MEMORANDUM of COMPLAINT of ELECTION FRAUD against THE HONORABLE

NANCY PELOSI, ACTING in a NON-GOVERNMENTAL ROLE as CHAIR, 2008 DNC

SERVICES CORPORATION (“DNC”) CONVENTION; and ALICE TRAVIS
GERMOND, SECRETARY, DNC; and REQUEST for INVESTIGATION by GEORGIA
ATTORNEY GENERAL

To: Thurbert E. Baker, Attorney General of Georgia

VIA FAX: 404.657.8733
From:

Subject: Complaint of Election Fraud against The Honorable Nancy Pelosi,

Acting in a Non-Governmental Role as Chair, 2008 DNC Services
Corporation (“DNC”) Convention; and Alice Travis Germond,
Secretary, DNC; and Request for Investigation by Attorney
General of Georgia
Date: March 5, 2010
Copies: The Honorable Nancy Pelosi, Speaker of the U.S. House of
Representatives
Alice Travis Germond, DNC
Karen C. Handel, Secretary of State

PURPOSE OF CONTACT

This is a formal complaint of election fraud against The Honorable Nancy Pelosi,
Speaker of the U.S. House of Representatives acting in the non-governmental role of
Chair, 2008 DNC Convention; and Alice Travis Germond, Secretary, DNC; and request
for investigation by the Office of Attorney General of Georgia.

Specifically, under Georgia law, in order to have state election officials print the name of
any candidate on our primary or general election ballots, s/he must be qualified for the
job. Under Article II, Section 1, of the U.S. Constitution, the President of the United
States (“POTUS”) must be a Natural Born Citizen (“NBC”). To get Barack Obama‟s
name on the general election ballot, Ms. Pelosi formally submitted to the Georgia Board
of Elections the Official DNC Certificate of Nomination signed by her and Ms. Germond
swearing Mr. Obama was “duly nominated” as the candidate for POTUS for the
Democratic Party and had met the legal qualifications for the job. However,
overwhelming circumstantial evidence points to the fact at the time they signed and
forwarded this Certification, neither of them could have ascertained Mr. Obama is a
NBC. And in Georgia, swearing to election officials he is a NBC without ascertaining he
is, in order to secure a place on the ballot, constitutes election fraud.

Citizens from several states, concerned that members of the Democratic Party had
submitted to their state election officials these unauthenticated Certificates of
Nomination, contacted the DNC requesting to see the documentation on which they had
MEMORANDUM of COMPLAINT of ELECTION FRAUD against NANCY PELOSI and ALICE GERMOND
March 5, 2010
Page 2 of 6

based this Certification. Ms. Pelosi ignored all such requests. Mr. Sandler, claiming he
was responding to requests that were directed to Ms. Germond, said, “The Democratic
National Committee is not a state agency subject to the open records or freedom of
information statutes of any state.” http://jbjd.wordpress.com/2009/09/20/the-cheese-
stands-alone/ And based on the fact, no law required him to produce the requested
documentation; he chose not to produce this documentation.

Such display of hubris by members of any political party confronted by citizens

concerned as to the legitimacy of the electoral process cannot be tolerated in our
Constitutional Republic.

Candidates representing the DNC Services Corporation may not participate in the
election process carried out in the state of Georgia on behalf of the citizens of
this state unless they obey our rules. And if our state law is to operate as anything
more than form with no function, the state must now compel this political party to
produce the evidence that was the basis for its Certification to Georgia election officials
that Barack Obama, the party‟s nominee for President, satisfied those laws requiring the
candidate to be qualified for the job. Absent such evidence, it appears that by Certifying
such qualification, Mmes Pelosi and Germond have perpetrated election fraud on the
citizens of Georgia.

WHEREFORE, I request an immediate investigation by the Attorney General of

Georgia.

(Note: This Complaint takes no position on whether Mr. Obama is a NBC.)

RATIONALE

1. Under the Official Code of GA Annotated (O.C.G.A.), §21-2-5, Qualifications

of candidates for federal and state office; determination of qualifications,
(a): “Every candidate for federal and state office who is certified by the
state executive committee of a political party … shall meet the
constitutional and statutory qualifications for holding the office being
sought.” Article II, section 1 of the U.S. Constitution requires the POTUS
must be a Natural Born Citizen.

Thus, in order to satisfy federal requirements for POTUS that would entitle Mr.
Obama‟s name to be printed on the Georgia general election ballot, he must be a
NBC.

2. The Honorable Nancy Pelosi, Chair, 2008 DNC Convention, submitted a

Certification of Nomination dated August 28, 2008 and signed by her and
Alice Germond, to Georgia elections officials swearing Barack Obama was
the “duly nominated” candidate for POTUS of the Democratic Party
verifying he is qualified for the job, to get those officials to print his name
on the general election ballot.
MEMORANDUM of COMPLAINT of ELECTION FRAUD against NANCY PELOSI and ALICE GERMOND
March 5, 2010
Page 3 of 6

The rules of the Democratic National Committee require the nominee must be
qualified under the U.S. Constitution.
http://s3.amazonaws.com/apache.3cdn.net/3e5b3bfa1c1718d07f_6rm6bhyc4.pdf
(p.14, K.1 and 2). Article II, section 1 of the U.S. Constitution requires that the
POTUS must be a Natural Born Citizen. Thus, Certifying Barack Obama has
been duly nominated as the Democratic Party candidate for POTUS was
tantamount to verifying, he is Constitutionally qualified for the job, which means,
he is a NBC.

State lawmakers failed to enact legislation that would require any state actor to
check on the nominee‟s qualifications. And they expressly excluded from
appearing on the ballot any candidate not qualified for the office sought. Thus,
the express meaning of legislation requiring candidate qualification is clear: if the
party gives us the name of its nominee for POTUS to be printed on the general
election ballot then, we must assume the party has previously determined this
person is Constitutionally qualified for the job.

(Note: Hawaii Revised Statutes §11-113 requires the party to Certify their
nominee is Constitutionally qualified for the job, to get his name on the ballot. So
the DNC added this line to the Certification of Nomination submitted to election
officials in that state: Barack Obama is “legally qualified to serve under the
provisions of the United States Constitution.”
http://jbjd.wordpress.com/2009/08/13/if-drowning-out-opposing-facts-is-un-
american-then-ignoring-unpleasant-facts-must-be-un-american-too/)
*http://jbjd.wordpress.com/2009/08/28/never-less-than-a-treason-2-of-2/

3. Mmes Pelosi and Germond could not have ascertained Barack Obama is a
NBC at any time prior to August 27, 2008, the date on the Official DNC
Certification of Nomination submitted to Georgia election officials verifying
he was a qualified candidate given the fact at this same time, he insisted
the evidence proffered to establish his Constitutional qualification for
POTUS “prove[d]” he is only a “native citizen” but not a NBC.

Explicitly acknowledging public doubts whether he is a NBC, in June 2008 Mr.

Obama created and paid for a web site entitled, “Fight the Smears” (“FTS”), on
which he posted a photocopy of a document entitled, “Certification of Live Birth”
(“COLB”) from the State of HI. http://fightthesmears.com/articles/5/birthcertificate
Mr. Obama proclaimed this photocopied Certification proves he is a “native
citizen of the United States of America.” (While the actual title that appears
within the document identifies this is a “Certification,” Mr. Obama wrote
underneath the image, this is his “Official Birth Certificate.”)

(Note: While the text of FTS pertaining to Mr. Obama‟s qualification for POTUS
remains the same, the footer of the page changes. In the original version, the
MEMORANDUM of COMPLAINT of ELECTION FRAUD against NANCY PELOSI and ALICE GERMOND
March 5, 2010
Page 4 of 6

footer read, “Paid for by Barack Obama 2008.” Subsequently, the footer was
altered to read, “Paid for by Obama for America”; which was then changed to
read, “Paid for by Organizing for America, a Project of the Democratic National
Committee.” This remains its current iteration. Also, at various times, the site
address appeared as either a .com or, a .org.)

4. Mmes Pelosi and Germond could not have ascertained Barack Obama is a
NBC prior to August 27, 2008, the date on the Official DNC Certification of
Nomination submitted to Georgia elections officials verifying he was a NBC
based on that internet COLB given the fact that 4 (four) months later, in
January 2009, Defendant Obama repeated in pleadings he submitted to the
federal court, the best evidence he was born in HI is the original document
of that FTS COLB; yet he failed to submit this „original‟ COLB to the Clerk
of the Court to be marked up as evidence and made a part of the official
court record.

In January 2009, Mr. Obama was the named Defendant in a case filed in federal
district court, ostensibly seeking to determine whether the Uniform Code of
Military Justice required a military Plaintiff to obey orders from a Commander in
Chief he was not certain was a NBC. (Pleadings for Hollister v. Soetoro, Civil
Action No. 1:08-cv-02254-JR, can be found on line at
http://jbjd.wordpress.com/2009/08/09/rumors-lies-and-unsubstantiated-facts/.)
Mr. Obama submitted a Motion to Dismiss predicated on Plaintiff‟s failure to
establish the Court's jurisdiction; and to state a claim upon which relief can be
granted. (The Defendant was represented by Attorney Robert F. Bauer of
PERKINS COIE LLP, who signed the pleadings submitted to the court on his
client‟s behalf.) Additionally, Mr. Obama asked the court to take judicial notice of
the following „fact‟: he had publicly produced a certified copy of a birth certificate
showing that he was born on August 4, 1961, in Honolulu, Hawaii. (Presumably,
he used the phrase “publicly produced” referring to the fact, he posted that
photocopied COLB on his FTS web site.) Yet he did not provide the court with
the „original‟ COLB so the Clerk could mark up the document as evidence and
place it in the case record (where it would be subject to scrutiny by the Plaintiff or
the judge‟s in-camera inspection). Instead, he tried to authenticate that internet
COLB just by asking the court to take “notice” that Annenberg Political Fact
Check (“APFC”) “conclude[d] that the birth certificate is genuine.”
http://jbjd.wordpress.com/2009/08/09/rumors-lies-and-unsubstantiated-facts/
(APFC is one of many such organizations wholly funded by the Annenberg
Foundation, which also paid his salary as Chair of the Chicago Annenberg
Challenge from 1995-1999.) (And recall he wrote on FTS, this COLB only
establishes he is a “native citizen,” anyway.)

Given the fact that 2008 DNC Convention Chair Pelosi is also the Speaker of the
U.S. House of Representatives, making her 3rd in line of Presidential succession,
with all of the gravitas incorporated therein, it defies credulity that Mr. Obama
would seek judicial notice of the lesser fact he is a native citing APFC says he is;
MEMORANDUM of COMPLAINT of ELECTION FRAUD against NANCY PELOSI and ALICE GERMOND
March 5, 2010
Page 5 of 6

but not offer into evidence the DNC Official Certification of Nomination Ms. Pelosi
submitted to election officials in the state of HI, swearing Barack Obama is
“legally qualified to serve under the provisions of the United States Constitution,”
or any one of the dozens of her signed Certifications, which persuaded election
officials throughout the country to print the name of Barack Obama next to the D
on the Presidential ballots in the 2008 general election.

Eschewing reliance on Ms. Pelosi‟s Certification, incredibly, Mr. Obama asked

the court to take judicial notice of this information: APFC “note[d] a
contemporaneous birth announcement published in a Honolulu newspaper.” In
fact, APFC had only posted on their web site an image of an unattributed
„newspaper announcement,‟ which phantom image they admitted they had
usurped from the “td” blog, where it was posted anonymously. (Note: the “td”
TexasDarlin blog site was closed by its owner in August 2009.) With no further
investigation into that „announcement,‟ APFC declared, “The evidence is clear:
Barack Obama was born in the U.S.A.” http://www.factcheck.org/elections-
2008/born_in_the_usa.html) Like APFC, Defendant Obama omitted the name of
this publication. And he failed to enter into the court record any physical
evidence of a newspaper announcement, making his claims there was such an
announcement, as with his claims the internet COLB was real, impossible to
verify, too.

5. Mmes Pelosi and Germond could not have ascertained Barack Obama is a
NBC prior to August 27, 2008, the date on the Certification submitted to
Georgia elections officials verifying he was a NBC given the fact that as of
August 2009, a year after submitting this Certification, the DNC advertised
Mr. Obama is a “native citizen” but not a NBC.

A Google ad appearing on the internet in August 2009 asks this intriguing

question followed by the answer: “Where was Obama Born? The President was
Born in Hawaii. Learn More! www.FightTheSmears.com .”
http://pages.suddenlink.net/tristanne/turks.png
Following the link provided in the ad takes you to a version of FTS which,
according to the attribution in the footer, is “Paid for by Organizing for America, a
Project of the Democratic National Committee.” Again, the FTS site only claims
Mr. Obama is a native, not a NBC. And, again, the web site displays the image
of that Certification which Mr. Obama had only described to the court thereby
eliminating the possibility of an „in-camera‟ inspection.

CONCLUSION

Georgia law requires candidates for public office whose names appear on any election
ballot must be qualified for the job. Officials of the Democratic Party Certified to
Georgia election officials Barack Obama was qualified for the job of POTUS, causing
these officials to print his name on the general election ballot. But the scant evidence
available in the public record at the time of this Certification failed to establish he is a
MEMORANDUM of COMPLAINT of ELECTION FRAUD against NANCY PELOSI and ALICE GERMOND
March 5, 2010
Page 6 of 6

NBC (or even that he is a citizen). Citizens concerned the Democratic Party Certified
Mr. Obama‟s qualifications without verification asked the party to disclose the basis for
their Certification. The party said, „No.‟ Therefore, the AG must now intervene on the
citizens‟ behalf to investigate these charges of election fraud.