IN THE UNITED STATES DISTRICT COURTFOR THE NORTHERN DISTRICT OF TEXASDALLAS DIVISIONDR. ORLY TAITZ, ESQ., §§Plaintiff, §§v. § Case No. 3:12-cv-03251-P§KATHLEEN SEBELIUS, Secretary, §Health and Human Services,
, §§Defendants. §
FEDERAL GOVERNMENT DEFENDANTS’ MOTION TO DISMISS
Defendants President Barack Obama; Kathleen Sebelius, Secretary of Health and HumanServices; Michael Astrue, Commissioner of Social Security; Eric Holder, Attorney General of the United States; and William A. Chatfield, past director of the Selective Service (collectivelythe “Federal Government Defendants”) hereby move to dismiss plaintiff Orly Taitz’s complaint.
The motion is made on the grounds that the Court lacks subject matter jurisdiction over Taitz’sclaims, that venue is improper in this district, and that Taitz otherwise fails to state a claimagainst the Federal Government Defendants upon which relief may be granted. In support of thismotion, the Court is respectfully referred to the attached memorandum of points and authorities.Dated: September 20, 2012. Respectfully submitted,STUART F. DELERYActing Assistant Attorney GeneralSHEILA M. LIEBER
Insofar as Taitz sues Chatfield for actions taken in his official capacity, the proper defendant isthe current director of the Selective Service, Lawrence G. Romo.Taitz served the United States Attorney’s Office by certified mail on September 4, 2012. Shedoes not appear to have served the Attorney General or any of the federal government agenciesor official-capacity defendants, as required by Federal Rule of Civil Procedure 4(i).
Case 3:12-cv-03251-P Document 15 Filed 09/20/12 Page 1 of 36 PageID 394