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TAITZ v OBAMA (QW) - 30 - SUPPLEMENTAL MEMORANDUM - gov.uscourts.dcd.140567.30.0

TAITZ v OBAMA (QW) - 30 - SUPPLEMENTAL MEMORANDUM - gov.uscourts.dcd.140567.30.0

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Published by Jack Ryan
05/24/2010 30 SUPPLEMENTAL MEMORANDUM to re 29 Reply to opposition to Motion filed by ORLY TAITZ. (Attachments: # 1[RECAP] Exhibit 05.18.10 letter from SSA, # 2 Exhibit 05.19.10 Death threat)(TAITZ, ORLY) (Entered: 05/24/2010)
05/24/2010 30 SUPPLEMENTAL MEMORANDUM to re 29 Reply to opposition to Motion filed by ORLY TAITZ. (Attachments: # 1[RECAP] Exhibit 05.18.10 letter from SSA, # 2 Exhibit 05.19.10 Death threat)(TAITZ, ORLY) (Entered: 05/24/2010)

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Categories:Types, Research, Law
Published by: Jack Ryan on May 24, 2010
Copyright:Attribution Non-commercial

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06/02/2010

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Case
1:
10-cv-00151-RCL Document 30 Filed
OS/24/10
Page 1
of
7
Dr. Orly Taitz, esq29839 Santa Margarita Parkway, STE 100Rancho Santa Margarita CA 92688Tel: (949) 683-5411; Fax (949) 766-7603
E-Mail:
drtaitz@yahoo.com
UNITED
STATES
DISTRICT COURT
FOR
THE
DISTRICT OF
COLUMBIA
Dr.
ORL
Y T AITZ, ESQ,
PRO
SEPlaintiff,
v.
Barack Hussein
Obama,Defendant.Your Honor,
§
§HONORABLE ROYCE LAMBERTH
§
PRESIDING
§
Civil Action: 10-151
RCL
§
§
ADDENDUM TO REPL
Y
TO
§
OPPOSITION
TO
MOTION
§
FOR
RECONSIDERATION
§§§§§
Part
of
the complaint
in
this action is a
FOIA
request.
Mr.
Obama, defendant inthis case,
via
US
attorney's office sought dismissal
of
a
FOIA
request due to the fact
that
the refusal
of
information request by the Social Security administration was
not
final. Your
Honor
initially agreed, stating
that
the response from the Social Securityadministration was
not
final. Until
now
Taitz could
not
obtain a response from SSN,stating that it is a final decision.Yesterday Taitz received a letter from Jonathan R. Cantor, Executive Director
of
Office
of
Privacy
and
Disclosure
of
the Social Security Administration dated andsigned
May
18, 2010. (Exhibit 1 Letter and envelope)
As
a stroke
of
providence theletter states "This is our final decision
in
this matter.
If
you
still believe the decisionis incorrect, however, the
law
permits
you
to seek review in a district court
of
theUnited States".
Taitz v Obama. Addendum to Reply to Motion for reconsideration
1
 
12
Case
1:
10-cv-00151-RCL Document 30 Filed
OS/24/10
Page 2
of
7
3 As such an impediment was lifted, and the Plaintiff respectfully requests this4 Honorable court to grant her motion for reconsideration, so that the matter can be5 heard
on
the merits.6 Legal Argument7
In
regards to the content
of
the response from the Social Security Administration,8 it relies
on
the finding
of
Department
of
Justice
v.
Reporters Committee for Freedom9
ofthe
Press, 489 U.S. 749 (1989).
10
It concedes following points:
11
1.
Under 5U.S.C. §552(b)(6) exemption from the FOIA Taitz can obtain
12
Obama's application for the Social Security without Obama's consent,
if
other
19
conditions are fulfilled.
20
2.
Social security or court cannot consider the identity
of
the requester-therefore
21
the court cannot deny Taitz request due to her lack
of
standing or lack
of
22
particularized injury
23
3.
Social Security or courts cannot consider the purpose for which the person
24
requests the information.
25
4.
Social security administration is obligated to provide information,
ifthere
is a
26
public interest in knowing
how
SSA administers the Social Security Act.
27
5.
The only objection to Taitz request by the SSA, is their claim that "disclosure
28
of
records containing personal information about President Obama would notshed light
onhow
the agency performs its statutory duties". This is the reasonSSA provides as justification for their refusal to provide the information inquestion.
6.
Taitz appeals this decision on following grounds:
a.
Official on line records
of
Selective service confirm that Barack Obama hasbeen using SS number_4425.
Taitz v Obama. Addendum to Reply to Motion for reconsideration
2
 
12
Case
1:
10-cv-00151-RCL Document 30 Filed
OS/24/10
Page 3
of
7
3 b. Information requested does not represent
personal information
of
Mr.
4
Obama, but rather personal information
of
another individual born in
5
1890, who would have been 120 years old, who is most probably deceased,
6
but whose death was either never reported
to
the Social Security
7
Administration or was deleted from the records
of
the Social Security
8
Administration prior
or
around 1986, and the number was unlawfully
9
assumed by Mr. Obama.
According to previously submitted sworn affidavit
10
of
recently retired senior deportation officer with the department
of
Homeland
11
Security
Mr.
John Sampson, this Social Security number was issued to another
12
individual in the state
of
Connecticut between 1976-1977, while Obama never
19
resided there.
20
c.
One
of
the printouts provided by
Mr.
Sampson show
Mr.
Obama's
origin
in
21
Equatorial Guiney, which is different from the official information stating his
22
origin to be Hawaii and Kenya.
23
d.
According to previously submitted sworn affidavit from Susan Daniels,
24
licensed private investigator, certified by the Department
of
Homeland
25
Security, this Social Security number was issued
in
the state
of
Connecticut
26
between 1976-1977, to an individual born
in
1890. As
Mr.
Obama never
27
resided
in
CT and was not born in 1890, Ms. Daniels concludes that this is not
28
his SS number. Ms. Daniels provided a follow up report, showing thataccording to multiple national databases there are numerous Social Securitynumbersconnected to name Barack Obama and Michelle Obama, none
of
which were issued
in
Hawaii.
e.
According to memoirs by
Mr.
Obama, such as Dreams From
My
Father
Mr.
Obama started working
in
Baskin Robbins store
in
Honolulu HI around 1975-
Taitz v Obama. Addendum to Reply to Motion for reconsideration
3

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