orly taitz filing 04-27-2010

8/9/2019 orly taitz filing 04-27-2010

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Taitz v Obama. Motion for reconsideration, motion for leave of court to file second amended

complaint 1

Dr. Orly Taitz, esq.29839 Santa Margarita Parkway, STE 100Rancho Santa Margarita CA 92688Tel: (949) 683-5411; Fax (949) 766-7603

E-Mail:[email protected]

UNITED STATES DISTRICT COURTFOR THE DISTRICT OF COLUMBIA

Dr. ORLY TAITZ, ESQ, PRO SE Plaintiff, HONORABLE ROYCE LAMBERTH

PRESIDINGv. Civil Action: 10-151 RCL

MOTION FORBarack Hussein Obama, RECONSIDERATION

MOTION FOR LEAVE OF COURT

TO FILE A SECOND AMENDED COMPLAINT WITH PRESIDENTIAL CANDIDATE AND VICE PRESIDENTIAL

Defendant. CANDIDATE ON THE BALLOT

IN 2008 ELECTION AS

ADDITIONAL PLAINTIFFS

MOTION: REQUEST TO FORWARD TO THE ATTORNEY GENERAL ERIC

HOLDER REQUEST FOR APPOINTMENT OF A SPECIAL PROSECUTOR TOINVESTIGATE AND PROSECUTE MULTIPLE ACTS OF SOCIAL SECURITY

FRAUD, PERJURY, IDENTITY THEFT, FRAUD AND OTHER POSSIBLE

FELONIES PERPETRATED BY MR. BARACK HUSSEIN OBAMA.

ORAL ARGUMENT REQUESTED AS MATTERS OF LAW AND FACT

ARE AT ISSUE

YOUR HONOR,

Plaintiff would like to start this motion for reconsideration with reference to your

remark in your latest order regarding Plaintiffs quixotic quest.

Case 1:10-cv-00151-RCL Document 25 Filed 04/27/10 Page 1 of 8
mailto:[email protected]:[email protected]:[email protected]:[email protected]


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complaint 2

Yes, Taitz would agree that it is extremely difficult to be a person, an attorney,

who brings forward evidence, showing that the sitting president of the United States

is committing multiple felonies and needs to be criminally prosecuted, however ifYour Honor will be so kind to review some historic events, Your Honor will see that

some events considered quixotic at a time, were correct, just and successful in the

long run.

When Susan B. Anthony undertook a cause of voting rights for women, many

laughed and considered her quest to be quixotic, yet she succeeded and we see today

a first female Speaker of the House, female Presidential and Vice Presidential

candidates and female senators and congresswomen as a direct result of her quixotic

quest.

When a young woman by name Golda Meir set on her quest to build a Jewish

state after six million Jews were killed in the Holocaust, many considered her actions

quixotic, yet she succeeded and became the mother of the state of Israel.

When Margaret Thatcher and Ronald Reagan set on the quest to defeat the

Communist Soviet Union, many considered them as Don Quixote and Sancho Panza,

yet they succeeded, and the iron curtain was lifted, the Berlin Wall fell and free

people marched through the Brandenburg gate.

Today it might seem an impossible quest, but Taitz is fighting to make sure that

the Constitution of the United States of America does not turn into a Dulcinea, who

is never rescued by her Prince in Shining Armor.

Plaintiff wants to make sure, that she, as well as three hundred and five millionAmerican citizens are not treated as brain-dead robots, as a herd of sheep by Barack

Hussein Obama who went through life with multiple Social Security numbers, who

is sitting in the White House today using the Social Security number 042-68-4425

(which was assigned in the state of Connecticut to another individual born in 1890),



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complaint 3

who never provided any vital records that would be admitted in any court of law, and

who does not even possess a valid long form birth certificate with the name of a

doctor, name of a hospital and signatures; who has allegiance to three other Nationsand god knows who else. Plaintiff is not asking your Honor to tilt windmills, but

rather uphold the US Constitution, that your Honor took an oath to protect.

Motion: Request to Forward to the Attorney General Eric Holder for

appointment of a special prosecutor to investigate and prosecute multiple acts of

Social Security Fraud, Perjury, Identity Theft, Fraud and other possible

felonies perpetrated by Mr. Barack Hussein Obama.

On 12/21/94, when your Honor reviewed evidence presented and found that Mr.

Ira Magaziner has committed perjury, your honor contacted Eric Holder, prosecutor

at that time, and asked him to start an investigation of Mr. Magaziner for perjury and

criminal contempt. Your honor also asked Attorney General Janet Reno to appoint an

independent counsel to investigate the affair. According to the US Constitution,

nobody is above the law. Millions of American citizens are following this case, as

are Millions around the World. Even if your Honor does not find injuries sustained

by the Plaintiff to be sufficient and the connection to Barack Hussein Obama to be

strong enough, your Honor clearly has seen evidence of numerous felonies

committed by Barack Hussein Obama:

1.Social Security Fraud 42 USC 408 (a)(7)(B), which is punishable under title18 with up to 5 years in prison for each offense (Investigator Sankey shows

some 39 different Social security numbers used);

2. Conspiracy to defraud the United States 18 USC 371, which carries up to five

years in prison for each offense;



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complaint 4

3. Perjury 18 USC 1621 with up to five years in prison for each offense

There are other crimes committed such as elections fraud, voter fraud, identity

theft, that any other US citizen would have been convicted of and serving a lengthyprison term for the above crimes. Plaintiff is asking your Honor for equal treatment

of the law for Mr. Obama, just as your Honor has treated other parties and any other

citizen, and to forward the request to the US Attorneys Office and Attorney General

Eric Holder for appointment of a special prosecutor to investigate multiple felonies

perpetrated by Mr. Obama.

Motion for leave of court to file a second amended complaint with two

additional plaintiffs: Presidential candidate from American Independent Party

on the 2008 ballot Ambassador Dr. Alan Keyes, and Vice Presidential

Candidate on the ballot in 2008 election Gail Lightfoot.

Motion for reconsideration is allowed when there is an error of fact or law. While

typically Quo Warranto is utilized by interested parties, who challenge the franchise

of the government, 16-3502, does not specifically limit quo warranto to such

parties, whereby Your Honor is not statutorily precluded from granting Taitz Quo

Warranto.

16-3502. Parties who may institute; ex rel. proceedings.

The Attorney General of the United States or the United States attorney may

institute a proceeding pursuant to this subchapter on his own motion or on the

relation of a third person. The writ may not be issued on the relation of a third

person except by leave of the court, to be applied for by the relator, by a petition

duly verified setting forth the grounds of the application

http://www.michie.com/dc/lpext.dll/dccode/7978/8058/8904/8906/890d?f=templates&fn=document-frame.htm&2.0#JD_16-3502http://www.michie.com/dc/lpext.dll/dccode/7978/8058/8904/8906/890d?f=templates&fn=document-frame.htm&2.0#JD_16-3502http://www.michie.com/dc/lpext.dll/dccode/7978/8058/8904/8906/890d?f=templates&fn=document-frame.htm&2.0#JD_16-3502


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complaint 5

As an attorney for plaintiffs, Keyes, Lightfoot and others, Taitz has submitted

Quo Warranto requests to the Attorney General and US Attorney, who have not

responded. Therefore, Taitz is asking for leave of the Court to proceed under QuoWarranto, and in case your Honor does not grant Quo Warranto to the Plaintiff, she

moves for Leave of Court to file a Second Amended Complaint with two additional

plaintiffs: Presidential candidate from American Independent Party in 2008 election

Ambassador Dr. Alan Keyes, as well as Gail Lightfoot, a Vice Presidential candidate

for a write in Presidential Candidate Ron Paul.

Additionally, Ambassador Keyes was a senatorial candidate in the state of

Illinois. Plaintiff previously submitted to this Court the March 25th Official report of

the National Assembly of Kenya. Page 31 of the report contains a statement of the

minister of Lands James Orengo, clearly indicating Mr. Obama was born in Kenya,

and there is no evidence of Mr. Obama going through proper immigration procedures

after his birth. As such, not only is Mr. Obamas Natural Born status in question, but

his citizenship in general is in question, and whereby, Ambassador Keyes has

suffered particularized damage in losing both the senatorial and presidential elections

to one who is not entitled to hold office, which indicates clear standing.

Motion for this Honorable court to grant Plaintiff sua sponte admission to

US District Court bar without local attorney movant.

Typically, admission to this court requires a sponsor/movant local attorney or alocal counsel for pro Hac Vice. Due to the sense of fear associated with a legal

action, implicating a sitting president, the damage by slander and libel of Taitz has

chilled the opportunity to secure a local attorney as a pro Hac Vice movant; however

Your Honor can authorize her acceptance to the court Sua Sponte without such pro



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complaint 6

hac vice movant. She requests Sua Sponte authorization of acceptance to this bar in

order to represent above mentioned additional plaintiffs and opportunity to file a

Second Amended Complaint on their behalf.Commerce Clause claims

Your Honor has stated that the First Amended Complaint was filed prior to

Patient Protection Act being signed into law, which signifies lack of standing.

However, standing exists not only in relation to current injury; it exists in relation to

imminent injury as well. Taitz has filed her First Amended complaint after the bill

was approved by both houses of Congress and the injury was imminent, which

suffice for standing. In the alternative Taitz is seeking a leave of Court to file a

Second amended Complaint based on Amended Patient Protection Act, since the

original act was modified through the process of reconciliation in Senate and House

of Representatives, wherefore making any complaint in regards to the initial Patient

Protection Act, moot.

FOIA relief

Your Honor has stated that the FOIA complaint has failed since Taitz did not wait

until April 9th for the administrative remedies to be exhausted. As there was no

response to the FOIA request by April 9 th and none was received by today, April

26th, Taitz is moving this Honorable court for a leave of court to file a Second

Amended Complaint for FOIA relief, due to the fact that by today, April 26 th

administrative remedies were exhausted and no relief was provided.

Fraud and RICO claims

Similarly, Taitz is seeking a leave of court to file a second amended complaint on

these causes of action, more fully pleading reliance and damages based on 10th, 9th,



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complaint 7

5th and 1st amendment with reference to the pattern of multiple crimes with more

than two predicate acts of the enterprise, as well as more fully plead standing on the

issues of fraud in relation to her Taxpayer standing and her Whistleblower status.

/s/ DR ORLY TAITZ ESQBy:__________________________________Dr. Orly Taitz, Esq. (California Bar 223433)

Attorney for the Plaintiffs29839 Santa Margarita Parkway ste 100Rancho Santa Margarita CA 92688Tel.: 949-683-5411; Fax: 949-766-7603E-Mail:[email protected]

PROOF OF SERVICE

mailto:[email protected]:[email protected]:[email protected]:[email protected]


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complaint 8

I CERTIFY THAT TRUE AND CORRECT COPY OF THE ABOVE

PLEADINGS WAS SERVED on 04.26.10. on

Alan Burch, Assistant United States Attorney for the District of Columbia555 4

thStreet, N.W.

Washington D.C. 20530

/s/Orly Taitz

Dr. Orly Taitz Esq.29839 Santa Margarita PKWYRancho Santa Margarita CA 92688


orly taitz filing 04-27-2010

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