Case 1:10-cv-00151-RCL Document 25 Filed 04/27/10 Page 1 of 8

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3 Dr. Orly Taitz, esq.
29839 Santa Margarita Parkway, STE 100
4 Rancho Santa Margarita CA 92688
Tel: (949) 683-5411; Fax (949) 766-7603
5 E-Mail: dr_taitz@yahoo.com
6 UNITED STATES DISTRICT COURT
7 FOR THE DISTRICT OF COLUMBIA

8 Dr. ORLY TAITZ, ESQ, PRO SE §

Plaintiff, §HONORABLE ROYCE LAMBERTH
9 § PRESIDING
v. § Civil Action: 10-151 RCL
10 § MOTION FOR
Barack Hussein Obama, § RECONSIDERATION
11 § MOTION FOR LEAVE OF COURT
§ TO FILE A SECOND AMENDED
12 § COMPLAINT WITH
§ PRESIDENTIAL CANDIDATE
19 § AND VICE PRESIDENTIAL
20 Defendant. § CANDIDATE ON THE BALLOT
§ IN 2008 ELECTION AS
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ADDITIONAL PLAINTIFFS
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MOTION: REQUEST TO FORWARD TO THE ATTORNEY GENERAL ERIC
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HOLDER REQUEST FOR APPOINTMENT OF A SPECIAL PROSECUTOR TO
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INVESTIGATE AND PROSECUTE MULTIPLE ACTS OF SOCIAL SECURITY
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FRAUD, PERJURY, IDENTITY THEFT, FRAUD AND OTHER POSSIBLE
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FELONIES PERPETRATED BY MR. BARACK HUSSEIN OBAMA.
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ORAL ARGUMENT REQUESTED AS MATTERS OF LAW AND FACT
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ARE AT ISSUE

YOUR HONOR,
Plaintiff would like to start this motion for reconsideration with reference to your
remark in your latest order regarding Plaintiff’s quixotic quest.

Taitz v Obama. Motion for reconsideration, motion for leave of court to file second amended

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3 who never provided any vital records that would be admitted in any court of law, and
4 who does not even possess a valid long form birth certificate with the name of a
5 doctor, name of a hospital and signatures; who has allegiance to three other Nations
6 and god knows who else. Plaintiff is not asking your Honor to tilt windmills, but
7 rather uphold the US Constitution, that your Honor took an oath to protect.
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9 Motion: Request to Forward to the Attorney General Eric Holder for
10 appointment of a special prosecutor to investigate and prosecute multiple acts of
11 Social Security Fraud, Perjury, Identity Theft, Fraud and other possible
12 felonies perpetrated by Mr. Barack Hussein Obama.
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20 On 12/21/94, when your Honor reviewed evidence presented and found that Mr.
21 Ira Magaziner has committed perjury, your honor contacted Eric Holder, prosecutor
22 at that time, and asked him to start an investigation of Mr. Magaziner for perjury and
23 criminal contempt. Your honor also asked Attorney General Janet Reno to appoint an
24 independent counsel to investigate the affair. According to the US Constitution,
25 nobody is above the law. Millions of American citizens are following this case, as
26 are Millions around the World. Even if your Honor does not find injuries sustained
27 by the Plaintiff to be sufficient and the connection to Barack Hussein Obama to be
28 strong enough, your Honor clearly has seen evidence of numerous felonies
committed by Barack Hussein Obama:
1. Social Security Fraud 42 USC §408 (a)(7)(B), which is punishable under title
18 with up to 5 years in prison for each offense (Investigator Sankey shows
some 39 different Social security numbers used);
2. Conspiracy to defraud the United States 18 USC §371, which carries up to five
years in prison for each offense;

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3 3. Perjury 18 USC §1621 with up to five years in prison for each offense
4 There are other crimes committed such as elections fraud, voter fraud, identity
5 theft, that any other US citizen would have been convicted of and serving a lengthy
6 prison term for the above crimes. Plaintiff is asking your Honor for equal treatment
7 of the law for Mr. Obama, just as your Honor has treated other parties and any other
8 citizen, and to forward the request to the US Attorney’s Office and Attorney General
9 Eric Holder for appointment of a special prosecutor to investigate multiple felonies
10 perpetrated by Mr. Obama.
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12 Motion for leave of court to file a second amended complaint with two
19 additional plaintiffs: Presidential candidate from American Independent Party
20 on the 2008 ballot Ambassador Dr. Alan Keyes, and Vice Presidential
21 Candidate on the ballot in 2008 election Gail Lightfoot.
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Motion for reconsideration is allowed when there is an error of fact or law. While
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typically Quo Warranto is utilized by interested parties, who challenge the franchise
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25 of the government, §16-3502, does not specifically limit quo warranto to such
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parties, whereby Your Honor is not statutorily precluded from granting Taitz Quo
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Warranto.
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§ 16-3502. Parties who may institute; ex rel. proceedings.

The Attorney General of the United States or the United States attorney may
institute a proceeding pursuant to this subchapter on his own motion or on the
relation of a third person. The writ may not be issued on the relation of a third
person except by leave of the court, to be applied for by the relator, by a petition
duly verified setting forth the grounds of the application…

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3 As an attorney for plaintiffs, Keyes, Lightfoot and others, Taitz has submitted
4 Quo Warranto requests to the Attorney General and US Attorney, who have not
5 responded. Therefore, Taitz is asking for leave of the Court to proceed under Quo
6 Warranto, and in case your Honor does not grant Quo Warranto to the Plaintiff, she
7 moves for Leave of Court to file a Second Amended Complaint with two additional
8 plaintiffs: Presidential candidate from American Independent Party in 2008 election
9 Ambassador Dr. Alan Keyes, as well as Gail Lightfoot, a Vice Presidential candidate
10 for a write in Presidential Candidate Ron Paul.
11 Additionally, Ambassador Keyes was a senatorial candidate in the state of
12 Illinois. Plaintiff previously submitted to this Court the March 25th Official report of
19 the National Assembly of Kenya. Page 31 of the report contains a statement of the
20 minister of Lands James Orengo, clearly indicating Mr. Obama was born in Kenya,
21 and there is no evidence of Mr. Obama going through proper immigration procedures
22 after his birth. As such, not only is Mr. Obama’s Natural Born status in question, but
23 his citizenship in general is in question, and whereby, Ambassador Keyes has
24 suffered particularized damage in losing both the senatorial and presidential elections
25 to one who is not entitled to hold office, which indicates clear standing.
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27 Motion for this Honorable court to grant Plaintiff sua sponte admission to
28 US District Court bar without local attorney movant.

Typically, admission to this court requires a sponsor/movant local attorney or a

local counsel for pro Hac Vice. Due to the sense of fear associated with a legal
action, implicating a sitting president, the damage by slander and libel of Taitz has
chilled the opportunity to secure a local attorney as a pro Hac Vice movant; however
Your Honor can authorize her acceptance to the court Sua Sponte without such pro

Taitz v Obama. Motion for reconsideration, motion for leave of court to file second amended

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3 hac vice movant. She requests Sua Sponte authorization of acceptance to this bar in
4 order to represent above mentioned additional plaintiffs and opportunity to file a
5 Second Amended Complaint on their behalf.
6 Commerce Clause claims
7 Your Honor has stated that the First Amended Complaint was filed prior to
8 Patient Protection Act being signed into law, which signifies lack of standing.
9 However, standing exists not only in relation to current injury; it exists in relation to
10 imminent injury as well. Taitz has filed her First Amended complaint after the bill
11 was approved by both houses of Congress and the injury was imminent, which
12 suffice for standing. In the alternative Taitz is seeking a leave of Court to file a
19 Second amended Complaint based on Amended Patient Protection Act, since the
20 original act was modified through the process of reconciliation in Senate and House
21 of Representatives, wherefore making any complaint in regards to the initial Patient
22 Protection Act, moot.
23 FOIA relief
24 Your Honor has stated that the FOIA complaint has failed since Taitz did not wait
25 until April 9th for the administrative remedies to be exhausted. As there was no
26 response to the FOIA request by April 9 th and none was received by today, April
27 26th, Taitz is moving this Honorable court for a leave of court to file a Second
28 Amended Complaint for FOIA relief, due to the fact that by today, April 26th
administrative remedies were exhausted and no relief was provided.

Fraud and RICO claims

Similarly, Taitz is seeking a leave of court to file a second amended complaint on
these causes of action, more fully pleading reliance and damages based on 10th, 9th,

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3 5th and 1st amendment with reference to the pattern of multiple crimes with more
4 than two predicate acts of the enterprise, as well as more fully plead standing on the
5 issues of fraud in relation to her Taxpayer standing and her Whistleblower status.
6 /s/ DR ORLY TAITZ ESQ
7 By:__________________________________
Dr. Orly Taitz, Esq. (California Bar 223433)
8 Attorney for the Plaintiffs
9 29839 Santa Margarita Parkway ste 100
Rancho Santa Margarita CA 92688
10 Tel.: 949-683-5411; Fax: 949-766-7603
E-Mail: dr_taitz@yahoo.com
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PROOF OF SERVICE

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3 I CERTIFY THAT TRUE AND CORRECT COPY OF THE ABOVE
4 PLEADINGS WAS SERVED on 04.26.10. on
5 Alan Burch, Assistant United States Attorney for the District of Columbia
6 555 4th Street, N.W.
7 Washington D.C. 20530
8 /s/Orly Taitz
9 Dr. Orly Taitz Esq.
10 29839 Santa Margarita PKWY
Rancho Santa Margarita CA 92688
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