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Dr. Orly Taitz, Attorney-at-Law29839 Santa Margarita ParkwayRancho Santa Margarita CA 92688Tel: (949) 683-5411; Fax (949) 766-3078California State Bar No.: 223433
E-Mail: dr_taitz@yahoo.com
UNITED STATES DISTRICT COURTFOR THE CENTRAL DISTRICT OF CALIFORNIACaptain Pamela Barnett, et al., §Plaintiffs, §§v. § Civil Action:§Barack Hussein Obama, §
SACV09-00082-DOC-AN
Michelle L.R. Obama, §Hillary Rodham Clinton, Secretary of State, §Robert M. Gates, Secretary of Defense, § Motion for Joseph R. Biden, Vice-President and § Reconsideration of Order toPresident of the Senate, § Dismiss under Rule 59E andDefendants. § Rule 60
Here come all the plaintiffs (aside from plaintiffs Markham Robinson and WilleyDrake represented by Gary Kreep) and motion for reconsideration of October 29
th
order under Rule 59E and Rule 60.1.
A newly discovered fact, material to this action, that was the reason for mosterrors in the order, is the fact that on October 1, 2009 Your Honor hired asyour law clerk an attorney Siddharth Velamoor, who previously worked forPerkins Coie, a law firm representing the defendant in the above case, Mr.Obama. As a matter of fact Perkins Coie was one of the firms representing thedefendants in a prior legal action filed by the
plaintiffs in this very case
,Ambassador Alan Keyes et al against Secretary of State Deborah Bowen andDemocratic party electors
specifically for not vetting Mr. Obama
as a
presidential candidate, as Ms. Bowen didn’t request any vital reco
rds andnever checked any vital records of Mr. Obama, as she and all the othersecretaries of states took his Declaration of a Candidate
on it’s face value
. Asit is a common knowledge that law clerks do most of the research and writemost of the opinions for the judges,
the order to dismiss this case was defacto written or largely influenced by an attorney who until recentlyworked for a firm representing the defendant in this case, and whocurrently is working as a clerk for the presiding judge, as such most of theorder is tainted by bias. This is a clear prejudice against the plaintiffs.
While Mr. Velamoor will surely claim that he didn’t work on Obama case
before, his employment with Pe
rkins Coie should’ve disqualified him, and
indeed the order reads as if it is written by the defense counsel, highly biasedagainst the plaintiffs, 99 percent of the order either misstates the facts or thepleadings or oral argument, it misstates the law and is full of personal attacks,de facto accusing decorated members of the military of being cowards; andthis order is particularly used as a tool in what seems to be a concerted effort
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by this Court and judge Clay D Land in GA to use the power of federal judiciary to publicly lynch the undersigned counsel, to use innuendo, ex partedefamatory and slanderous statements to assassinate her character, to destroyher as a human being and endanger her law license, only because she is notonly the only attorney brave enough to bring most of eligibility legal actions,to bring actions from plaintiffs with real standing, the only one to get anyhearings, but she is also the only one to bring forward evidence from licensedinvestigators showing Mr. Obama committing multiple felonies, for which heshould be serving lengthy prison term. The court erred in hiring Mr.Velamoor or in the alternative not recusing himself from hearing this case.2.
The plaintiffs request the court to strike from the order unsupported andprejudicial verbiage. Please see in the attachment Declaration of theundersigned attorney.3.
The court has stated in the pleadings that the undersigned attorney hasencouraged her supporters to contact the court in an attempt to influence hisdecision in the October 5 hearing. This is not true. The plaintiffs request thisstricken from the final order.4.
During October 5 hearing your honor has stated that the undersigned attorney
encouraged the supporters to attempt to influence the court’s decision. This
never happened. When the undersigned attorney requested to respond, thecourt stated:
“no, no, it’s done. You’ve put it out there. Now it’s your responsibility”. The undersigned attorney has done nothing of a kind and believes that this information might’ve
come from some ex partecommunications with the presiding judge coming from parties connected tothe defense, which is prejudicial, inflammatory and defamatory. Theundersigned requests it stricken from the order.5.
The court has included in the order mention of yet another ex-partecommunication with the judge, where two parties claimed that the undersignedcounsel has asked them to perjure themselves. Please see the declaration, thiswas a slanderous, defamatory, prejudicial allegation, and the undersigned hadno opportunity to respond.6.
The undersigned believes that the letters came from Larry Sinclair and LucasSmith.7.
Larry Sinclair was asked to authenticate an affidavit he submitted to theChicago police regarding the homicide of Mr. Donald Young. In the affidavitsubmitted to the Chicago police and in his book recently published, Mr.Sinclair has stated that Mr. Donald Young has contacted him repeatedly andstated that he had a homosexual relationship with Mr. Barack Obama and thatMr. Young was found dead with multiple gunshot wounds December 23, 2007at the onset of 2008 Democratic primary elections. Any allegations of theundersigned attorney asking the witness to perjure himself are not onlycompletely defamatory and prejudicial, but are void of any sense or reason, as
Mr. Sinclair’s affidavit regarding Mr. Young’s homicide can be found filed
with the Chicago PD and in his book. A copy of the Affidavit of Larry Sinclairand Coroners Certificate of Death of Donald Young is attached as an Exhibit.8.
Luc
as Smith was asked to authenticate Mr. Barack Obama’s birth certificate
from Kenya, which he previously tried to sell on e-bay and which heauthenticated under penalty of perjury both on video camera and in writing. Assuch any allegations of suborning perjury are totally defamatory and void of any sense or reason, since Mr. Smith made this information public long beforeever meeting the undersigned counsel. Therefore any and all allegations of misconduct by the undersigned are totally without merit, prejudicial anddefamatory and need to be stricken from the order.
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9.
The undersigned is the only attorney, who has the bravery of character topursue
not only the issue of Mr. Obama’s illegitimacy to presidency, but also
information provided by two licensed investigators, showing that according toreputable databases
Mr. Obama has used 39 different social securitynumbers including the social security numbers of the deceasedindividuals
. This information is an indication of multiple felonies committedby the sitting president, and the undersigned believes that she was targeted anddefamatory statements were used in order to keep her silent, to endanger herlicense and prevent her from proceeding on the above issues. The undersignedis deeply concerned about the fact that the court chose to include in the orderslanderous ex-parte communications, while completely ignoring the aboveevidence against the defendant, which show a tremendous likelihood of success on a RICO claim.10.
The court has commented on the plaintiff
s’
inability to file a full pledgedRICO complaint, calling it inexcusable. The court apparently forgot the factthat the plaintiffs have asked for discovery in order to obtain sufficientinformation for complete RICO complaint.
The court has denied all requestsfor discovery, therefore making it impossible for the plaintiffs to submitfully pleaded RICO cause of action.
The plaintiffs request discovery in orderto submit a properly plead RICO complaint or in the alternative a leave of court to file a second amended complaint on RICO cause of action.11.
The court relies on Ashwander vs Tenn Valley, as the reason to assert that ithas no jurisdiction. This is a mistake of fact and a mistake of law. As
Ashwander states “If a case can be decided on either of two g
rounds, oneinvolving a constitutional question, the other a question of statutory
construction of general law, the Court will decide only the latter”.
The fact of the matter is that there is no law or statute,that provides definition of theNatural Born Citizen clause. The defense has argued a definition completelydifferent from the definition submitted by the plaintiffs, therefore in theabsence of any law or statute providing such definition Aswander actuallydictates that the issue
needs to be decided based on the Constitution
.
Central district court of California clearly has a right to interpret theConstitution
, so based on the courts
own argument
the case has to be
adjudicated. “With whatever doubts, with whatever difficulties, a case may be
attended, we must decide it, if it is brought before us. We have no more rightto decline the exercise of jurisdiction which is given, than to usurp that which
is not given. The one or the other would be treason to the constitution”
Supreme Court justice John Marshall in Cohen v Virginia 19 US 264 (1821).12.
The undersigned counsel requests the court to strike out of the orderunsupported, prejudicial, demeaning and defamatory language p8, line 22-24insinuating that the military plaintiffs in this action are cowards and writing:
“The court will not interfere in internal military affairs nor be used as a tool by
military officers to avoid deployment. The court has a word for such a refusalto follow the orders of the President of the United States, but it will leave the
issue to the military to resolve”. The undersigned has submitted to this court a
letter from Captain Crawford, Legal Counsel to Admiral Malin, Chairman of Joint Chiefs of Staff, which clearly stated that the commander in Chief isconsidered a civilian and there is nothing military can do regarding hiseligibility. Based on this response from the military the plaintiffs havebrought this matter to the Federal court to ascertain legitimacy and allegianceof the Commander in Chief, who is not a part of the military. The ordercompletely misstated the complaint and standing justification. Recent terroristincident at Fort Hood has given this question paramount importance. Thisorder has advocated blind obedience by the members of the military. If
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