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Kristi Noem lawsuit

Kristi Noem lawsuit

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Published by ArgusJHult
Lawsuit against Kristi Noem from Watertown resident Charles Haan.
Lawsuit against Kristi Noem from Watertown resident Charles Haan.

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Published by: ArgusJHult on Mar 29, 2013
Copyright:Attribution Non-commercial

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03/29/2013

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EXHIBIT
B
Case 1:13-cv-01009-CBK Document 1-2 Filed 03/27/13 Page 1 of 4 PageID #: 8
 
STATE
OF
SOUTHDAKOTA)
IN
CIRCUIT
COURT
:SS
COUNTY
OF
CODINGTON)
THIRD
JUDICIAL
CIRCUIT
jt**********************************************
CHARLES
W.
HAAN,
Constituent
)
CIV.
FILE
\^-l3,to
)
Plaintiff,
)
)
vs.
)
COMPLAINT
)
KRISTINOEM,
US
Congressperson
)
)
Defendant
)
)
***********************************************
COMES
NOW,
the
Plaintiff,
Charles
W.
Haan,
and
complainsand
alleges
as
follows:
1.
In2010,
the
Defendant
campaigned
forelectionto
the
US
House
of
Representatives
making
various
promisesandcommitments.
2.
In
November,
2010,
the
Defendant
was
elected
to
the
US
House
of
Representatives.
3.
InJanuary2011,the
Defendanttook
an
Oath,
"I
do
solemnly
swear
(oraffirm)that
I
will
support
and
defend
theConstitution
of
the
United
States
against
all
enemies,
foreign,
and
domestic;
that
I
will
bear
truefaith
and
allegiance
to
the
same;
that
I
take
this
obligation
freely,
without
anymental
reservation
or
purpose
of
evasion;
and
that
I
will
well
and
truthfully
dischargethe
duties
of
the
office
on
which
I
am
about
to
enter:
So
help
me
God.".
4.
The
Defendant
has
breached
theOath,the
contract,
in
failing
to
use
theauthorityvested
in
the
Defendant
toconsistently,
vigorously,
aggressively,
and
diligently
propose,
write,
and
introduce
Legislation:
(1
of
3)
Case 1:13-cv-01009-CBK Document 1-2 Filed 03/27/13 Page 2 of 4 PageID #: 9
 
a.
to
end
the
Federal
funding
ofPlanned
Parenthood;
b.
to
end
the
Federalfunding
of
embryonic
stem
cell
research;
c.
to
stopthe
killing
of
the
unborn;
d.
to
stopthe
implementationof
thePatientProtection
and
the
Affordable
Care
Act;
and
e.
to
stoptheunconstitutional
redistribution
ofincomes
in
variousforms,
i.e.
granting
money
toreligiousorganizations,
continuing
the
food
stamp
program,
etc.
5.
The
Defendant
has
broken
her
promises,
contract,in
voting
for
certain
Legislation:
a.
continuing
resolutions;
b.
to
raise
taxes;
and
c.
to
raise
the
debt
ceiling.
6.
The
Plaintiff
reservesthe
rightto
raise
other
failures
of
the
Defendant
thatare
not
delineatedabove.
THEREFORE,
the
Plaintiff
seeksredress
of
the
grievances
listed
herein
as
perthe
First
Amendment
tothe
US
Constitution
that
the
Defendant
should
be
Ordered
to
resign,
or,
to
be
removedfrom
Office
as
a
US
Congressperson.
Dated
at
Watertown,
South
Dakotaon
the
cfcxh^g
day
of
January,
2013
Charles
W.Haan
The
Plaintiff
herein
217
17
Street
SE
Watertown,South
Dakota
57201
(605)
882-3657
(2
of
3)
Case 1:13-cv-01009-CBK Document 1-2 Filed 03/27/13 Page 3 of 4 PageID #: 10

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