHSECSTATECE121513660MALIHI



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every elector and every Secretary of State, of his citizenship status, age and eligibility to be a

candidate for President of the United States.

35. Plaintiff took Obama up on his invitation to view said document. The document Plaintiff

viewed and researched is integral to and explicitly relied upon in this complaint.

The Presumption of Truth The Secretary Initially Affords Candidates Has Been

Undermined Concerning Candidate Obamas Eligibility

36. Plaintiff researched Hawaii law concerning vital records that requires signatures on original

birth certificates to be made in permanent ink.41

Hawaii Public Health Regulations Title: Vital

Statistics, Registration & Records. Chapter 8, Certificates of Vital Statistics Events, Section 1.

Preparation. Certificates of vital statistics events are to be filled in by typewriter or in ink. If ink

is used only permanent ink will be acceptable.All signatures are to be made with permanent

ink. In all other respects, the certificates shall comply with provisions of Section 57-14, R.L.H.

1955.42

(Emphasis added) Like most people today it has been standard practice for many

years for Plaintiff to buy software, learn about it and use it successfully. The software and

computer lexicon is not foreign to me. Using my computer I looked at the signature of Obamas

mother on the Certificate of Live Birth, posted on the White House website on April 27th, 2011,

and saw that it goes from pixels that are consistent with ink to non-ink pixels one letter to the

next. The pixels in the 'Ann' and the 'D' in Dunham are consistent with ink written penmanship.

But, right next to it, the unham and Obama have no visible pixilation, revealing that this part

of the signature was computer created andis not even penmanship. It did not take a trained

41Ex28HawaiiInkReportbyLindaJordan

42Ex29HawaiilawonBCsignatures/ink



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eye to see this anomaly.43 Plaintiff concluded, based on research of Hawaii Vital Records

procedures and law, that it was not possible for an authentic signature, on an original 1961

Certificate of Live Birth, to be a compilation of what appears to be a partial ink signature and a

confirmed computer created non-ink signature. A scan of an original ink signature, as

signatures were required to be in ink by Hawaii law in 1961 and today, would have pixels

consistent with ink pixels throughout the entire signature. This lack of consistency revealed that

the signature was a compilation, a forged signature which renders the entire document

fraudulent.

37. The inconsistency of the pixels that Plaintiff saw in this report, the fact that the birth

certificate was a PDF file and not a scanned photocopy, along with other anomalies noted by

software expert Mara Zebest44

confirmed to Plaintiff that the entire document was completely

manufactured in the computer and never originally existed in paper form.

38. On March 1 and July 17, 2012 Sheriff Joe Arpaio from the Maricopa County Sheriff

Department held a press conference wherein he made public the results of a law enforcement

investigation in to the authenticity of the document posted on the White House Website

purporting to be a photocopy of Obamas original 1961 Certificate of Live Birth. His

investigators concluded that the document, released by the White House on April 27th, 2011,

was a computer-created and generated forgery that never existed in paper form. I watched the

Press Conferences and found the reports by investigators, document and software experts,

detailing elements of the forgery, to be credible.45

43ER702

44Ex30PlaintiffattainedanAffidavitandReportfromsoftwareexpertMaraZebest.

45Ex31SheriffArpaioReports:Confirmed,ObamaBCForged



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39. Plaintiff wrote letters to Candidate Obama and the Secretary informing them that the identity

document Obama is using to prove eligibility was forged.

46

40. Plaintiff read a March 27th, 2012 decision by the Alabama Supreme Court wherein Justice

Tom Parker, In re: Hugh McInnish v. Beth Chapman, 1110665 wrote that , McInnish has

attached certain documentation to his mandamus petition, which, if presented to the appropriate

forum as part of a proper evidentiary presentation, would raise serious questions about the

authenticity of both the short form and the long form birth certificates of President Barack

Hussein Obama that have been made public. McInnish had attached the March 1, 2012 report

from the Maricopa County Sheriffs Department.47

Social Security Administration Guidelines For Detecting Forged Documents

41. The SSA has developed guidelines for detecting fraudulent documents.48

When SSA

employees examine a document they are to be alert for, Entries that have apparently been

altered; Entries that were apparently added at a later date (shown by use of a different

typewriter, ink, and/or handwriting); SSA employees are instructed to, Compare the

document with a valid one. and look to see if; The printed copy is evenly centered on the paper;

The size and style of type are uniform; The item numbers are in consecutive order with none

missing; If the subsection is lettered with a capital letter, all other subsections will have capital

letters; The print is clear and clean, not smudged; The lines of print are even and regular; The

dates are consistent.

42. Arpaios investigation confirmed that when the SSA criteria for identifying forged

documents was applied to the long form birth certificate Obama revealed on April 27, 2011, the

46Ex32LettersfromJordantoObamaandSOS

47Ex33SupremeCourtJusticeTomParker:SeriousquestionsaboutObamabirthcertificates,McInnish

48Ex34SSAPOMSRM10210.210,10210.205,00302.530,SSAHandbook1703Evaluatingevidence



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document did not pass muster. The size and style of type are not uniform, the lines of print are

not even and regular and there are obvious signs of erasure or cut and paste inserts. Sheriff

investigators found entries on the document that were altered; they found entries that were added

at a later date where they could clearly identify that a different typewriter, ink, and/or

handwriting was inserted. All signs of forgery according to the SSA.

43. In 1961, the purported year of Obamas birth, original long form Hawaiian birth certificates

were not created in a computer or generated by a computer. Hawaii DOH did not begin

producing computerized vital records until 2001. In an April 27th, 2011 Press Release,

announcing that Hawaii DOH had granted Obamas request to get photocopies of his original

birth certificate, the Governor of Hawaii, Neil Abercrombie, stated that Hawaii began issuing

computer generated vital records in 2001. He reveals that a computer generated short form

Certification of Live Birth and a photocopy of an original birth certificate are different

documents. In 2001, the Hawaii State Department of Healthbegan computer-generating vital

statistic records. Since then, its longstanding policy and practice has been to issue and provide

only computer-generated Certifications of Live Birth, and tonot produce photocopies of actual

records to fulfill requests for certified copies of certificates.

249

250

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252

49(Emphasis added) A Memo was

included in the Press Release from the Director of the Hawaii DOH, dated May 15, 2001, which

stated that, ...the Department of Health will henceforth issue and provideonly computer

generated abstracts of birth and marriage records andcease to produce photocopies of actual

records to satisfy requests for certified copies of certificates

253

254

255

50 (Emphasis added)

49Ex35HawaiiAbercrombiePressReleaseApril27,2011

50Ex36HawaiiDOHDirectorMay15,2001statement



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Obama Waivered

44. This fact, that Hawaii DOH no longer gave out photocopies of original vital records, was

important to Plaintiff because in April 2011 Obama and his personal lawyer, Judith Corley,51

asked Hawaii DOH to grant him a waiver in order to get what they had quit giving out:

photocopies of original birth certificates. And Hawaii granted that waiver.52

Corely flew to

Hawaii to pick them up.53

That a PDF file54

was posted on the White House Website, not a

scanned photocopy, confirmed to Plaintiff it was not what Obama asked for or what he says he

received.

45. White House General Counsel Bob Bauer explained at the April 27th 2011 press conference

that, Theres a difference betweena certificate and acertification. The certification is simply a

verification of certain information thats on the original birth certificate. (Emphasis added) (Ex

24 pg.10) and regarding the short form Certification of Live Birth, thats acomputer

generated document, which we posted in 2008, that information is abstracted, if you will, from

the original birth certificate, (Emphasis added) (Ex 24, pg. 10-11)

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47. Understanding that the White House had received photocopies of the purported birth

certificate a reporter asks, Q And this is going to sound -- I mean, you can just anticipate what

people are going to -- remain unconvinced. Theyre going to say that this isjust a photocopy of

a piece of paper, (Emphasis added) (Ex 24 p.13)

51Ex37OnApril22,2011ObamaandhispersonallawyerJudithCorleywroteletterstotheDirectoroftheHawaii

DOH,LorettaFuddy,askingforawaiverinordertogetcopiesofObamasoriginal1961longformCertificateof

LiveBirthinsteadoftheshortformCertificationofLiveBirth,acomputercreatedandgenerateddocument.52Ex38HawaiiDOHlettertoObamagrantingwaiver.

53Ex24WhiteHousePressGagglep22

54Ex22WhiteHousesannouncestheypostedaPDFfileofObamaslongformbirthcertificate.



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48. Software expert Mara Zebest notes in her report (Ex 30) that on the Certificate of Live Birth

in question the Hawaii date and registrar stamp, intended to validate the authenticity of the

document, were layered on to the document and can be completely lifted off and independently

moved around. the ability to remove or reposition the stamp authenticatorsrenders the

entire document as fraudulent and manufactured.(Emphasis added)

49. Plaintiff viewed a Verification of Birth55 for Barack Obama provided by the Hawaii DOH

to Arizona Secretary of State Ken Bennett at his request. Plaintiff made a Freedom of

Information Act request to Bennett for all communication between his office and Hawaii DOH

concerning the requested verification.56

Bennett had asked Hawaii to, verify the attached copy

of the Certificate of Live Birth for Mr. Obama is a true and accurate representation of the

original record in your files.57

Hawaii responded that, the information in the copy of the

Certificate of Live Birth for Mr. Obama matched the original record but did not verify that the

appearance of the document itself matched the original record. The Hawaii DOH also would not

verify that Obama was born in Hawaii stating instead that, A birth certificate is on file with the

Department of Health indicating that Barack Hussein Obama II was born in Honolulu, Hawaii.

(Emphasis added) Indicating is not a verification. This Verification of Birth was not signed by

the Hawaii Registrar, Alvin T Onaka, but by someone with the initials gk.

Best Evidence

55Ex18HawaiiMay2012VerificationofBirth

56Ex39JordanFOIAtoSOSBennett

57Ex40SOSBennettLettertoHawaiiDOH



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50. When the authenticity of an original birth certificate is called in to question SSA employees

are instructed to ask applicants to request a copy of their original birth certificate if it is available

and would not be a hardship to get.58

51. The standard described by the SSA is supported by Evidence Rule ER1003 and ER1004.59

The Best Evidence Rule, embodied in FRE 1002, on its express terms, requires the original

writing, recording, or photograph to be introduced when offered to prove the content of a

writing, recording, or photograph.

Allegedly, It Would Not Be A Hardship For Candidate Obama To Get His Original 1961

Long Form Certificate of Live Birth60

52. The Hawaii DOH has stated that they retain possession of Obamas original 1961 Certificate

of Live Birth and that they do not get rid of original birth records. We dont destroy vital

records, Health Department spokeswoman Janice Okubo said. Thats our whole job, to

maintain and retain vital records. And We have back ups of our back ups.61

Obama says he

just got copies of the original in April 2011. Accordingly, Hawaii can produce what they say is

Obamas original Certificate of Live Birth in the original paper form and microfiche for forensic

comparison to the one posted on the White House Website, to the paper photocopies Obama says

his personal lawyer, Judith Corley, picked up from the Hawaii DOH62

and to their own May

2012 verification.

58Ex41SSAPOMSGN00301.015,SSAHandbook1702Evidencetobesubmitted.

59ER1003GenuineQuestionRaisedAboutOriginal,ER1004OtherEvidenceOnlyIfOriginalNotAvailable

60ER1004(a)(b)Originalrequiredunless

61Ex42HawaiiOkubostatement,retainingObamaBCrecords

62Ex24WhiteHouseGagglep.



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53. By inviting Plaintiff to view and come to a conclusion about his original 1961 birth

certificate, Candidate Obama has conferred a level of expertise to Plaintiff concerning said

document.

Closing

54. Plaintiff has presented substantial evidence that the purported original, 1961 long form

Certificate of Live Birth, for Candidate Barack Obama, posted on the White House Website on

April 27, 2011, is a forgery.

55. Plaintiff has demonstrated that Candidate Obama, whether involved in the forgery or not, has

presented this forged document with the express intent to use it as an offer of proof, to every

elector in Washington State and to our Secretary of State, that he is an eligible Presidential

Candidate.

56. Plaintiff alleges, with sufficient certainty, that the posting of this alleged original birth

document to the White House Website and the ensuing Press Conference, on April 27th, 2011,

was fraud, the false representation of a document and the continued concealment of what should

have been disclosedObamas original long-form Certificate of Live Birth, if it indeed exists.

The related crime of uttering a forged document has also occurred because someone posted an

inauthentic identity document with the intent to pawn it off as a genuine scanned photocopy of

Obamas original 1961 Certificate of Live Birth.

57. A forged document can not prove eligibility and the introduction of this forgery, by

Candidate Obama, undermines the presumption of truth the Secretary affords candidates. For this

reason Obamas name should be kept off the 2012 General Election ballot as a candidate for

president.



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58. After reviewing the law and SOS procedures Plaintiff concluded that the Secretary has a duty

to uniformly carry out federal elections and to create uniform forms and procedures. The

Secretary instructs Write-In Candidates for President and Vice President to sign an Eligibility

Oath and instructs them, before they sign the oath, You must ensure that you meet all

qualifications of the office.

59. The Secretary has certified Candidate Obamas name for the ballot without instructing him to

meet the qualifications and without receiving a signed eligibility oath.

60. The Secretary is violating WAC 434-215-165 by certifying the names of major party

Presidential and Vice Presidential Candidates for the General Election ballot without receiving a

Certificate of Nomination63

64

and a list of electors from said party resulting from their

nomination process.

Signed_____________________________________, Seattle Washington.

Linda Jordan

Date___________________________________.

Notary Signature ____________________________________.

Date___________________________________.

63Ex2SOSAppearingonthePresidentialBallot,2012

64Ex43KingCountyCandidateGuide2012



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Exhibit & Citation Index: Linda Jordan v. Secretary of State, Sam Reed

Jordan Affidavit

Exhibit & Citation List Page/Line in Affidavit

1. Ex 1 Voter Registration pg.1 L20

2. Rule ER 602 Personal Knowledge pg. 1 L20

3. RCW 29A.68.011 (1)(3) pg. 2 L29

4. Rule ER 401,601,904,902 pg. 2 L31

5. RCW 29A.56 RCW 29A.04.067 pg. 2 L34

6. Ex 2 pg. 2 L38

Appearing on the Presidential Ballot in Washington State pg. 4

(http://www.sos.wa.gov/_assets/elections/Appearing-on-the-Presidential-

ballot.pdf)

7. WAC 434-215-170 pg. 3 L39

8. Ex 3 SOS Write In candidate form for President pg.3 L40

(http://www.sos.wa.gov/_assets/elections/Presidential%20Write-in%20form.pdf)

9. Ex 4 Convention Schedule pg. 3 L45

10. RCW 29A.56.030 pg. 3 L52

11. Ex 2 Pg.4 pg. 3 L53

12. RCW 29A.68.011 (1)(3) pg. 3 L57

13. Ex 5 SOS Primary Election Certification pg. 4 L58

14. Ex 6 Email from SOS to Linda Jordan pg. 4 L62

Ballots can be printed as early as August 24, 2012

15. SOS website, over 3 million voters pg. 4 L63

http://www.sos.wa.gov/_assets/elections/Appearing-on-the-Presidential-ballot.pdfhttp://www.sos.wa.gov/_assets/elections/Presidential%20Write-in%20form.pdfhttp://www.sos.wa.gov/_assets/elections/Presidential%20Write-in%20form.pdfhttp://www.sos.wa.gov/_assets/elections/Presidential%20Write-in%20form.pdfhttp://www.sos.wa.gov/_assets/elections/Presidential%20Write-in%20form.pdfhttp://www.sos.wa.gov/_assets/elections/Appearing-on-the-Presidential-ballot.pdfhttp://www.sos.wa.gov/_assets/elections/Appearing-on-the-Presidential-ballot.pdfhttp://www.sos.wa.gov/_assets/elections/Appearing-on-the-Presidential-ballot.pdfhttp://www.sos.wa.gov/_assets/elections/Appearing-on-the-Presidential-ballot.pdfhttp://www.sos.wa.gov/_assets/elections/Appearing-on-the-Presidential-ballot.pdfhttp://www.sos.wa.gov/_assets/elections/Appearing-on-the-Presidential-ballot.pdfhttp://www.sos.wa.gov/_assets/elections/Appearing-on-the-Presidential-ballot.pdfhttp://www.sos.wa.gov/_assets/elections/Appearing-on-the-Presidential-ballot.pdf


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Linda Jordan Affidavit: Exhibit & Citation List Page/Line in Affidavit

http://www.sos.wa.gov/elections/vrdb/VRDBFaq.aspx

16. RCW 29A.68.011(1)(3) pg. 4 L65

17. RCW29A.68.011 pg. 4 L68

18. Ex 7 U.S. Constitution Article II Section 1 Clause 5 pg. 4 L76

19. Ex 8 SOS Description of Elected Offices/Eligibility pg. 5 L79

http://www.sos.wa.gov/_assets/elections/Office_Descriptions.pdf

http://www.sos.wa.gov/office/search.aspx?query=description+of+presidential+qualifications

20. WAC 434-215-170 pg. 5 L83

21. RCW 29.A.04.611 pg. 5 L89

22. Ex 9 SOS Devised Form for Write In Presidential pg. 5 L95

Candidates

http://www.sos.wa.gov/_assets/elections/Presidential%20Write-in%20form.pdf

23. Ex 10 Washington State Constitution/Oath pg. 6 L98

24. Ex 9 SOS Devised Form for Write In Pres. Candidate pg. 6 L103

25. Ex 11 Email From SOS Elections to Linda Jordan pg. 6 L108

Write In Candidate Form Not Valid Without Eligibility Oath

26. Ex 12 SSA POMS RM 10210.505 pg. 6 L114

Birth Certificate needed to prove citizenship status/age (Program Operation

Management System POMS)

https://secure.ssa.gov/poms.nsf/lnx/0110210505

SSA Handbook, 1705 Proof of age,1725 Proof of citizenship

http://www.sos.wa.gov/_assets/elections/Office_Descriptions.pdfhttp://www.sos.wa.gov/_assets/elections/Office_Descriptions.pdfhttp://www.sos.wa.gov/office/search.aspx?query=description+of+presidential+qualificationshttps://secure.ssa.gov/poms.nsf/lnx/0110210505https://secure.ssa.gov/poms.nsf/lnx/0110210505https://secure.ssa.gov/poms.nsf/lnx/0110210505https://secure.ssa.gov/poms.nsf/lnx/0110210505http://www.sos.wa.gov/_assets/elections/Presidential%20Write-in%20form.pdfhttp://www.sos.wa.gov/_assets/elections/Presidential%20Write-in%20form.pdfhttp://www.sos.wa.gov/_assets/elections/Presidential%20Write-in%20form.pdfhttp://www.sos.wa.gov/_assets/elections/Presidential%20Write-in%20form.pdfhttp://www.sos.wa.gov/office/search.aspx?query=description+of+presidential+qualificationshttp://www.sos.wa.gov/office/search.aspx?query=description+of+presidential+qualificationshttp://www.sos.wa.gov/office/search.aspx?query=description+of+presidential+qualificationshttp://www.sos.wa.gov/office/search.aspx?query=description+of+presidential+qualificationshttp://www.sos.wa.gov/office/search.aspx?query=description+of+presidential+qualificationshttp://www.sos.wa.gov/office/search.aspx?query=description+of+presidential+qualificationshttp://www.sos.wa.gov/office/search.aspx?query=description+of+presidential+qualificationshttp://www.sos.wa.gov/office/search.aspx?query=description+of+presidential+qualificationshttp://www.sos.wa.gov/_assets/elections/Office_Descriptions.pdfhttp://www.sos.wa.gov/_assets/elections/Office_Descriptions.pdfhttp://www.sos.wa.gov/_assets/elections/Office_Descriptions.pdfhttp://www.sos.wa.gov/_assets/elections/Office_Descriptions.pdfhttp://www.sos.wa.gov/elections/vrdb/VRDBFaq.aspxhttp://www.sos.wa.gov/elections/vrdb/VRDBFaq.aspxhttp://www.sos.wa.gov/elections/vrdb/VRDBFaq.aspxhttp://www.sos.wa.gov/elections/vrdb/VRDBFaq.aspx


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http://www.ssa.gov/OP_Home/handbook/handbook.17/handbook-1705.html


27. Ex 13 SSA says Birth Certificate Primary and Preferred pg. 7 L118

Level evidence of age/citizenship status. POMS GN 00302.530


POMS GN 00302.057 https://secure.ssa.gov/poms.nsf/lnx/0200302057

28. Ex 14 (26) SSA POMS RM 10210.270, GN 00203.020 pg. 7 L119

29. Ex 15 (27) SSA POMS RM 10210.210 pg. 7 L119

30. Ex 16 (28) SSA POMS RM 10210.260 pg. 7 L119

31. Ex 17 Susan Daniels Affidavit pg. 7 L130

32. Ex 18 Hawaii DOH BC Verification pg. 7 L132

33. Ex 19 Hawaii Article on Onaka reviewing pg. 8 L136

Little League Birth Certificates for age.

http://archives.starbulletin.com/2008/07/14/news/story07.html

34. Ex20 SSA INS Citizenship SSA POMS 10210.500 pg. 8 L139


34. Ex 21 Obama purported Short form pg. 8 L144

Certification of Live Birth posted 2008 and April 27, 2011.http://www.whitehouse.gov/sites/default/files/rss_viewer/birth-certificate.pdf

35. Ex 22 White House Blog Long Form BC released. pg 8 L147

http://www.whitehouse.gov/blog/2011/04/27/president-obamas-long-form-birth-

certificate

http://www.ssa.gov/OP_Home/handbook/handbook.17/handbook-1705.htmlhttps://secure.ssa.gov/poms.nsf/lnx/0200302530https://secure.ssa.gov/poms.nsf/lnx/0200302530https://secure.ssa.gov/poms.nsf/lnx/0200302057http://archives.starbulletin.com/2008/07/14/news/story07.htmlhttp://www.whitehouse.gov/sites/default/files/rss_viewer/birth-certificate.pdfhttp://www.whitehouse.gov/blog/2011/04/27/president-obamas-long-form-birth-certificatehttp://www.whitehouse.gov/blog/2011/04/27/president-obamas-long-form-birth-certificatehttp://www.whitehouse.gov/blog/2011/04/27/president-obamas-long-form-birth-certificatehttp://www.whitehouse.gov/blog/2011/04/27/president-obamas-long-form-birth-certificatehttp://www.whitehouse.gov/blog/2011/04/27/president-obamas-long-form-birth-certificatehttp://www.whitehouse.gov/blog/2011/04/27/president-obamas-long-form-birth-certificatehttp://www.whitehouse.gov/blog/2011/04/27/president-obamas-long-form-birth-certificatehttp://www.whitehouse.gov/blog/2011/04/27/president-obamas-long-form-birth-certificatehttp://www.whitehouse.gov/sites/default/files/rss_viewer/birth-certificate.pdfhttp://www.whitehouse.gov/sites/default/files/rss_viewer/birth-certificate.pdfhttp://www.whitehouse.gov/sites/default/files/rss_viewer/birth-certificate.pdfhttp://www.whitehouse.gov/sites/default/files/rss_viewer/birth-certificate.pdfhttp://archives.starbulletin.com/2008/07/14/news/story07.htmlhttp://archives.starbulletin.com/2008/07/14/news/story07.htmlhttp://archives.starbulletin.com/2008/07/14/news/story07.htmlhttp://archives.starbulletin.com/2008/07/14/news/story07.htmlhttps://secure.ssa.gov/poms.nsf/lnx/0200302057https://secure.ssa.gov/poms.nsf/lnx/0200302057https://secure.ssa.gov/poms.nsf/lnx/0200302057https://secure.ssa.gov/poms.nsf/lnx/0200302057https://secure.ssa.gov/poms.nsf/lnx/0200302530https://secure.ssa.gov/poms.nsf/lnx/0200302530https://secure.ssa.gov/poms.nsf/lnx/0200302530https://secure.ssa.gov/poms.nsf/lnx/0200302530http://www.ssa.gov/OP_Home/handbook/handbook.17/handbook-1705.htmlhttp://www.ssa.gov/OP_Home/handbook/handbook.17/handbook-1705.htmlhttp://www.ssa.gov/OP_Home/handbook/handbook.17/handbook-1705.htmlhttp://www.ssa.gov/OP_Home/handbook/handbook.17/handbook-1705.html


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36. Ex 23 Obama April 27, 2011 Press Statement pg. 8 L148


http://www.whitehouse.gov/the-press-office/2011/04/27/remarks-president

37. Ex 24 White House General Counsel/Press Gaggle pg. 8 L148

http://www.whitehouse.gov/the-press-office/2011/04/27/press-gaggle-press-

secretary-jay-carney-4272011

38. Ex25 News coverage of Press Conference pg. 8 L149

White House Press Conference

39. Obama Press Statement/Bauer Press Gaggle pg.9 L154

(Ex 22 and Ex 23)

40. Ex 26 Seattle Times article, Why now? pg. 9 L158

41. Ex 27 Obama attorney Jablonski pg. 9 L166

Obama releases BC to prove citizenship.

Jablonski Motion to Quash pg.1-2 OSAH-SECSTATE-CE-1215136-60-MALIHI

42. Obama press statement. pg. 9 L171

(Ex 22)

43. Ex 28 Hawaii Ink Report by Linda Jordan pg. 10 L181

Signature of Obamas Mother forged.

44. Ex 29 Hawaii law signatures on BC pg. 10 L186

must be made in ink.Hawaii Public Health Regulations, Chapter 8http://gen.doh.hawaii.gov/sites/har/AdmRules1/8%208A%20B%20VR%20Admin

%20Rules.pdf

45. ER 702

http://www.whitehouse.gov/the-press-office/2011/04/27/press-gaggle-press-secretary-jay-carney-4272011http://gen.doh.hawaii.gov/sites/har/AdmRules1/8%208A%20B%20VR%20Admin%20Rules.pdfhttp://gen.doh.hawaii.gov/sites/har/AdmRules1/8%208A%20B%20VR%20Admin%20Rules.pdfhttp://gen.doh.hawaii.gov/sites/har/AdmRules1/8%208A%20B%20VR%20Admin%20Rules.pdfhttp://gen.doh.hawaii.gov/sites/har/AdmRules1/8%208A%20B%20VR%20Admin%20Rules.pdfhttp://gen.doh.hawaii.gov/sites/har/AdmRules1/8%208A%20B%20VR%20Admin%20Rules.pdfhttp://gen.doh.hawaii.gov/sites/har/AdmRules1/8%208A%20B%20VR%20Admin%20Rules.pdfhttp://gen.doh.hawaii.gov/sites/har/AdmRules1/8%208A%20B%20VR%20Admin%20Rules.pdfhttp://gen.doh.hawaii.gov/sites/har/AdmRules1/8%208A%20B%20VR%20Admin%20Rules.pdfhttp://gen.doh.hawaii.gov/sites/har/AdmRules1/8%208A%20B%20VR%20Admin%20Rules.pdfhttp://www.whitehouse.gov/the-press-office/2011/04/27/press-gaggle-press-secretary-jay-carney-4272011http://www.whitehouse.gov/the-press-office/2011/04/27/press-gaggle-press-secretary-jay-carney-4272011http://www.whitehouse.gov/the-press-office/2011/04/27/press-gaggle-press-secretary-jay-carney-4272011http://www.whitehouse.gov/the-press-office/2011/04/27/press-gaggle-press-secretary-jay-carney-4272011http://www.whitehouse.gov/the-press-office/2011/04/27/press-gaggle-press-secretary-jay-carney-4272011http://www.whitehouse.gov/the-press-office/2011/04/27/press-gaggle-press-secretary-jay-carney-4272011http://www.whitehouse.gov/the-press-office/2011/04/27/press-gaggle-press-secretary-jay-carney-4272011http://www.whitehouse.gov/the-press-office/2011/04/27/press-gaggle-press-secretary-jay-carney-4272011http://www.whitehouse.gov/the-press-office/2011/04/27/remarks-presidenthttp://www.whitehouse.gov/the-press-office/2011/04/27/remarks-presidenthttp://www.whitehouse.gov/the-press-office/2011/04/27/remarks-presidenthttp://www.whitehouse.gov/the-press-office/2011/04/27/remarks-president


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46. Ex 30 Software expert Mara Zebest Affidavit pg. 11 L204

45. Ex 31, 32 March 1, 2012 and July 17, 2012 pg. 11 L213


Press Release and Results of Sheriff Arpaio investigation.

http://www.mcso.org/MultiMedia/PressRelease/Sheriffreleasesobamafindings.pdf

http://www.mcso.org/MultiMedia/PressRelease/Birth%20Certificate%20Investigat

ion%20Part%20II.pdf

46. Ex 33, Alabama Supreme Court Justice pg. 12 L222

Tom Parker, Serious questions raised about both Obama BCs

47. Ex 34 SSA POMS RM 10210.210 pg. 12 L224

Reviewing age, identity, citizenship.


RM 10210.205

Policy for reviewing and verifying evidence for SSN


RM 00302.530

Hospital birth records.


SSA Handbook. 1703 Evaluating evidence.


48. Ex 35 Hawaii Governor Press Release pg. 13 L250

Obama given photocopies of original BC

http://www.mcso.org/MultiMedia/PressRelease/Birth%20Certificate%20Investigation%20Part%20II.pdfhttp://www.mcso.org/MultiMedia/PressRelease/Birth%20Certificate%20Investigation%20Part%20II.pdfhttps://secure.ssa.gov/poms.nsf/lnx/0110210210https://secure.ssa.gov/poms.nsf/lnx/0110210205https://secure.ssa.gov/poms.nsf/lnx/0200302530https://secure.ssa.gov/poms.nsf/lnx/0200302530https://secure.ssa.gov/poms.nsf/lnx/0200302530https://secure.ssa.gov/poms.nsf/lnx/0200302530https://secure.ssa.gov/poms.nsf/lnx/0200302530https://secure.ssa.gov/poms.nsf/lnx/0110210205https://secure.ssa.gov/poms.nsf/lnx/0110210205https://secure.ssa.gov/poms.nsf/lnx/0110210205https://secure.ssa.gov/poms.nsf/lnx/0110210205https://secure.ssa.gov/poms.nsf/lnx/0110210210https://secure.ssa.gov/poms.nsf/lnx/0110210210https://secure.ssa.gov/poms.nsf/lnx/0110210210https://secure.ssa.gov/poms.nsf/lnx/0110210210http://www.mcso.org/MultiMedia/PressRelease/Birth%20Certificate%20Investigation%20Part%20II.pdfhttp://www.mcso.org/MultiMedia/PressRelease/Birth%20Certificate%20Investigation%20Part%20II.pdfhttp://www.mcso.org/MultiMedia/PressRelease/Birth%20Certificate%20Investigation%20Part%20II.pdfhttp://www.mcso.org/MultiMedia/PressRelease/Birth%20Certificate%20Investigation%20Part%20II.pdfhttp://www.mcso.org/MultiMedia/PressRelease/Birth%20Certificate%20Investigation%20Part%20II.pdfhttp://www.mcso.org/MultiMedia/PressRelease/Birth%20Certificate%20Investigation%20Part%20II.pdfhttp://www.mcso.org/MultiMedia/PressRelease/Birth%20Certificate%20Investigation%20Part%20II.pdfhttp://www.mcso.org/MultiMedia/PressRelease/Birth%20Certificate%20Investigation%20Part%20II.pdf


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(http://hawaii.gov/gov/newsroom/press-releases/hawaii-health-department-grants-

president-obamas-request-for-certified-copies-of-long-form-birth-certificate

49. Ex 36 2001 Hawaii DOH Memo pg. 13 L254


No more photocopies just computer generated BC

http://hawaii.gov/gov/newsroom/press-releases/hawaii-health-department-grants-

president-obamas-request-for-certified-copies-of-long-form-birth-certificate

50. Ex 37 Letter to Fuddy from Obama, and lawyer wants original BC

pg. 13 L258

http://www.whitehouse.gov/sites/default/files/rss_viewer/birth-certificate-

correspondence.pdf

51. Ex 38 Fuddy letter to Obama pg. 14 L260

Yes you can have copies of original BC

(http://hawaii.gov/health/vital-records/obama.html)

http://www.whitehouse.gov/sites/default/files/rss_viewer/birth-certificate-

correspondence.pdf

53. Ex 24 pg. 8, 10, 11 Bauer Press Gaggle explains pg. 14 L265-269

difference between Certification and Certificate, Obama lawyer got copies of BC

54. Ex 24 Press asks question about photocopy of BC pg. 15 L273

55. Ex 30 Mara Zebest Affidavit, Onaka authenticating pg. 15 L278

Stamp can be independently moved on Obama BC, renders BC fraudulent.

56. Ex 39 Hawaii Verification of Birth pg. 15 L279

57. Ex 40 Jordan FOIA letter to SOS Bennett pg. 15 L282


http://hawaii.gov/gov/newsroom/press-releases/hawaii-health-department-grants-president-obamas-request-for-certified-copies-of-long-form-birth-certificatehttp://www.whitehouse.gov/sites/default/files/rss_viewer/birth-certificate-correspondence.pdfhttp://www.whitehouse.gov/sites/default/files/rss_viewer/birth-certificate-correspondence.pdfhttp://www.whitehouse.gov/sites/default/files/rss_viewer/birth-certificate-correspondence.pdfhttp://www.whitehouse.gov/sites/default/files/rss_viewer/birth-certificate-correspondence.pdfhttp://www.whitehouse.gov/sites/default/files/rss_viewer/birth-certificate-correspondence.pdfhttp://www.whitehouse.gov/sites/default/files/rss_viewer/birth-certificate-correspondence.pdfhttp://www.whitehouse.gov/sites/default/files/rss_viewer/birth-certificate-correspondence.pdfhttp://www.whitehouse.gov/sites/default/files/rss_viewer/birth-certificate-correspondence.pdfhttp://www.whitehouse.gov/sites/default/files/rss_viewer/birth-certificate-correspondence.pdfhttp://hawaii.gov/gov/newsroom/press-releases/hawaii-health-department-grants-president-obamas-request-for-certified-copies-of-long-form-birth-certificatehttp://hawaii.gov/gov/newsroom/press-releases/hawaii-health-department-grants-president-obamas-request-for-certified-copies-of-long-form-birth-certificatehttp://hawaii.gov/gov/newsroom/press-releases/hawaii-health-department-grants-president-obamas-request-for-certified-copies-of-long-form-birth-certificatehttp://hawaii.gov/gov/newsroom/press-releases/hawaii-health-department-grants-president-obamas-request-for-certified-copies-of-long-form-birth-certificatehttp://hawaii.gov/gov/newsroom/press-releases/hawaii-health-department-grants-president-obamas-request-for-certified-copies-of-long-form-birth-certificatehttp://hawaii.gov/gov/newsroom/press-releases/hawaii-health-department-grants-president-obamas-request-for-certified-copies-of-long-form-birth-certificatehttp://hawaii.gov/gov/newsroom/press-releases/hawaii-health-department-grants-president-obamas-request-for-certified-copies-of-long-form-birth-certificatehttp://hawaii.gov/gov/newsroom/press-releases/hawaii-health-department-grants-president-obamas-request-for-certified-copies-of-long-form-birth-certificate


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58. Ex 41 Bennett letter to Hawaii DOH pg. 15 L284

59. Ex 42 SSA POMS Section: GN 00301.015 pg. 16 L294

Best evidence, original document

https://secure.ssa.gov/poms.nsf/lnx/0200301015,

SSA Handbook 1702 Evidence to be submitted


60. ER 1003 Genuine Question raised about original, pg. 16 L295

ER 1004 Other Evidence only if original not available pg. 16 L300

61. Ex 43 Hawaii News Hawaii DOH retains Obama original BC pg. 16 L304

(http://www.msnbc.msn.com/id/42519951/ns/politics-more_politics/t/ex-hawaii-

official-denounces-ludicrous-birther-claims/#.TwyMkqVIrKg)

http://www.usatoday.com/news/nation/2009-07-27-obama-hawaii_N.htm

62. Ex44 King County 2012 Candidate Manuel pg. 18 L341

http://your.kingcounty.gov/elections/candidate/pdfs/candidate-manual.pdf

63. Ex 2 SOS Appearing on the Presidential Ballot pg. 18 L341

http://www.msnbc.msn.com/id/42519951/ns/politics-more_politics/t/ex-hawaii-official-denounces-ludicrous-birther-claims/#.TwyMkqVIrKghttp://www.msnbc.msn.com/id/42519951/ns/politics-more_politics/t/ex-hawaii-official-denounces-ludicrous-birther-claims/#.TwyMkqVIrKghttp://www.msnbc.msn.com/id/42519951/ns/politics-more_politics/t/ex-hawaii-official-denounces-ludicrous-birther-claims/#.TwyMkqVIrKghttp://www.msnbc.msn.com/id/42519951/ns/politics-more_politics/t/ex-hawaii-official-denounces-ludicrous-birther-claims/#.TwyMkqVIrKghttp://www.msnbc.msn.com/id/42519951/ns/politics-more_politics/t/ex-hawaii-official-denounces-ludicrous-birther-claims/#.TwyMkqVIrKghttp://www.msnbc.msn.com/id/42519951/ns/politics-more_politics/t/ex-hawaii-official-denounces-ludicrous-birther-claims/#.TwyMkqVIrKghttp://www.msnbc.msn.com/id/42519951/ns/politics-more_politics/t/ex-hawaii-official-denounces-ludicrous-birther-claims/#.TwyMkqVIrKghttp://www.msnbc.msn.com/id/42519951/ns/politics-more_politics/t/ex-hawaii-official-denounces-ludicrous-birther-claims/#.TwyMkqVIrKghttp://www.msnbc.msn.com/id/42519951/ns/politics-more_politics/t/ex-hawaii-official-denounces-ludicrous-birther-claims/#.TwyMkqVIrKghttp://www.msnbc.msn.com/id/42519951/ns/politics-more_politics/t/ex-hawaii-official-denounces-ludicrous-birther-claims/#.TwyMkqVIrKghttps://secure.ssa.gov/poms.nsf/lnx/0200301015https://secure.ssa.gov/poms.nsf/lnx/0200301015https://secure.ssa.gov/poms.nsf/lnx/0200301015https://secure.ssa.gov/poms.nsf/lnx/0200301015


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PLAINTIFFSMOTIONFORORDERTOSHOW LINDAJORDAN,PLAINTIFFPROSE


MEMORANDUMANDAPPENDIXOFLAW 1OF10


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x Expedite

Nohearingset

XHearingisset

Date:September7,20129:00AM

Judge/Calendar:LisaSutton

IN THE SUPERIOR COURT OF THE STATE OF WASHINGTON

FOR THURSTON COUNTY

Linda Jordan ) No. 12-2-01763-5

Plaintiff ) MEMORANDUM AND APPENDIX OF LAW

v. ) IN SUPPORT OF PLAINTIFFS

Secretary of State Sam Reed ) MOTION FOR ORDER TO SHOW CAUSE

Defendant )

______________________________________________________________________________

1. Courts Affirm That Electors Have A Legitimate Interest In The Integrity Of Elections

The Supreme Court has noted that public confidence in the integrity of the electoral process has

independent significance, [aside from the State interest to prevent voter fraud] because it

encourages citizen participation in the democratic process.1

The Supreme Court has

recognized the right to vote as a judicially cognizable interest.2

1Crawford,ETALv.MarionCountyEtAl,553U.S.2008,p.13

2See,e.g.,Reynoldsv.Sims,377U.S.533,544(1964))



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MEMORANDUMANDAPPENDIXOFLAW 2OF10


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The Anderson Court concluded that presidential selection procedures implicate a uniquely

important national interest because the President and the Vice-President of the United States

are the only elected officials who represent all the voters in the Nation. 3

From the Anderson case; "Nevertheless, as we have recognized,the rights of voters and the

rights of candidates do not lend themselves to neat separation; laws that affect candidates

always have at least some theoretical, correlative effect on voters."4

The Jimmy Carter Commission on the integrity of elections concluded in part that, "The

electoral system cannot inspire public confidence if no safeguards exist to deter or detect fraud

or to confirm the identity of voters."5

Confirming the identity and citizenship status of candidates is of equal importance.

The Supreme Court has long recognized that, "as a practical matter, there must be a substantial

regulation of elections if they are to be fair and honest and if some sort of order, rather than

chaos, is to accompany the democratic process."6

2. The Court Has Found That Eligibility Requirements Are Legal

In Dumas v. Gagner the Court found that States can restrict candidates by requiring they meet

eligibility qualifications.7 The Court also noted that, Statutory provisions relating to conduct of

an election, such as requirements for notice, have been held to be directory onlyBut provisions

3

CNCL

of

Alternative

v.

Hooks

No.

98

5256

(Citing

Anderson,

460

U.S.

at

794)

4Bullockv.Carter,405U.S.134,405U.S.143(1972)

5Ex1BuildingConfidenceinU.S.ElectionsReportoftheCommissiononFederalElectionReformSeptember2005

6Burdick,504U.S.at433(quotingStorer,415U.S.at730).

7Statutoryprovisionsregardingqualificationsofcandidates,suchasaresidencerequirement,directlyand

substantivelyaffectanelecti

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