Taitz et al v Democratic Party of MS, Secretary of State of MS

Dr. Orly Taitz, ESQ.
29839 Santa Margarita Parkway, Ste. 100
Rancho Santa Margarita, CA 92688
Ph 949-683-s41 I F949-7 66-7 603
Orlr.'l'aitzra gmail,com
CA Bar License 223433
In propria Persona in MS
                                                                      FIRST JUDICIAL DISTRICT
                                                                       Circuit Clerk's Oflice
                                                                            P.O. BOX327
                                                                            Jackson, MS 39205
                                                                         Phone: (601) 968-6628
DR. ORLY TAITZ, ESQ
BRIAN FEDORKA
LATruE  ROTH
LEAH    LAX
TOM  MacLERAN
V
DEMOCRAT PARTY OF MISSISSPPI, ) presiding
SECRETARY OF STATE OF MISSISSIPPI )
) FIRST AMENDED COMPLAINT
)PETITION FOR AN EMERGENCY
) INJUNCTION FROM GENERAI
)ELECTION, PERMANENT
) INJUNCTION, DECLARATORY
) RELIEF, TREBLE DAMAGES IN
) Rrco
) Hon R Kenneth Coleman
) CASE#2012-107
)
)
)
)
)
)
BARACK HUSSEIN OBAMA
OBAMAFORAMERICA
NANCI PELOSI
DR. ALVINONAKA
LORETTA FUDDY
MICHAEL ASTRUE
JANE DOES, JOHN DOES 1-1OO
Taitz et al v Democratic Party of MS, Secretary of State of MS
COME NOW PLAINTIFFS Dr. Orly Taitz ESQ, Brian Fedorka, Laurie Roth,
Leah Lax, Tom Macleran, hereinafter Plaintiffs and seek following relief
DECLARATORY RELIEF- declaring candidate for the U.S. Presidency Barack
Obama not eligible to be on the ballot as a President due to lack of constitutional
eligibility, not being a natural bom citizen, fraudulently using forged identification
papers as a basis of his eligibility.
INJUNCTM RELIEF, seeking an injunction against placing Obama's name on
the ballot in the general election and an order de-certifring any and all votes for
Obama in the primary election due to the fact that Obama was not eligible and
commiffed elections fraud by using a forged birth certificate, forged selective
service certificate and a stolen Social Security number as a basis for his natural
bom status.'
TREBLE DAMAGES in RICO for damages suffered by the Plaintiffs
PARTIES
l. Dr. Orly Taitz, ESQ, political dissident leader of an opposition movement
against Barack Obama. Taitz was named by the media either the "leader of the
birther movement" or a "queen of the birthers" due to her leadership position in
bringing forward explosive evidence, showing Obama committing elections fraud
and using a computer generated forgery instead of a valid long form birth
certificate, as well as his fraudulent use of a Connecticut social Security number
Taitz et al v Democratic Party of MS, Secretary of State of MS
042-68-4425, which was not assigned to obama. Taitz was severely persecuted for
her opposition dissident legal work and civil rights work in restoring the rights of
the u.S. citizens to lawful elections and removal of obama from the ballot, as well
as criminal prosecution of Obama.
2. Brian Fedorka- citizen of the state of Mississippi and a registered legal voter in
Mississippi.
3. Leah Lax- a Democrat running for the U.S. presidency, registered with the FEC
as a Presidential candidate
3. Laurie Roth- a Presidential candidate fiom American Independent parfy,
registered with the FEC
4. Tom Maclaren,- a Presidential candidate from Republicalparty,registered with
the FEC
5. Barack Hussein obama, candidate for the U.S. president in 2012 elections,
hereinafter "Obama"
6. "obama for America"- official Presidential campaign organization for Barack
Hussein Obama
7. Secretary of state of Mississippi is sued only in his official capacity as the chief
elections officer of the state of Mississippi and he is sued only as a respondent in
relation to the declaratory relief and injunctive relief in seeking his action in his
official capacity of the Secretary of State to remove candidate obama from the
Taitz et al v Democratic Party of MS, Secretary of State of MS
ballot in the general 2012 Presidential election and in de-certiSing any and all
votes for obama fraudulently received by obama in the primary 2012 presidential
election. Secretary of State is NOT being sued in RICO causes of action.
8. Democratic Party of Mississippi- sued in its capacity of a political party, which
submitted candidacy of Barack obama and which maintained such candidacy in
spite of evidence of lack of eligibility of obama and evidence of election fraud and
use of forged documents by Obama
9.Loretta Fuddy -director ofthe Department of Health of the state of Hawaii
10 Alvin onaka-Registrar ofthe Department of Health ofthe state of Hawaii
11. Michael Astrue -Commissioner of the Social Security
12. Nanci Pelosi-chair of the 2008 Presidential nominating convention, signatory
on the certificate of candidate of Barack Obama
13. Jane Does, John Does 1-100 Plaintiffs believe that Defendants Jane Does and
John Does aided and abetted Obama in elections fraud, forgery, uttering of forged
identification papers, harassment, intimidation, defamation, persecution of plaintiff
Taitz and her family. Names of Jane Does and John Does are not fully known at
this time and will be ascertained upon completion of the discovery.
JURISDICTION AND APPLICABLE LAW
RICO
Chapter 96 of Title 18 of the United States Code, 18 U.S.C. g 1961-1968
Taitz et al v Democratic Party of MS, Secretary of State of MS
PREDICATE ACTS
section 1028 (relating to fraud and related activity in connection with identification
documents),
section 1341 (relating to mail fraud),
section 1343 (relatingto wire fraud),
section 1425 (relating to the procurement of citizenship or nationalization
unlawfully), section 1426 (relating to the reproduction of naturalization or
citizenship papers
section 1503 (relating to obstruction ofjustice),
section 7512 (relating to tampering with a witness, victim, or an informant),
section l5l3 (relating to retaliating against a witress, victim, or an informant),
section
section 1546 (relating to fraud and misuse of visas, permits, and other documents)
Mississippi code of 1972 as amended
Chapter 021 of Title9T
97-21-5. Certain instruments deemed writings.
SEC. 97-21-5. Certain instruments
deemed writings.
Every instrument, partly written and
partly printed, or wholly printed, with a
written signature thereto, and every
signature of an individual, firm, or
Taitz et al v Democratic Party of MS, Secretary of State of MS 5
97-21-21.
97-21-27.
97-21-31.
corporate body, or of any officer of such
body, and every writing purporting to be
such signature, shall be deemed a
writing and a written instrument within
the meaning of the provisions of this
chapter.
Destruction, erasure, or obliteration of
writing deemed forgery.
Intent to defraud.
SF,,C.97-21-27. Intent to defraud.
Whenever, by any of the provisions of
this chapter, an intent to defraud is
required to constitute a forgery, it shall
be sufficient if such intent appear to
defraud the United States, any state or
territory, and body-corporate, county,
city, town, or village, or any public
officer in his official capacity, any
copartnership, or any one of such
partners, or any real person whatever.
Parts of several genuine instruments
connected to make one instrument.
SEC. 97-21-31. Parts of several
genuine instruments connected to
make one instrument.
When different parts of several genuine
instruments shall be so placed or
connected together as to produce one
instrument, with intent to defraud, the
same shall be forgery, in the same
Taitz et al v Democratic Party of MS, Secretary of State of MS 6
97-21-33.
manner as if the parts so put together
were falsely made or forged.
Penalty for forgery.
SEC. 97-2f-33. Penalty for forgery.
Persons convicted of forgery shall be
punished by imprisonment in the
Penitentiary for a term of not less than
two (2) years nor more than ten (10)
years, or by a fine ofnot more than Ten
Thousand Dollars ($10.000.00). or both:
provided, however, that when the
amount of value involved is less than
Five Hundred Dollars ($500.00) in lieu
of the punishment above provided for,
the person convicted may be punished
by imprisonment in the county jail for a
term of not more than six (6) months, or
by a fine of not more than One
Thousand Dollars ($1.000.00). or both.
within the discre tion of the court.
SEC. 97-21-35. Pleadings, process
and other court papers, licenses, or
written instruments generally.
Every person who, with the intent to
injure or defraud, shall falsely make,
alter, forge, or counterfeit any
instrument or writing being or
purporting to be any process issued by
any competent court, magistrate, or
officer, or being or purporting to be any
pleading or proceeding filed or entered
in any court of law or equity, or being or
purporting to be any certihcate, order, or
allowance, by any competent court,
T aitz et al v Democratic Party of MS, Secretary of State of MS
board, or officer, or being or purporting
to be any license o. by autt ority authorized any. statute, o. uny- in'r,**ar, o.
X'i'::q-::'*'o' Pu'Po*i"g io u" tt'" u"t
*,"#!!?,;9,i!*[T :X",1?" ffiffiH to be-.created, increased, dis.hurg"d, o. diminished, or by which *y .igh, o. properfy whatever shall be or purport to be transferred,. co.rr.yeJ, discharged,
$;Ti','*"t,,"Jffr_,+ffi [:tr:Ht
;;;ulterfeiting any p..io, may bi
n" *i3;X"":X1#[::n.il?Jffiif forgery. :X
97-21-63. SEC.97_2I_63. Wiil, deed,Will, .deed, certificare of certificate of acknowtedgment or ;;#;;k";*redgment or proof of recordabre of recordable instrument. instrument.
fhvaevrinyg p erson who shall be convicted of forged, counterfeited, o. iul;"i, altered any will of ,.ul o.-p.ioii
ll_9fny, or any deed or other insirument,
oerng oI purporting to be the act of another by which any right or interest in rear or personal property shall be or purport to be transferred, conveyed, or in
c:yen,:r1ttcya tec hoanrg eedn door rsaeffmecetendt ; oi unf of th;
olie$e"oY or* got.heern ints toruf maennyt person of any which by law
n9a1v1e f b ereenco mraaedd,e mbayd e or purporting to any officer Julv autnonzed to make such certificate o'r endorsement; or any certificate of the plo.ol of any deed or other instrument
which by law may be recorded, made oi
Taitz et al v Democratic parfy of MS, Secretary of State of MS
purporting to have been made by any
officer duly authorized to make such
certificate, with intent to defraud, shall be
guilty of forgery.
23-15.963. EXCLUSIVE PROCEDT]RES FOR CONTESTING
QUALIFICATIONS OF CAI\IDIDATE FOR GENERALELECTION;
EXCEPTIONS.
(1) Any person desiring to contest the qualifications of another person who has
qualified pursuant to the provisions of Section 23-15-359, Mississippi Code of
1972, as a candidate for any office elected at a general election, shall file a petition
specifically setting forth the grounds of the challenge not later than thirty-one (31)
days after the date of the first primary election set forth in Section 23-15-191,
Mississippi Code of 1972. Such petition shall be filed with the same body with
whom the candidate in question qualified pursuant to Section 23-15-359,
Mississippi Code of 1972.
(2) Within ten (10) days of receipt of the petition described above, the appropriate
election officials shall meet and rule upon the petition. At least two (2) days before
the hearing to consider the petition, the appropriate election officials shall give
Taitz et al v Democratic Party of MS, Secretary of State of MS
notice to both the petitioner and the contested candidate ofthe time and place of
the hearing on the petition. Each party shall be given an opportunity to be heard at
such meeting and present evidence in support ofhis position.
(3) If the appropriate election officials fail to rule upon the petition within the time
required above, such inaction shall be interpreted as a denial of the request for
reliefcontained in the petition.
MISSTSSPPT ELECTTONS CODE 23-t5-961, ELECTIONS CIIALLENGE
(5) upon the filing of the petition and bond, the circuit clerk shall immediately, by
registered letter or by telegraph or by telephone, or personally, notifi, the Chief
Justice of the Supreme Court, or in his absence, or disability, some other judge of
the Supreme court, who shall forthwith designate and notifu from the list provided
in Section 23-15-951 a circuit judge or chancellor of a district other than that
which embraces the district, sub district, county or any ofthe counties, involved in
the contest or complaint, to proceed to the county in which the contest or complaint
has been filed to hear and determine the contest or complaint. It shall be the
official duty of the circuit judge or chancellor to proceed to the discharge of the
designated duty at the earliest possible date to be fixed by the judge or chancellor
and of which the contestant and contestee shall have reasonable notice. The
contestant and contestee are to be served in a reasonable mtrnner as the judge or
Taitz et aI v Democratic Party of MS, Secretary of State of MS l0
chancellor may direct, in response to which notice the contestee shall promptly file
his answer, and also his cross-complaint if he has a cross-complaint. The hearing
before the circuit court shall be de novo. The matter shall be tried to the circuit
judge, without a jury. After hearing the evidence, the circuit judge shall determine
whether the candidate whose qualifications have been challenged is legally
qualified to have his name placed upon the ballot in question. The circuit judge
may, upon disqualification of any such candidate, order that such candidate shall
bear the court costs ofthe proceedings.
(6) Within three (3) days after judgment is rendered by the circuit court, the
contestant or contestee, or both, may file an appeal in the Supreme Court upon
election contest
2) Within ten (10) days of receipt of the petition described above, the appropriate
executive committee shall meet and rule upon the petition. At least two (2) days
before the hearing to consider the petition, the appropriate executive committee
shall give notice to both the petitioner and the contested candidate ofthe time and
place ofthe hearing on the petition. Each parry shall be given an opportunity to be
heard at such meeting and present evidence in support ofhis position.
(3) If the appropriate executive committee fails to rule upon the petition within the
time required above, such inaction shall be interpreted as a denial ofthe request for
reliefcontained in the petition.
Taitz et al v Democratic Party of MS, Secretary of State of MS ll
(a) Any party aggrieved by the action or inaction of the appropriate executive
committee may file a petition for judicial review to the circuit court of the county
in which the executive committee whose decision is being reviewed sits. Such
petition must be filed no later than fifteen (15) days after the date the petition was
originally filed with the appropriate executive committee.
STATEMENT OF FACTS AND ALLEGATIONS RELEVANT TO ALL
CAUSES OF ACTION
l.On April 27 , 20ll Defendant Obama held a press conference in the White House
and presented what he alleged to be a true and correct copy of his original long
form birth certificate. Obama used his position of the U.S. President and a
Presidential candidate for the 2012 election to viciously attack "birthers" , civil
rights attomeys and patriots, questioning legitimacy of his eligibility for the U.S.
Presidency and questioning authenticity of his alleged identification papers, by
calling them "a side show and camival barkers". Taitz was named by the media a
"queen of the birthers" and a leader of the birther movement. Upon the verbal
attack by Obama she was subjected to a wave of attacks, which included
defamation, slander of her character, harassment, persecutions. Obama never
presented to any court of law or any elections commission any valid original
identification papers or any valid certified copies, which can be used to veriff the
originals. As an emperor without clothes, Obama, a usuryer without identification
Taitz et al v Democratic Party of MS, Secretary of State of MS 12
papers is continuing to reside in the white House and is continuing his bid to be a
candidate inthe 2012 primary and general elections.
From 2008 campaigr until now Taitz and other plaintiffs and patriots of this
country suffered a total of nearly four years of humiliation, defamation, slander,
persecutions, harassment, sanctions, tampering with vehicles, attacks on their
families by some of the defendants, by the "[Jsurper in chief and his knights of the
crooked table. "
2. On March 1,31,2012 sheriff Joe Arpaio of Maricopa County, Arizona held a
press conference, where he announced to the public results of his six months
investigation and testing of obama's alleged copy of his birth certificate and other
papers. Arpaio and his lead investigator Michael Zullo announced that the
document presented by obama during April 27,2011 press conference represents
a computer generated forgery. @xhibit 2 Transcript of March l, 2012 press
conference by Sheriff Joe Arpaio and affidavit of authenticity and Exhibit 3 Video
tape ofthe Press conference by SheriffJoe Arpaio and investigator Zullo)
Arpaio and, Zullo announced that the stamp of the registrar Alvin Onaka and of the
date stamp on Obama's alleged copy of his alleged birth certificate were
transported to this computer generated forgery from other documents. They also
announced that the security paper was not a part of the document, but was rather
added to this computer generated document later, leaving a halo, which is
Taitz et al v Democratic Party of MS, Secretary of State of MS 13
indicative of forgery. These findings by Arpaio confirmed findings by several
experts, who worked with Taitz.
3. Plaintiff Taitz provided Defendant Democratic party of Mississipi, hereinafter
"Party" with the evidence of forgery and fraud in obama's identification papers.
Plaintiff raitz served the Democratic party with the elections challenge against
candidate Barack Obama. (Exhibits 4-12)
2. challenge provided swom affidavits from multiple experts showing obama
using a forged birth certificate and a stolen connecticut Social Security number
042-68-4425. (Exhibits 1 - 12)
3. In order to be a legitimate candidate for the US presidency according to Article
2, section 1 of the uS constitution one needs to be a natural born uS citizen.
4. Since Obama is using forged identification papers, he does not have any
credentials to be a legitimate candidate.
5Additionally Taitz provided the Democratic party with precedents showing that
meaning of natural born citizen as intended in the uS constitution, is one bom in
the country to two uS citizen parents. since obama's father was a foreign national,
even if Obama were to have a valid U.S. birth certificate, he would have been a
foreign national from birth based on his father's citizenship.
6. Democratic Party of Mississippi did not respond and de facto became criminally
complicit in elections fraud and use of forged identification papers by Obama
Taitz et al v Democratic Party of MS, Secretary of State of MS 14
7 - Taitz filed a complaint in Hinds county circuit court in Jackson MS
8. Pursuant to 23-15-961 of MS code, this complaint, being an elections ballot
challenge, was immediately forwarded to the chief Justice ofthe Supreme court of
MS for expedient handling.
9. chief Justice Dickenson immediately forwarded the complaint to special judge
Honorable R. Kenneth Coleman.
10. Primary election was held on March 13th prior to judge coleman contacting
the parties, therefore it became necessary to provide the party with a new challenge
relating to the general election and bringing this complaint at hand
13. Other Plaintiffs joined Taitz.
14. Through their attomey, samuel Bagley, Democratic party was contacted and
advised that since the court did not hear the complaint before the primary election,
plaintiffs are asking for the response of the Democratic party in regards to the
same challenge for the general election
15. Yet again the Democratic Party did not respond
16. Since neither party filed an answer to the complaint, the first Amended
Complaint was filed as of right.
FIRST CAUSE OF ACTION
DECLARATORY RELIEF
Taitz et al v Democratic Party of MS, Secretary of State of MS 15
l. In 2008, when Mr. Obama ran for the U.S. Presidency, he was never vetted and
he never provided any valid documentary evidence of his natural bom status.
2. A natural bom citizen would be expected to have valid U.S.
identification papers, such as a valid long form birth certificate and a valid Social
Security number, which was lawfully obtained by presenting a valid birth
certificate to the Social Security administration and which can be verified through
ofEcial U.S. Social Security verification services, such as E-Verifu and SSNVS.
The most glaring evidence of Obama's lack of natural bom status and legitimacy
for the US Presidency, is Obama's lack of most basic valid identification papers,
such as a valid Social Security Number (-SSN) and his use of a fraudulently
obtained Social Security Number from the state of Connecticut, a state where he
never resided, and which was never assigned to him according in part to SSN
verification systems "E-Veriff" and SSNVS.
3. Reports from licensed investigator Susan Daniels ("Daniels") show
that for most of his life Obama used a Connecticut Social Security Number 042-
68-4425 issued in 1977, even though he was never a resident of the State of
Connecticut. In 1977 Social Security numbers were assigned according to the state
where the Social Security applications were submitted. ln 1977 Obama was
nowhere near Connecticut, but rather a young student at the Punahoa school in
Hawaii, where he resided.
Taitz et al v Democratic Party of MS, Secretary of State of MS l6
3. Additionally, according to the review performed by licensed
investigators Sankey and Daniels, and as publicly available, national databases
revealed another birth date associated with this number, a birth date of 1890. In or
around 1976-77, due to changes in the Social Security Administration, many
elderly individuals who never had Social Security numbers before, had to apply for
their Social Security numbers for the first time in order to obtain Social Security
Benefits. It appears that the number in question was assigned to an elderly
individual in Connecticut around March of 1977. The death of this elderly
individual was never reported, and from around 1980 this number was fraudulently
assumed by Barack Obama. See Exhibit 7 attached hereto, Affidavit of Susan
Daniels.
4. Petitioner Taitz was a delegate at the Continental Congress
Convention in 2009, where she had a discussion on the matter of Barack Obama's
fraudulent use of the aforementioned Connecticut SSN with a recently retired
Senior Deportation Officer from the Department of Homeland Security ("DHS"),
Mr. John Sampson ("Sampson"). Sampson provided Dr. Taitz with an affidavit
attesting to the fact that indeed, according to national databases, Obama is using a
Connecticut SSN even though there is no reasonable justification or explanation
for such use by one who resided in Hawaii in and around the time the Social
Taitz et al v Democratic Party of MS, Secretary of State of MS t7
Security number in question was issued. see Exhibit 8 attached hereto, Affidavit of
John Sampson.
5. In 2010 Obama posted online on WhiteHouse.gov his 2009 tax
retums. Those responsible for posting those retums did not "flatten" the PDF file
thereof, so all the layers of modification of the file became visible to the public.
One of the pages contained Obama's fulI SSN 042-68-4425. Taitz received an
affidavit from Adobe Illustrator program expert Mr. Felicito Papa ("Papa")
attesting to the fact that the tax retums initially posted by Obama contained the
Connecticut SSN 042-68-4425. While the file was later "flattened" and the SSN
can no longer be seen, thousands of U.S. Citizens and individuals around the world
were able to obtain the original file with the fulI SSN. ,See hhibit J attached
hereto, Affidavit of Felicito Papa.
6. Counsel herein, Taitz checked an official site for Selective Service
SSS.gov. She entered the name "Barack Obama" along with his publicly available
alleged date of birth "08.04.1961" and Connecticut SSN 042-68-4425 (whrch
Obama is using in his tax returns as indicated above). Taitz received a verification
showing that Obama registered for Selective Service using the Connecticut SSN.
See Exhibit 10 attached hereto, Selective Service Verification.
7. Taitz received an affidavit from a witness named Linda Jordan
("Jordan"), who ran an E-verifr check for SSN 042-68-4425. According to ETaitz
et al v Democratic Party of MS, Secretary of State of MS 18
verify, there is no match between obama's name and the sSN he used on his tax
retums and Selective Service application. see Exhibit 6 attached hereto, Affidavit
from Linda Jordan.
8. Taitz received an email from a U.S. Army office1 Colonel Gregory
Hollister, whereby he did an independent check and found that indeed Obama is
using this Connecticut SSN. He also contacted SSNVS (Social Security Number
Verification Systems) and found that the number Obama is using was never
assigned to him. See Exhibit 12 attached hereto, Email from Colonel Gregory
Hollister.
9. Recently Obama's Uncle Onyango Obama was arrested for drunk
driving and found to be using for employment a Social Security Number even
though he is an illegal alien and not allowed to work. Obama's Aunt Zeutuni
Obama was stealing taxpayer dollars by living in subsidized housing and using an
Indiana-issued Social Security Number, even though he is an illegal alien and was
never a resident of the State of Indiana. Therefore, there is a pattem of multiple
members of Obama's family using fraudulently obtained Social Security numbers,
at Obama's behavior is true to that pattem of Social Security fraud and immigration
fraud.
10. Obama's close associate, William Ayers, in his book Fugitive Days,
admitted to creating over a hundred fraudulent Social Security Numbers using
Taitz et al v Democratic Party of MS, Secretary of State of MS t9
names of deceased infants who did not get their Social Security numbers before
their deaths. As he states it Fugitive Days, "After the Baltimore fiasco, stealing ID
was forbidden. Instead we began to build ID sets around documents as flimsy as a
fishing license or a laminated card available in a Times Square novelty shop called
"official ID.' we soon figured out that the deepest and most foolproof ID had a
govemment-issued social Security card at its heart, and the best source of those
were dead-baby birth certificates. I spent impious days over the next several
months tramping through rural cemeteries in Iowa and wisconsin, Illinois and
North Dakota, searching for those sad little markers of people bom between 1940
and 1950 who had died between 1945 and.1955. The numbers were surprising: two
in one graveyard, a cluster of fourteen in another. Those poor souls had typically
been issued birth certificates-available to us at any county courthouse for a
couple of bucks and a simple form with information I could copy from the death
announcement at the archive of the local paper-but they had never applied for a
Social Security card. collecting those birth certificates became a small industry,
and within a year we had over a hundred. For years I was a paper-made Joseph
Brown, and then an Anthony Lee, remarkably durable identities. My on-paper
official residences: a transient hotel in San Francisco and a warehouse in New
York.' william Ayers, Fugitive Days. Association and close friendship with Ayers
is an additional indication and circumstantial evidence of social security fraud by
Tutz et al v Democratic Party of MS, Secretaxy of State of MS 20
obama, and his lack of valid identification documents to prove not only natural
bom status, but any status for t}lat matter.
I 1. For nearly three years after his inauguration obama refused to provide
to the public his long form birth certificate. on April 27,2011, when obama
posted his alleged long form birth certificate online, just as with his tax retums, he
originally did not flatten the file, which means that anyone with an Adobe
Illustrator program on his computer could see layers of alterations in this alleged
"birth certificate" which looked like a complete fraud and hoax. Multiple long
form birth certificates from 1961 are available. In those years green safety paper
was not available and was not used. other birth certificates, as one for Susan
Nordyke, born the next day on August 5,1961, in the same hospital, and signed by
the registrar on August 11,1961, show white paper with yellow aging stains, clear
borders, raised seal and a lower serial number. (Exhibit 13) obama's alleged binh
certificate is on a safety paper, which was not used in 1961, does not have a clear
paper, no raised seal, and the serial number is higher than the numbers issued later
by the same Registrar. See Exhibit 4, 13.
12. According to the affidavit from Adobe Illustrator expert papa (Exhibit
4,hereto), the released image digital file showed layers of alteration of the alleged
birth certificate. It showed a signature of Obama's mother, Stanley Ann D. Soetoro
(her maried name by her second husband), where it looks as though "Soetoro"
Taitz et al v Democratic Party of MS, Secretary of State of MS 21
was erased, whited out and computer graphics used to add "unham Obama" and a
signature "Stanley Ann Dunham Obama" was created by pasting and filling the
blanks with computer graphics.
13. Taitz received an affrdavit from scanning machines expert Douglas
Vogt. ("Vogt") See Exhibit t hereto, Affidavit of Douglas Vogt. Vogt attests to
further evidence of forgery, such as different types of ink used. Some of the
document shows as "gray scale" scanning, some as black and white scanning, and
some as color scanning. It shows different types of letters and variations in
keming, meaning some letters are encroaching into the space of other letters which
is possible only with computer graphics, not with a typewriter used in 1961.
Numerous other parameters lead to the same conclusion, that the document in
question is not a copy of a 1961 typewritten document, but a computer-generated
forgery, created by cutting and pasting bits and pieces from different documents
and filling in the blanks with computer graphics.
14. It appears that Obama used a Social Security number of a deceased
elderly individual, as well as a birth certificate number of a deceased infant, to
fabricate his false identity. Research pointed to the fact that one Virginia Sunahara
was born in Honolulu on August 4, 1961 and passed away the next day. Recently
her surviving family member demanded to see her long form birth certificate, but
the department of Health provided Mr. Sunahara only with a computer generated
Taitz et al v Democratic Party of MS, Secretary of State of MS 22
short form birth certificate with a serial number, which was suspiciously out of
sequence from all the other numbers issued to infants bom August 4, 1961.
15. In spite of numerous demands, Director of Health Loretta Fuddy
refused to allow the inspection of the original birth certificate of either obama or
Sunahara in lieu of the alleged certified copy, and the Social Security
Administration refused to provide even a redacted application for Connecticut SSN
042-68-4425, which Obama is fraudulently using.
16. Affidavit of Chris Strunk (Exhibit 11 Case file Farrar v
Obama admitted into evidence) shows that in his motJrers passport records received
by Strunk in response to his FOIA request submitted to the Department of State,
Obama is listed under the name Barack Obama Soebarkah. There is no evidence
of Obama ever legally changing his name. Additionally, in his school records in
Indonesia Obama is listed under the name Soetoro and citizenship Indonesian
(Exhibit 11).
Based on all of the above, Obama does not have any valid identification
papers and is a foreign national, who is fraudulently using forged identification
papers in order to be on the ballot.
17. Additionally, the term "Natural Born Citizen," as it is applied to the
U.S. Presidency, means one bom in the country to citizen parents. The plaintiffs
submit their evidence showing that from the time of the adoption of the
Taitz et al v Democratic Party of MS, Secretary of State of MS 23
Constitution until today the standard was "One bom in the country to parents who
are citizens do not owe their allegiance to others." The U.S. Constitution was based
in no small measure upon the book The Latv of Nations by Emer de Vattel, stating
that "Natural Bom Citizens" are ones born in the "Nations to citizens. @mer De
Yaltel, The Law of Nations, p. 499, section 212). A similar definition was used by
John A Bingham, drafter of the l4h amendment to the United States Constitution,
who stated during Congressional Hearings that a "natural bom citizen is bom in the
U.S. Territories to parents, who didn't owe allegiance to other sovereignties." A
similar definition was used in the case of Minor v. Happerset,88 U.S. 162 (1875).
18. In 2008 natural bom citizenship of John McCain was questioned as
well due to his birth in the zone of the Panama Canal. In Joint Senate Resolution
5ll the Senate unanimously found Senator McCain to be a'Natural Bom" U.S'
Citizen. The Senate used the same Vattel two pronged test and found McCain to be
eligible for the presidency due to the fact that he was bom in the Panama Canal
zone to two parents who were U.S. Citizens. Obama's father was never a U.S.
citizen. He never had a green card. He was in the U.S. for a few years on a student
visa and, as such, Obama did not satisfr either one of the two prongs of the test for
natural bom status. Even if this office was to subscribe to a more liberal modem
definition ofnatural bom citizen, Obama does not qualifu as he never proved his
birth in Hawaii and is using a computer-generated forgery instead of a valid long
Taitz et al v Demoqatic Party of MS, Secretary of State of MS 24
form birth certificate and he is fraudulently using a Social security Number which
was never assigned to him. This case shows an unprecedented level of comrption
and lawlessness in the federal government and in the govemment of Hawaii, which
allowed Obama to get on the ballot in 2008.
Due to all of the above, Barack Hussein obama does not have any valid U.S.
identification papers and is constitutionally not eligible. Based on all of the above
a Declaratory relief has to be granted and obama has to be declared ineligible to be
on the ballot for the 2012 general election.
INJT]NCTIYE Rf,LIEF
A. EMERGENCY PRELIMINARY INJUNCTION
Plaintiffs incorporate all prior paragraphs as if fully pled herein.
a. EQUITABLE RELIEF IS NECESSARYAS NO FINANCIAL DAMAGES
WOULD SUFFICE
The issue at hand is a Presidential election. Voters are being deprived of a
lawful election, as unlawful candidate is running for the US presidency.
Consequences of such deprivation of rights are staggering. No financial
compensation can account for the loss. As such equitable relief is warranted and
necessary.
Taitz et al v Democratic Party of MS. Secretary of State of MS 25
b. DEFENDANTS WOULD NOT BE PREJUDICED BY TTM INJLINCTION
AND WOULD NOT SUFFER AN UNDUE TIARDSHIP
Defendants would not suffer undue hardships. First, the only defendant, who can
even claim hardship, is candidate Obama; however hardship can be suffered,
only if one loses something he was entitled to. Obama never had any valid
identification papers, he was never entitled to be on the ballot in the first place.
Therefore, no hardship will be suffered by Obama. Additionally, even if one
were to believe that Obama had a right to be on the ballot, a preliminary
injunction will not deprive him of such right
c. BALANCE OF HARDSHIPS POINTS TO A NEED FOR INJLNCTIVE
RELIEF
In balancing the hardships between the Plaintiffs and defendants, the Plaintiffs
rights would outweigh the defendants' rights, as there is a deprivation of the
basic civil rights to have a lawful election. Plaintiff Taitz received multiple death
threats from Obama supporters who do not believe that their "messiah" is
capable of committing elections fraud and is using forged documents. Unless the
injunction is issued and the public is apprised of the evidence of the elections
fraud and forgery by Obama, such death threats will continue until one of
Obama's supporters will succeed in making his threat a reality. Balancing the
hardships points to the need ofinjunction.
Taitz et al v Democratic Party of MS, Secretary of State of MS 26
d. INJUNCTION WOTILD BE IN PUBLIC INTEREST
Today the voters axe deprived of lawful elections. Plaintiffs are being harassed
and defamed due to their status of whistleblowers.
We are experiencing an unprecedented level of censorship of our so called
"main stream media", where the truth about Obama's forged identification
papers is being suppressed and the voters are being kept in the dark and
defrauded as they mistakenly believe Obama to be a legitimate candidate.
Whistleblowers, like the Plaintiffs are attacked. Preliminary injunction is the
only way to apprise the public ofthe elections fraud and forgery in the highest
office in the land. If emergency preliminary injunction is not issued, the public
will be permanently disenfranchised in the Presidential elections. Time is of the
essence, as the voters and other candidates need a sufficient notice that Obama
is not a legitimate candidate, so that they will come up with an altematrve
candidate. Particularly the Democratic Party voters are at risk of being
disenfranchised. Preliminary injunction is warranted and necessary.
Due to the urgency and importance of the matter and due to the fact that the
Honorable judge Coleman is ill and unable to conduct a hearing, Plaintiffs are
requesting the Preliminary injunction to be issued ex-parte on the pleadings
without a hearing. Defendants will have an opportunity to present their case and
evidence during the hearing for the permanent injunction.
Taitz et al v Democratic Party of MS, Secretary of State of MS 27
B. Permanent injunction.
Plaintiffs incorporate all of the previous paragraphs as if fully pled herein.
Upon receipt of the preliminary injunction, and evidentiary hearing Plaintiffs
are seeking a permanent injunction.
RICO
Chapter 96 of Title 18 of the United States Code, 18 U.S.C. $ 1961-1968
Predicate acts
section 1028 (relating to fraud and related activrty in connection with identification
documents),
section 1341 (relating to mail fraud),
section 1343 (relating to wire fraud),
section 1425 (relxing to the procurement of citizenship or nationalization
unlawfully), section 1426 (relating to the reproduction of naturalization or
citizenship papers
section 1503 (relating to obstruction ofjustice),
section 1512 (relating to tampering with a witness, victim, or an informant),
section 1513 (relating to retaliating against a witness, victim, or an informant),
section
section 1546 (relating to fraud and misuse of visas, pennits, and other documents)
Taitz et al v Democratic Party of MS, Secretary of State of MS 28
OBAMA FOR AMERICA-RACKETEERING INFLUENCED CORRUPT
ORGANIZATION
"Obama for America" -Racketeering Influenced Comrpt Organization
Barack Hussein Obama created "Obama For America" as his fundraising
organization for his Presidential run. At all times Obama was not eligible for the
US presidency and he used "Obama for America" as a vehicle to defraud American
citizens and get
documents.
into the position of the U.S. President while using forged
DE-FACTO RICO ENTERPRISE, "ASSOCIATION-IN-FACT" RICO
ENTERPRISE
Between 2007-2012 defendants acted together or in groups and created an
"association- in- fact" enterprise, which is sufficient for RICO, even if "Obama for
America" was not a RICO enterprise. Defendants acted directly or indirectly,
personally or through agent or agents, employed the same or similar methods of
commission with the purpose to defraud, utter forged documents, commit wire and
mail fraud, unlawfully procure citizenship and nationalization unlawfully, obstruct
justice and intimidate, harass, defame, slander and otherwise retaliate against
witnesses, victims, informants and whistleblowers. Plaintiffs were victims of the
acts of the racketeering or the acts of racketeering were otherwise interrelated by
distinguishing characteristics and were not isolated events.
Taitz et al v Democratic Party of MS, Secretary of State of MS 29
PATTERN OF ONGOING RACKETEERING ACTIVITY
Fraud committed by defendants, who were acting directly or indirectly and
committed fraud, which was on going from 2007 until now, for over four years.
Actions by the defendants established a pattern of racketeering activity within the
meaning of 18 U.S.C. $1962(c), in that their corlmon purpose was to defraud, the
common result was to defraud. Plaintiffs were victims of the acts of racketeering
and the acts of racketeering were otherwise related by distinguishing
characteristics and were not isolated events.
RICO
FRAI]D
FRAUD COMMITTED BY OBAMA
1. Obama created "Obama for America" with a purpose to defraud American
citizens and illegally usurp the U.S. Presidency, while using forged
identification papers.
2. Obama used a forged birth certificate as his identification paper and as a
proof of his eligibility
3. Obama used one or more Social Security numbers, that were not assigned to
him
4. Obama used a forged selective service certificate
Taitz et alv Democratic Party of MS, Secretary of State of MS 30
6.
7.
5. It is Plaintiffs informed belief that Obama used other fraudulently obtained
identification papers
Obama held April 27, 2011 press conference, presenting a forged birth
certificate and attacking "birthers"
Obama refused to comply with any subpoenas and notices to appear in court
or elections commission or board hearing in relation to his identification
papers.
8. Obama acted through his agents, such as aids, press secretaries, attomeys,
campaign workers, his web site "Fight the Smears" and "Obama for
America in order to defraud the Plaintiffs and others and in order to attack,
harass, defame, slander and persecute Plaintiffs and other patriots seeking to
get expose Obama's forged documents.
Fraud Committed by Defendant Obama for America
Defendant Obama for America by and through its website ran and continues to
run a page httil://www.attackwatch.com/gop-conspiracy-theorists
un- b ir-th-certill citte- rt1\ thi
This website is being used for defrauding the public and attacking defendants.
In an unprecedented magnitude of malice obama and obama for America are
using the web pages paid by Obama for America to create truth squads and
,.Truth Team", inciting followers to report "birthers" and others, who they
Taitz et al v Democratic Party of MS, Secretary of State of MS 31
claim, are lying, while in reality, Obama and Obama for America
committing the biggest fiaud in the history of this nation.
FRAT]D COMMITTED BY DEFENDANT LORETTA FUDDY
Defendant Loretta Fuddy, director of Health of the state of Hawaii aided and
abetted Obama in committing elections fraud by covering up the fact that Obama is
using a forged birth certificate. In and around April 25,2011 Fuddy either
personally issued a fraudulent letter, claiming that she observed copying of
Obama's birth certificate, or she was silent when she had a duty to speak up, when
Obama, his attomey Robert Bauer and his press secretary Jay Camey presented a
forgery, claiming that it came with an authenticating letter from Fuddy.
FRATID COMMITTED BY DEFENDANT ALYIN ONAKA
Defendant Alvin Onaka, Registrar of the state of Hawaii aided and abetted Obama
and was complicit in the cover up of the fact that Obama is using a forged birth
certificate. He had a duty to speak up when on Apil 27th Obama and his associates
presented a forgery, claiming it to be a valid true and correct copy of Obama's
original 1961 birth certificate. Onaka knew that the "document" was a computer
generated forgery, that the security paper image and an image of his stamp were
brought from another document.
FRAUD COMMITTED BY DEFENDANT ASTRT]E
Taitz et al v Democratic Party of MS, Secretary of State of MS 32
Defendant Michael Astrue, commissioner of the Social Security, aided and abetted
Obama by covering up the fact that Barack Obama is fraudulently using a
Connecticut Social Security number 042-68-4425, which was issued in and around
1977 in the State of Connecticut to a resident of Connecticut bom in 1890 and that
this Social Security number does not pass E-verifu, when checked under the name
Barack Obama
FRAUD COMMITTED BY DEFENDANT DEMOCRATIC PARTY OF
MISSISSIPPI
Defendant Democratic Party of Mississippi aided and abetted Obama by covering
up elections fraud and forgery and refusing to respond to the ballot challenge by
the Plaintiffs and by keeping Obama as the Democratic candidate for the US
Presidency, while knowing that he is not eligible and is committing elections fraud
FRAI]D COMMITTED BY DEFEI\DANT PELOSI
During the 2008 democratic party convention Pelosi served as the chair of the
convention.
Until the 2008 convention certificates of the party candidate contained wording
"eligible according to the constitution"
Upon nomination of Obama Pelosi released an altered certification of candidate
where the words "according to Constitution" were removed.
Taitz et al v Democratic ParE of MS, Secretary of State of MS 33
Such altered certifications were sent to 49 out of50 states.
Apparently the state of Hawaii was not willing to accept the certification with an
altered wording.
The only reasonable explanation for Pelosi to remove the wording, was to
fraudulently place Obama's name on the ballot, while attempting to shield herself
from criminal liability.
Pelosi commilted 49 counts of fraud by signing altered certificates of candidacy.
Defendants acted with an intent to defraud and aid Obama in committing elections
fraud. Plaintiffs were intended victims and foreseeable victims.
Defendant acted through Obama for America and in association-in-fact RICO
enterprise. As a result of actions by the Defendants Plaintiffs suffered financial
damages, defamation, humiliation, harassment and emotional distress as a result of
fraud committed by the defendants.
MAIL AND WIRE FRAUD
DEFENDANT OBAMA
Defendant Obama committed mail and wire fraud, when he posted on the lntemet
in and around Api,l 27,2012 a paper, which he claimed to be a true and correct
copy ofhis long form birth certificate.
Taitz et al v Democratic Party of MS, Secretary of State of MS 34
obama committed mail and wire fraud, when he posted on the Internet on his site
"Fight the smears" a paper, which he claimed to be his short form birth certificate.
obama knew that he is committing fraud and intended to defraud in order to
continue usurping the position of the U.S. President.
obama committed fraud when he sent to 50 states in 2007-2008, as well as in
2011'2012 his declarations of candidacy. obama used mail or other
instrumentalities of the Interstate commerce to commit such fraud.
Obama committed mail and wire fraud when in and around January 25th,2012 he,
through his attomey Michael Jablonski, sent by mai1, fax and e-mail a defamatory
letter to the Secretary of State of Georgia, where he attacked plaintiff raitz, who
was an attomey in Farrar v Obama, claiming that he has produced a birth
certificate and that he suffers from Taitz.
In and around November 19,2011Obama committed mail and wire fraud, when he
through his agent, Deputy Campaign Manager Juliana Smoot, personally attacked
and defamed Taitz: "IIELEASE TFm MUGS
By Julianna Smoot, Deputy Campaign Manager on November 19,20ll
Yesterday, four Republicans in the New Hampshire State House allowed a hearing
requested by Orly Taitz, the notorious dentist-lawyer-birther who wants
President Obama o{Iicially removed from the state's primary ballot.
Taitz et al v Democratic Party of MS, Secretary of State of MS 35
So in honor of conspiracy theorists everywhere, we're re-releasing the campaign's
limited-edition "Made in the USA" mugs.
There's clearly nothing we can do to satisfu this crowd----or anyone else who
insists on wasting time and energy on nonsense like this.
But when it starts to make your head hurt, I've found the best remedy is to have
in my "Made in the USA" mug.
Works like a charm. I recommend Earl Grey."
Obama and his agent were defrauding the nation, while at the same time defaming
and harassing Taitz.
PRELIMINARY LIST OF'FORGED DOCUMENTS TIIAT WERE
I]"TTERED BY OBAMA
a. long form bi*h certificate- affidavits of Adobe illustrator expert Felicito Papa,
scanning and printing machines expert Doug Vogt, senior deportation officer John
Sampson and announcement by sheriff Arpaio (exhibits 1-3) show Obama's long
form birth certificate to be forged
b. short form birth certificate-certifltcation of live birth. Research by Dr. Ron
Polland show short form birth certificate to be forged
c. Selective Service Certificate- investigative report by federal agent Steven
Cofftnan, joumalist Linda Bentley and announcement by Sheriff of Maricopa
Taitz et al v Democratic Party of MS, Secretary of State of MS
county, Aizona and lead investigator Mike Zullo, Maricopa county, Arizona,
show Obama's selective service certificate to be forged
d. Social Security certificate- affidavits of Senior Deportation officer Sampson,
licensed investigator Daniels, researcher Linda Jordan, adobe illustrator expert
Felicito Papa show Obama using as his own a social security number 042-68-4425,
which was assigned to another individual, resident of Connecticut, who was bom
in 1890
e. possibly all other identification documents are fraudulently acquired, as those
rest on forged primary identification papers
Barack Obama knew that he is using forged identification papers and is not eligible
for the U.S. Presidency
Obama used created "Obama for America" with a purpose to defraud American
citizens and illegally usurp the U.S. Presidency, while using forged identification
papers.
Defendant Loretta Fuddy, director of Health of the state of Hawaii aided and
abetted Obama in committing elections fraud by covering up the fact that Obama is
using a forged birth certiflicate
Taitz et al v Democratic Party of MS, Secretary of State of MS 37
Defendant Alvin Onaka, Registrar of the state of Hawaii aided and abetted Obama
and was complicit in the cover up of the fact that Obama is using a forged birth
certificate
Defendant Nanci Pelosi, former speaker of the House and chairwoman of the
Democratic National convention aided and abetted Obama by submitting to 49 out
of 50 states an altered certificate of candidate for the U.S. Presidency for Barack
Obama, where usual wording "eligible according to the U.S. constitution" were
removed.
Defendant Michael Astrue, commissioner of the Social Security aided and abetted
Obama by covering up the fact that Barack Obama is fraudulently using a
Connecticut Social Security number 042-68-4425, which was issued in and around
1917 itthe State ofConnecticut to a resident ofConnecticut bom in 1890 and that
this Social Security number does not pass E-veriff, when checked under the name
Barack Obama
Defendant Democratic Party of Mississippi aided and abetted Obama by covering
up elections fraud and forgery and refusing to respond to the ballot challenge by
the Plaintiffs and by keeping Obama as the Democratic candidate for the US
Presidency, while knowing that he is not eligible and is committing elections fraud
OBSTRUCTION OF JUSTICE
Taitz et al v Democratic Party of MS, Secretary of State of MS 38
Obstruction of Justice by Defendant Obama
Taitz served Obama with a valid subpoena in Farrar v Obama OSAH-SECSTATECE-
1215136-60-MALHI in the Administrative court of the State of Georgia.
Obama by and through his attomey filed a motion to quash the subpoena. Motion
was denied and Obama was supposed to appear in court and present either original
or true and correct copies of his identification papers. Obama did not show up, he
did not send a representative and he obstructedjustice by being in contempt ofa
valid subpoena. Obama obstructed justice in order to hide forgery in his
identification papers.
OBSTRUCTION OF JUSTICE BY DEFENDANT FUDDY
In and around of June of 2011 Taitz served Fuddy with a valid federal subpoena to
produce for inspection a book of birth records for 1961 with Obama's original
1961 long form birth certificate. Through her attomey, Deputy Attomey General
Nagamine, Fuddy refused to comply with valid federal subpoena. Fuddy
obstructed justice in order to aid and abet Obama in his use of a forged birth
certificate .
RETALIATION AGAINST A WITNESS, VICTIM OR AN INT'ORMANT
BY DEFENDANT OBAMA
Taitz et a1v Democratic Party of MS, Secretary of State of MS 39
Obama retaliated against the Plaintiffs by defaming and humiliating them, while at
the same time defrauding the nation. Obama issued a statement, calling Plaintiffs
"side show and camival barkers" with a clear goal of intimidation.
Defendant Obama by and through his Deputy Campaign manager Juliana Smoot
intimidated Taitz personally, when a statement was issued on November 19,2011
naming Taitz and implying and relating to Obama supporters that Taitz is
somehow harassing Obama.
Defendant Obama, by and through his attomey Michael Jablonski sent letters to
Secretary of State of Georgia and judge Malihi in Georgia personally attacking
Taitz and demanding some action to be taken against her. All of this was done, as
Obama knew that indeed he was using forged documents and while he acted with
an only goal of retaliating, harassing, intimidating Taitz, who is a witness,
whistleblower and a victim.
R.ETALIATION AGAINST A WITNESS, VICTIM OR AN INFORMANT
BY DEFENDANT OBAMA FORAMERICA
Defendant Obama for America retaliated against the defendants by posting
fraudulent and defamatory statements in order to defame, harass and intimidate
Plaintiffs.
RETALIATION AGAINST A WITNESS, VICTIM OR AN INFOR]VIANT
BY DEFENDAIYT DEMOCRATIC PARTY OF MISSISSPPI
Taitz et al v Democratic Party of MS, Secretary of State of MS 40
Democratic Party of Mississippi used this case at hand in order to harass and
intimidate Plaintiff Taitz, intimidate her supporters and donors by making
unreasonable and outlandish demands on her.
RETALIATION AGAINST A WITNESS, YICTIM OR AN INT'ORMANT
BY DEFENDANTS JOHN DOES AND JANE DOES
Defendants John Does and Jane Does who are yet to be identified, retaliated
against Plaintiffs and particularly plaintiffTaitz in a following manner
1. Tampering with her car, where a fumes emissions hose was disconnected
and hot combustible fumes were going back to the engine, which could
cause the car to ignite, bum, explode with Taitz, her husband and her three
children in the car
2. Hiring an artist whose nzrme is believed to be Jim Lacey, to paint a series of
inappropriate pomographic nude paintings of Dr. Taitz, under the title
"Birther Orly Taitz " creating a whole exposition of such paintings and
posting those images all over the Internet, in local papers and sending those
to her three children.
3. Subsidizing and running websites, where Plaintiffs and particularly Taitz
were defamed, humiliated, harassed and intimidated.
Taitz et al v Democratic Party of MS, Secretary of State of MS 4l
1.
4. Hacking, destroying and otherwise tampering with her web sites, e-mail
accounts, mail, Federal Express packages, phone and other forms of
communication
As a result of actions by the defendants Plaintiffs were deprived of their first
amendment right to free speech in that they were deprived of their right of
parti cipating in free elections.
Plaintiffs suffered defamation and humiliations, being attacked as "birtherso',
were called crazy, while they were telling the truth about the fact that
defendant Obama is committing elections fraud and is using and uttering
forged documents as a proof of his eligibility for the U.S. Presidency.
Plaintiff Taitz received multiple death threats from Obama supporters who
do not believe that their "messiah" is capable of committing elections fraud
and using forged documents. Unless the injunction is issued and the public is
apprised of the evidence of the elections fraud and forgery by Obama, such
death threats will continue until one of obama's supporters will succeed in
making his threat a reality.
2.
Taitz et al v Democratic Party of MS, Secretary of State of MS 42
4. Plaintiffs suffered damages of emotional distress, financial damages,
defamation, slander, harassment as a direct result of the actions by the
defendants.
5. Defendants acted intentionally, outrageously, oppressively, despicably
and maliciously. Exemplary and punitive damages are warranted in order to
punish and deter such conduct in an amount to be determined at trial.
PRAYER FOR RELIEF
I . Declaratory relief deeming Barack Obama not eligible to be on the ballot as a
candidate for the U.S. Presidency due to fraud, lack of eligibility and use of forged
identification papers.
2. Issue an injunction preventing Secretary of State from placing Obama's name on
the ballot in the general election and de-certifring/annulling all votes for Obama in
the primary election.
3. Award treble damages to plaintiffs in RICO charges to cover financial damages
of the Plaintiffs, as well as damages suffered as a result of defamation, slander,
harassment and persecutions of Plaintiffs, who blew the whistle on Obama.
4. Cost and fees of this trial
5. Punitive and exemplary damages
Taitz et al v Democratic Party of MS, Secretary of State of MS 43
6. Any other damages this court finds proper andjust
04.12.2012
l

sl Orly Taitz
/s/ Brian Fedorka
/s/ Leah Lax
/s/ Laurie Roth
/s/ Tom Mac Leran
Taitz et al v Democratic Party of MS, Secretary of State of MS 44


CERTIFICATE OF SERVICE
I. Lila Dubert, Erm over 18 years old, not apaxty to this case and I attest that on
served the defendants with above pleadings.
Taitz et al v Democratic Party of MS, Secretary of State of MS 45