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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
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Taitz v Obama. Motion for reconsideration, motion for leave of court to file second amended
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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Taitz v Obama. Motion for reconsideration, motion for leave of court to file second amended
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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Taitz v Obama. Motion for reconsideration, motion for leave of court to file second amended
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
Case 1:10-cv-00151-RCL Document 25 Filed 04/27/10 Page 4 of 8
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_16-35028/9/2019 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 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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Taitz v Obama. Motion for reconsideration, motion for leave of court to file second amended
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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Taitz v Obama. Motion for reconsideration, motion for leave of court to file second amended
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
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Taitz v Obama. Motion for reconsideration, motion for leave of court to file second amended
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
Case 1:10-cv-00151-RCL Document 25 Filed 04/27/10 Page 8 of 8
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