Strunk v. U.S. Department of State et al. DCDC 08-cv-2234Supplement Petition for Writ of Mandamus – Page 1 of 20

UNITED STATES DISTRICT COURTFOR THE DISTRICT OF COLUMBIA

--------------------------------------------------x Case No.:

08-cv-2234 (RJL)

:CHRISTOPHER EARL STRUNK :

SUPPLEMENT AMENDED

VERIFIED COMPLAINT

Petitioner, :

AND PETITION FOR

v. :

WRIT OF MANDAMUS

UNDER F.O.I.A.

U.S. DEPARTMENT OF STATE, and :U.S. DEPARTMENT OF HOMELAND :SECURITY, :Defendants. ::-------------------------------------------------x

NOW COMES

Christopher Earl Strunk, as the Petitioner, andbrings this Supplement Amended Complaint under Federal Rules of CivilProcedure Rule 15(a)(1)(c)(1)(B)(d) of the Complaint filed with the clerk of the District Court on November 26. 2008, and pursuant to the Freedom of Information Act, 5 U.S.C. §552, et sequitur, against the Defendants theUnited States Department of State, and U.S. Department of HomelandSecurity, stating:

JURISDICTION AND VENUE

This cause of action arises under the Freedom of Information Actpursuant to 5 U.S.C. §552. Jurisdiction is properly before this Courtpursuant to that federal statute with the United States District Courts under28 USC §1331 with a Federal question and under 28 USC §1346.

Strunk v. U.S. Department of State et al. DCDC 08-cv-2234Supplement Petition for Writ of Mandamus – Page 2 of 20

This particular District Court for the District of Columbia affords theproper venue under 28 USC §1391 (e) (2) for this action in that theDefendant U.S. Department of State and Defendant U.S. Department of Homeland Security as each is located within the District of Columbia andthe failure of the Defendant and or Defendants to act separately and or inconcert was also within the District of Columbia.3.

Petitioner filed this complaint requesting this Court to Order the U.S.Department of State and U.S. Department of Homeland Security to fulfilltheir obligations pursuant to the Freedom of Information Act (hereinafter"FOIA") immediately turn over the following documents on the followingindividual:a.

Stanley Ann Dunham, a/k/a Ann Dunham a/k/a Stanley AnnObama a/k/a Ann Obama a/k/a Stanley Ann Soetoro a/k/a AnnSoetoro a/k/a Stanley Ann Sutoro a/k/a Ann Sutoro a/k/aStanley Ann Dunham Obama a/k/a Ann Dunham Obama,bornNovember 29, 1942 at

Wichita

Leavenworth KS. U.S., a.k.a.Stanley Ann Dunham Obama and who died on November 7,1995 under the name Stanley Ann Dunham Soetoro (a.k.a.Sutoro), SSN: 535-40-8522; andb.

Barack Hussein Obama, Jr. a/k/a Barry Soetoro Date of Birth:

Strunk v. U.S. Department of State et al. DCDC 08-cv-2234Supplement Petition for Writ of Mandamus – Page 3 of 20

August 4, 1961 and as a living natural person; and4.

The following documents:a.

Any and all U.S. Applications for a U.S. Passport;b.

Entry and Exit Passport Records pertaining to the United Statesand Kenya from the period of time of January 01, 1960 toDecember 31, 1975 and January 1, 1979 to December 31,1985;c.

Entry and Exit Passport Records pertaining to the United Statesand Indonesia from the period of time of January 01, 1960 toDecember 31, 1973 and January 1, 1979 to December 31, 1985;d.

The above travel records on for the dates specified travelling ona U.S. Passport, Kenyan Passport, Indonesian Passport or anyother foreign passport and/or visa;e.

Foreign Birth Certificate registered and filed with the U.S.Embassy, Kenya and/or U.S. Embassy of Indonesia for Barack H. Obama a/k/a Barry Soetoro, Date of Birth: August 4, 1961;f.

Foreign Birth Registry filed with the U.S. Embassy, Kenyaand/or U.S. Embassy of Indonesia by Stanley Ann Dunham, etal. Registering the birth of Barack H. Obama a/k/a BarrySoetoro, Date of Birth: August 4, 1961; and