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TX - TvS - 2012-10-05 - Taitz Reply to Opp to Motion for Preliminary Injunction - ECF 16

TX - TvS - 2012-10-05 - Taitz Reply to Opp to Motion for Preliminary Injunction - ECF 16

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Published by Jack Ryan
10/05/2012 16 REPLY filed by Orly Taitz re: 14 Response/Objection, (Attachments: # 1 Declaration(s) certificate of service) (Taitz, Orly) (Entered: 10/05/2012)



10/05/2012 16 REPLY filed by Orly Taitz re: 14 Response/Objection, (Attachments: # 1 Declaration(s) certificate of service) (Taitz, Orly) (Entered: 10/05/2012)



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Published by: Jack Ryan on Oct 09, 2012
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Taitz v Sebelius Reply to Opposition 1
Dr. Orly Taitz ESQ29839 Santa Margarita, ste 100Rancho Santa Margarita, CA 92688ph. 949-683-5411 orly.taitz@gmail.comPlaintiff pro se
IN THE NORTHERN DISTRICT OF TEXASOrly Taitz, ESQ ) Case 3:12-cv-03251v Kathleen Sebelius , in her official )capacity as the Secretary )of Health and human Services, et al )REPLY TO OPPOSITION TO MOTION FOR PRELIMINARYINJUNCTIONComes now plaintiff, Dr. Orly Taitz, ESQ, Hereinafter "Taitz", and replies tothe opposition by the defense as follows:
1. VenueAs it was explained in the response to the court, Taitz originally filed hercomplaint in California, where she resides.According to the ruling of CA judge Dolly Gee, defendant Chatfield did notqualify as a Federal employee for the purpose of ascertaining venue. That is whythe case was dismissed in California without prejudice, so that Taitz could refile inanother district.
Case 3:12-cv-03251-P Document 16 Filed 10/05/12 Page 1 of 15 PageID 498
 
Taitz v Sebelius Reply to Opposition 2
Mr. Chatfield resides at 1517 BONHAM CT, IRVING, TX 75038, which is in theNorthern district of TX, therefore Taitz filed in the correct district, the venue isproper and the court has jurisdiction.Moreover Chatfield's actions were not in furtherance of legitimacy of the SelectiveService, his actions undermined the legitimacy of the selective service. Taitzpresented to Chatfield evidence of forgery in Obama's IDs and due to someconsideration Chatfield decided to burry this evidence. his actions are outsidenormal functions of former Director of Selective Service2. Taitz does not belong to a recognized exemption group and will be subject toObamatax.See exhibit 1, Affidavit by Orly Taitz, stating that she does not belong to areligious group or sect and will be subject to Obamatax.
3. DEFENSE IS STATING THE OPPOSITE OF WHAT JUDGELAMBERTH STATED IN TAITZ V OBAMA 10- CV-151 RCR
Taxpayer standing was confirmed by the chief Judge of the US District court forthe District of Columbia, Judge Lamberth.In Taitz v Obama Taitz originally sued under the Writ of Mandamus and theCommerce Clause and the original complaint dealt with Obama's eligibility per DCQuo Warranto statutes. ACA was not signed into law until after the originalcomplaint was briefed. The court ruled that she did not have standing under thosetwo clauses and stated that there is taxpayer standing under the EstablishmentClause.
Case 3:12-cv-03251-P Document 16 Filed 10/05/12 Page 2 of 15 PageID 499
 
Taitz v Sebelius Reply to Opposition 3
"
Ms. Taitz requests reconsideration of the Court's dismissal of herCommerce
Clause
claim, which asked the Court to declare the recentlyenacted Patient Protection and
Affordable
Care Act, Pub. L. No. 111-148, invalid. Ms. Taitz claims that because President Obama has notproved that he is a natural born citizen, he thus cannot legitimatelysign the bill into law. Additionally, Ms. Taitz asserts that her imminentinjury is sufficient for
standing..."
"while the U.S. Supreme Court has recognized
that
taxpayer standing can besufficient in an Establishment Clause challenge to government action
in
Flast v. Cohen,
392 U.S. 8 (1968), it has refused to create a similar rule forCommerce
Clause
challenges.
 DaimlerChrysler Corp. v. Cuno,
547 U.S. 332,347-49 (2006);
see also Bowen v. Kendrick,
487 U.S. 589, 618 (1988)06.18.10 order by judge Lamberth in Taitz v Obama 10-cv-151 RCR, order onmotion for reconsideration.Upon receiving this ruling, Taitz filed another motion for reconsideration, askingto rule in her favor based on the Establishment clause, however the court ruledthat since she did not bring the Establishment clause in the original complaint, itwould not consider it under rule 60B.
Case 3:12-cv-03251-P Document 16 Filed 10/05/12 Page 3 of 15 PageID 500

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