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TX - TvS - 2012-08-28 - ECF 9 - Taitz Reply to Order to Show Cause

TX - TvS - 2012-08-28 - ECF 9 - Taitz Reply to Order to Show Cause

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Published by Jack Ryan
08/31/2012 9 Supplemental Document by Orly Taitz as to 6 Order to Show Cause Response to courts sua sponte inquiry on venue. (Attachments: # 1 Ruling on venue by Judge Gee in Central District of CA) (Taitz, Orly) (Entered: 08/31/2012) [Reply to Order to Show Cause re: Venue]
08/31/2012 9 Supplemental Document by Orly Taitz as to 6 Order to Show Cause Response to courts sua sponte inquiry on venue. (Attachments: # 1 Ruling on venue by Judge Gee in Central District of CA) (Taitz, Orly) (Entered: 08/31/2012) [Reply to Order to Show Cause re: Venue]

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Categories:Types, Research, Law
Published by: Jack Ryan on Sep 04, 2012
Copyright:Attribution Non-commercial

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09/10/2012

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1
2
3
4
56
1
B
9
1011L213L415
16
L7
1B
192021
22
23242526
2'1
2B
Dr.Orly
Taitz,
ESQ
29839
Santa
Margarita,
ste
100
Rancho
Santa
Margarita,
CA
92688
Ph.
949-683-54
1
1
fax
949-7
66-7
603
Pro
se
plaintiff
DR.
ORLY
TATTZ,
ESQ
Plaintiff,
VS.
KATHLEEN
SEBELIUS,In
her capacity
of
Secretary
of
Health
and
Human
Services et.al.
Defendant.
IN
THE
US
DISTRICT
COURT
FOR
THB
NORTHERI\DISTRICT
OF
TEXAS
DALLASDIVISION
Case
No.:
3:12-cv-03251-P
VIOLATION
OF
14TH
AMENDMENT
EQUAL
PROTECTIONRIGHTS,
ESTABLISHMENT
CLAUSE
ARTICLE
2SEC
1
OF
COSTITUTIO
INJLINCTIVE
RELIEF,STAYDECLARATORYRELIEF
RICO, PREDECATE
CRIMES
:
FRAUD,
AIDINGANDABETTING
FORGERY
ANDUTTERING
OF
FORGEDDOCUMENTSTO
COMMIT
ELECTIONS
FRAIID
7TH
AMENDMENT
JTIRY
DEMANDEDREPLYTO
ORDER
TO JUSTIFYVENUEBACKGROUND
Case 3:12-cv-03251-P Document 9 Filed 08/31/12 Page 1 of 5 PageID 259
 
1
23
4
56
1
B
9
1011
t2
1aAJ
74
15
L6
l1
1B
l9
2L2223
24
2526
21
2B
The
case
Taitz
v
Sebeliuset.
al
was
originallyfiled
in
the
U.S.
District
CourtCentral
District
ofCalifornia
on
Ju1y5,
2A12.
The
complaint
Challengesthe
constitutionalityof
the
PatientProtection
and
Affordable
Act26
USC
50004.
On
August
16,2012
the
District
Judge
DollyM.
Gee
dismissed
the
case
without
prejudice
for
lack
of
venue.
Plaintiff
re-filed
the
Complaint
in
Northern
District
of
Texas
due
tothe
fact
that
one
of
the
non-federal
defendants
William
Chatfield
resides
inNorthern
District
of
Texas,
Dallas
Division.
Argument
In
her
decision
from
August
16,2012,
the
District
Judge
Gee
ordered
to
dismiss
the
Complaint without
prejudice
for
lack
of
venueonthe
basis
that
none
of
the
anynon-federal
defendant reside
intheCentral
District
ofCalifomia.
28
U.S.C.
$
1391(eX1XC)
states
that
Non-federal
defendants
may
be
joinedin
such
a
civil
action
if
the
plaintiff
demonstrates
that
venue
is
proper
for
such
non-federal
defendantsunder
o'other
venue
requirements
as
would
be
applicable
if
the
United
States
or
one
of
its
officers,
employees,
or
agencieswere
not
a
party."In
her
decision,
Judge
Gee
pointedthat Defendant
William
Chatfield
is
a
non-federal
defendant
and does
not
reside
inCA,
Exhibit
1
Ruling
by
Judge
Gee.
Due to
thefact
that
defendant
Chatfield
resides
in
the
Northern
District
of
TX,Plaintiff
Taitz
Case 3:12-cv-03251-P Document 9 Filed 08/31/12 Page 2 of 5 PageID 260
 
123
4
J
6
7
89
1011121374
16
t7
18
79202L23
Z4
2526
2'7
2B
properlyre-filed
the
case
in
the
Northern
District
of
TX.
The venueis
proper.
As
the complaint
was
originallyfiled
on
July
5th
and
all
theparties
were
served
on
July
5,
2012,and
currentcomplaint
was
refilled
in
order
to
changevenue,
Taitz
isrequesting
an
expedited
Motion
hearing
on her
motionto
stay
Healthcare
penaltiHealthcare
tax,which
was
originally
scheduled
in
CA
on
August
10th
and had
to
rescheduled.
This
case
has
nationalimportance
and
expedited
hearing
iswarranted.
Respectfully
submitted
lsl Dr.Orly
Taitz
ESQ
08.31
.2012
Case 3:12-cv-03251-P Document 9 Filed 08/31/12 Page 3 of 5 PageID 261

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