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Case 3:12-cv-00036-JAG Document 3-1 Filed 01/23/12 Page 1 of 10 PageID# 62
UNITED STATES DISTRICT COURT
F r t D : : : n : r r : ; - ~ l L - - ~ ~ - " ' " 
~!
ASTERN DISTRICT OF VIRGINIA
l0'
ichmond Division
.23
012
CLERK,
u.s.
DISTRfCT COURTRICHMOND,
VA
CHARLES TISDALEPlaintiff, Pro se
v.
Honorable Barack
H.
Obama, II,
Personally
and
in
his capacity
as
President
of
the
United
States,
and
DON
PALMER,
in
his
officialCapacity
as
Secretary
of
the Virginia State Board
Of
Elections,
and
THE
VIRGINIA STATE
BOARDOF
ELECTIONS,
and
NEIL
H.
MACBRIDE,
in
His
official capacity
as
United States Attorney
for
The Eastern District
of
Virginia, and
THEFEDERAL
ELECTION COMMISSION.
DefendantsSTANDINGCivil Action
MEMORANDUM
OF
LAW
TO
SUPPORT PLAINTIFF'S
CASE
I
me
1-i
Doll.
fi)
"
lJllc\\lVIc\()1I\
_I._Plaintiff
as an Afro-American natural born citizen has Article Three Standingbecause he has and will continue to suffer an invasion
of
a legally protected right underthe First Amendment to petition the government as an aggrieved person. That right is
impeded
by
the highest government office holder (The President
of
the United States)
ineligible to be President under Article Two, Section One, Clause Five
of
the UnitedStates Constitution.
 
Case 3:12-cv-00036-JAG Document 3-1 Filed 01/23/12 Page 2 of 10 PageID# 63
2.
Political decisions from the President effecting United States Citizens under the
14th
Amendment's Constitutional right or privilege to medicare, medicaid,unemployment, foreign policy, acts
of
war, housing, criminal justice as enjoyed bywhite people, must be free from ineligible office holders whose decisions
on
thesematters greatly and adversely effect the due process/equal protection clauses for whichplaintiff is entitled under the
14th
Amendment.
3.
The conditions
of
Plaintiff as an Afro-American and those similarly situatedunder this President and this Congress is so egregious, that it violates the protectionsafforded under the Fourteenth Amendment.
4.
Evidence will show, the President and Congress continue to respond to
an
8.5 to 9per cent national unemployment mte for White America while in total disregard to the22 to 26 per cent unemployment rate in the Afro-American communities, specificallyMecklenburg and Richmond counties
in
Virginia and throughout the nation.
S.
When the President and Congress are in active collusion with the Commonwealth
of
Virginia in denying the most basic freedoms
of
housing opportunities, employmentopportunities, educational opportunities, medical care opportunities, businessopportunities as enjoyed
by
"White People", is deprivation to Afro-Americans.
6.
The President must be
at
minimum eligible to his office under Article Two,Section One. Many federal programs are administered
in
some fashion by the states suchas medicaid, stimulus funds, unemployment,7. Here, in Virginia, the very legitimate state codes intended to protect every
2
 
Case 3:12-cv-00036-JAG Document 3-1 Filed 01/23/12 Page 3 of 10 PageID# 64
citizen regardless
of
color, is denied to Afro_Americans, state codes which protecthousing rights against unlawful evictions, are denied to Afro_Americans, state codeswhich protect criminal and civil justice rights, are denied to Afro-Americans, state codeswhich protect medical care, are denied to Afro-Americans, state codes which protectinsurance benefits, are denied to Afro-Americans, state codes which protectunemployment rights, are denied to Afro-Americans, state codes which protect votingrights, are denied to Afro-Americans, state codes which protect educational rights, aredenied to Afro-Americans, state codes which protect business rights, are denied to AfroAmericans. all without a word or deed
of
challenge from the Obama justice department,8. A natural born citizen who is President would not ignore the unconstitutionaldeprivation to a protected group
of
Americans such as Afro-Americans.
9."
The
14th
Amendment is a federal protection, not a state protection, itsenforcement is to Congress, its violations
of
that enforcement is to the President andthe justice department, the language
of
"No State Shall Make
Or
Enforce Any LawWhich Abridges The Rights
of
Citizens"
.....
, is cognizable under 42
U.S.
C.1983.
10. The President in order to provide the necessary protections
to
Afro-Americansand all Americans, must be a "natural born citizen", it makes certain the President hasno division
of
loyalty to the United States Constitution, which the founding fathersadopted through Article Two, Section One. Thus Petitioner has credible standing as anaggrieved person under 42 U.S.C. 1983 to request this court apply Article Two, SectionOne, Clause Five, appJies to defendants Virginia State Board
of
Elections
.
3
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