BEFORE THE FEDERAL COURT OF C. UCI: 6182-2763 RPD File: TB9-00570 Applicant NOAH, Saad Sadoon Respondents TRB, Date of Hearing: August 6, 2021 Panel Tyler Nicholson APPLICATION FOR LEAVE TO APPEAL, THIS IS A NOVEL CASE WITH NOVEL ISSUES AND FACTUAL BACKGROUND FROM MANY COUNTRIES IN THREE CONTINENTS INTRODUCTION 1, The Applicant Saad Sadoon NOAH (NOAH) is filing his Application for leave to Appeal to the Honorable Court from the decision of the IRB on August 6, 2021, IRB and the reason] which is an Intemational Crime by through the IRB. The dec the ASSASSINATION of NOAH’s CHARACTER and LIBEL in the Canadian Government's attempt to ASSASSINATE NOAH’s person and/or makes him disappear. FACTUAL BACKGROUND 2. On September 12, 2018, NOAH entered Sprague, Manitoba, Canada on September 12, 2018, while he was (a) A Stateless Deportable/Inadmissible Alien in the United States by the SECRET order of Obama-Biden, who ILLEGALLY held NOAH a HOSTAGE/POLITICAL PRISONER in NYC Rikers Island Prison NY, USA in violation of, inter alia, Title 8 USC §1182. Inadmissible aliens. See [Exhibit November 3, 2001, US DHS Form 1.213, NYC] However, Member is DISABLED to DISCERN REALITY. (b) Furthermore, Obama-Biden SECRETLY and ILLEGALLY Transported NOAH from NYC, to Joliet, Ilinois and again ordered that NOAH be held a HOSTAGE/POLITICAL PRISONER with the Disposition/Order that NOAH is “Not Amenable for Removal” from TORTURE in Ilinois USA on January 12, 2011, i violation of, inter alia, Title 8 USC §1182. Inadmissible aliens and in violation of 18 USC §2340(1). [Exhibit January 12, 2011 US DHS Form 1-213 in Chicago]. However, Member is DISABLED to DISCERN REALITY. (©) While Obama-Biden was detaining NOAH a HOSTAGE/POLITICAL PRISONER at Will County Adult Detention Facility (WCADF) in Joliet, Illinois as in NY by the SECRET order of Obama-Biden, NOAH drafied many legal cases, and filed manylawsuits before the United States Courts one of which was on February 14, 2012, NOAH filed a Counter-Claim against an inmate. NOAH’s counter-claim was by adding third parties defendants, the United States et. al., and removed his counter- claim from Will County Circuit Court of the state of Mlinois, to the United States Court for the Northern District of Hlinois, case No. 12 C 1063. [Exhibit February 14, 2012 Counter Claim] However, Member is DISABLED to DISCERN REALITY. (d) Therefore, the United States Court acknowledged that “NOAH has expatriated, while he was in Finland, European Union, and not a citizen of the USA [anymore,] and he was unconstitutionally [ILLEGALLY] and forcibly admitted [by Obama-Biden] into the USA [in the TREASONOUS Acts ‘of Obama-Biden against the Constitution of the USA and against NOAH in violations of, inter alia, Title 8 USC §1182 Inadmissible aliens, and Title 18 USS. Criminal Code CHAPTER 115-TREASON, SEDITION, AND SUBVERSIVE ACTIVITIES] while he was an excludable, and a deportable alien [in the USA] for not having any visa to enter [and remain in] the USA.” [Emphasis added] See [Exhibit of the Notice of Removal of NOAH’s counter-claim to the US Federal Court of February 14, 2012] However, Member is DISABLED to DISCERN REALITY. (e) Therefore, on March 14, 2012, the US Court declared NOAH a Native of Finland but did not order NOAH’s release from the ILLEGAL detention and Tortures by Obama- Biden. [Exhibit the Court's Order of March 14, 2012] However, Member is DISABLED to DISCERN REALITY. (a) On March 18, 2014, while NOAH was still under Torture by the SECRET order of Obama-Biden, who was holding NOAH a HOSTAGE/POLITICAL PRISONER in one of the HIGHEST Security Mental Hospital in Chester, Illinois, and in the last case NOAH for (5) five times filed in the United States Court was before the United States Court for the District of Columbia against Obama-Biden’s Administration, the Honorable Senior Judge Richard J. Leon GRANTED NOAH’s “REQUEST TO PROCEED IN FORMA PAUPERIS” which NOAH filed and signed under the penalty of perjury. [ECE 2] [Exhibit 3.18, 2014 NOAH’s request to proceed in forma pauperis] Therefore, the Court accepted and filed NOAH’s Petition for a Writ of Mandamus and Declaratory Relief against John Kerry, and Janet Napolitano, NOAH’s case, which he filed and signed also under the penalty of perjury was docketed as (NOAH v. Kerry et. al., No, 14-cv-420 District of Columbia) [ECF 1]. In his petition for a Writ of Mandamus NOAH asked the United States Court to order John Kerry to ISSUE NOAH his constitutionally mandated RIGHT of Certificate of Loss of Nationality (CLN) and to order the US DHS to deport NOAH back to Finland, among other things [ECF 1]. See [Exhibit NOAH v Kerry et. al., No 14-cv- 420] (b) On May 5, 2014, and in order not to face NOAH’s response to the US Department of Justice (DOJ), Obama-Biden made another SECRET order ordering NOAH’s Rel from TORTURE in the HIGHEST Security Mental Hospital in Chester Illinois, in the USA [Exhibit May 5, 2014 nolle prosequi of Will County Circuit Court, Illinois, USA], while NOAH was STILL a Deportable/Inadmissible Alien, Present Without Admission (PWA) in the USA, and illegal in the USA since November 1, 2010, uponing NOAH into the USA from Helsinki, Finland by Refoulement , with a REVOKED US Passport, see [Exhibit March 30, 2010, FIS denying NOAH’s Application for Political Asylum] that was after Obama-Biden Kidnapped NOAH from Frankfort, Germany on October 14, 2010, and delivered to the Finnish Border Guard by two FBI Agents. See [Exhibit order of deportation from Frankfurt Germany] (c) Obama-Biden, who were not in touch with reality, they were spaced out thinking that they can against the will of God make NOAH disappear in the USA as Germany, and Finland thought, However, the TRAITOR Obama-Biden were completely DISABLE to face NOAH’s Response in Court to Obama-Biden’s DOS’s TREASONS [ECE 10 and ECF 11] against the Constitution of the United States, and warring against it, by and through DOI’s ENCYCLOPEDIC Criminal Acts such as, but not limited to, OBSTRUCTION of JUSTICE by criminal Omissions of [Exhibit November 3, 2001 US DHS Form 1-213, NYC] and [Exhibit January 12, 2011 US DHS Form 1-213 in Chicago] and by the DOJ’s PERJURIES and FRAUDS, ILLEGALLY holding NOAH under TORTURES, and CONTEMPT of Court by DOJ. [Exhibit May 5, 2014, order of Will County Court of nolle prosequi of the charge of Eavesdropping] (d) Obama-Biden made the charge of Eavesdropping against NOAH through the International crime of the International Criminal State Attorney James Glasgow (Glasgow), who signed the perjurious charge of Eavesdropping against NOAH, while ‘NOAH was in Finland on January 13, 2010. Glasgow fraudulently alleged and PERJURIOUSLY alleged in his charge of Eavesdropping against NOAH stating under oath that NOAH was physically present at and within Will County, Illinois, USA on January 13, 2010, [Exhibit AFR] and see NOAR’s Petition for a Writ of Habeas Corpus before the United States Supreme Court [Exhibit Writ of Habeas Corpus US Supreme Court], which NOAH disclosed to the IRB by a USB memory stick among many other files on December 31, 2019, when NOAII, in person, filed his first Application for a new hearing date at the IRB building at 74 Victoria Street, because NOAH never received the alleged notice of the hearing of January 3, 2020. Furthermore, the same alleged notice is not in the corrupt disclosure, which IRB sent to NOAH about November 2020. Furthermore, NOAH filed the same Application, of December 31, by fax of (1) eleven pages with successful transmission on December 30, 2019, with exhibits [Exhibit 1" Fax transmission] to the IRB, however, the IRB did not file it in NOAH’s claim file nor filed NOAH’s first Application of December 30, 2019. See [Exhibit the photo of 1" page of the Application]. Moreover, NOAI filed many other Applications and disclosed numerous files and documents but the IRB did not file them in NOAH"s claim file. THEREFORE, NOAH’s case file in the IRB is CORRUPT beyond recognition. (e) Therefore, on June 13, 2014, [ECF 10, and 11][Exhibit June 13, 2014 ECF 10, and ECF 11] Obama-Biden admitted all the elements of NOAH’s Petition [ECF 1] and the facts of NOAH other pleadings. Under Federal Rule of Civil Procedure &(b)(2), an “allegation — other than one relating to the amount of damages — is admitted if'a responsive pleading is required and the allegation is not denied.” see Fed. R. Civ. P. 8(b)(5), in any other circumstance an answer that neither admits nor denies allegations is deemed to admit the truth of those allegations. See also Miller v. American Airlines, Inc., No, 03-C-7756, 2007 WL 489147, at *11 (N.D. IIL. 2007);Westfield High Sch. LLF.E. Club v. City of Westfield, 249 F, Supp. 2d 98, 102.4 (D. Mass 2003). It follows that a plaintiff is entitled to judgment on the pleadings where the defendant’s answer fails to deny the elements constituting a cause of action. See Vehicle 2007 Mack 600 Dump Truck, 680 F. Supp. at 826. (0) However, and in the fraudulently allegation “In conformity with” the “Court's order of March 28, 2014 [ECF 4] (Exhibit signed order of Judge Jackson], Obama-Biden in defending “Respondents John Kerry and Jeh Johnson” the new Secretary of DHS “through the undersigned couneil” of the US Department of Justice (DON), DOI filed a FRAUDULENT TREASONOUS response to connive Obama-Biden's CRIMINAL OMISSION of the facts of Obama-Biden already, but SECRETLY, REVOKED NOAIT’s US Citizenship and his US Passport because NOAH expatriated in Finland but Hillary Clinton (Hillary) did not issue NOAH the CLN, and the other Obama- Biden's CRIMINAL OMISSION of Janet Napolitano already issued [Exhibit November 3, 2001 US DHS Form 1-213, NYC] and [Exhibit January 12, 2011 US DIS Form 1-213 in Chicago] but kept NOAIT illegally in the USA for Tortures (g) Obama-Biden deceived NOAH through Clinton, when she issued NOAH the last US Passport No. 458233422 [Fxhibit May 18, 2009 US Passport] stating in [ECF 11, page 2 line 4] “As recently a May 17 [sic], 2009, NOAH received a U.S. passport” actually Clinton issued the passport on May 18, 2009 therefore, how can NOAH receive the passport one day before Clinton issued it? (h) Furthermore, the US passport normally has the following statement that “The Secretary of State of the United States of America hereby requests all whom it may concern to permit the citizen/national of the United States named herein to pass without delay or hindrance and in case of need to give all lawful aid and protection.” Actually, Clinton had Secret information in NOAH’s passport to hinder NOAH’s pass to any country. Therefore, Clinton denied NOAH’s Right to travel in Article 13, of the United Nations Universal Declaration on Human Rights (UNUDHR) of NOAH’s Right to travel. (i) Therefore, on June 26, 2009, when NOAIT first time used Obama-Biden’s deception of its fraudulent statement in the new US passport, supra, was shortly discovered by CBSA at Windsor Detroit Tunnel Port of Entry Ontario, when CBSA stopped NOAH and initially did not allow him to enter Canada but after hours of questioning by the Canadian Authorities including the CSIS, NOAH was allowed to enter Canada with only (2) two months by a Visitor Record from which NOAH’s UCT is from [Exhibit June 26, 2009 Visitor Record] as such Obama-Biden hindered NOAH’s Right to Travel Article 13 of UNUDHR. ()) Furthermore, Obama-Biden’s DOJ clearly showed its deception to the reader of its [ECF 11 page 2 line 5] while Clinton has the record of when NOAH departed the USA to Canada, which was on June 26, 2009, DOJ deception by the USA by stating, loah alleges that he began traveling outside the United States in June 2009,” Doesn't the record of the State Department show that NOAH departed the USA as in the Canadian Visitor Record? See [Exhibit June 26, 2009 Visitor Record].Obama-Biden was miserably trying to support the Perjuries of Glasgow's AFR [Exhibit AFR], which states that NOAH departed to Finland after the indictment of November 4, 2010. The deception and the FRAUDS of the DOS does not stand. (k) Furthermore, CBSA vehemently refused to disclose [Exhibit June 26, 2009 Visitor Record] in spite of NOAH requested the Record under ATIP. Because CBSA is, working with the FRAUDULENT DOJ’s and using its FRAUDS against NOAH and against Michael and Michael, who are spending time in China’s prison. While the Prime Minister of Canada Mr. Trudeau (PM) alleges that the detention of Michael and Michael is a Political Detention, and it is the priority of Canada?! () NOAH repeatedly offered his expertise and the evidence such as, but not limited to, DO!’s FRAUDULENT [ECF 10 and ECF 11] to be used in impeaching DOS, deny the request of the extradition of the Respectful Mrs. Meng Wanzhou (Wanzhou), and release Wanzhou from the FRAUDULENT Political Extradition of the DOJ in order that Canada may have a chance to get Michael and Michael released. However, the Canadian Authorities are victimizing NOAII and violating his Human Rights in the UNUDRR instead of working with him and thanking him, NOAH is the only person, who can impeach the DOJ and make them loose as he did in his Application for a Writ of Mandamus [ECF 1] but to no avail with the Canadian Authorities including the CSIS. See [Exhibit of NOAH’s Application before the IRB in the title of “No one is above the law”] However, the IRB did not act upon and still pending, Although IRB initially filed it in NOAH’s CORRUPT case file in violation of Immigration and Refugee Protection Act , and Refugee Protection Division Rules (m)Furthermore, and more of the FRAUDS of DOJ we see footnote | which states, “1 According to State Department records, however, Noah traveled using his U.S, passport on November 1, 2010, when Finland deported him to the United States. Exh. 1 at 2.” However, the FRAUDULENT DOJ is not using the records of the State Department to show NOAH?’s departure of June 26, 2009, because Obama-Biden kidnapped NOAH and keep stating frauds in support of keeping NOAH a HOSTAGE/POLITICAL Prisoner as Canada is helping the fraudulent DOJ against Michael and Michael and NOAH. (n) Furthermore, DOJ also states in its FRAUDULENT [ECF 11 and 10] page 2 lines 10- 14, referring to paragraph 13 of NOAH’s [ECF 1] that “Noah also claims that, on or about January 28, 2010, he “made an ath /affirmation of renunciation of his United States Nationality * * * as prescribed by the Department of State in form DS-4080, and executed and signed form DS-4080, of Department of State of the ath /aftirmation of his renunciation United States Nationality.” See page 3 items 20 and 23 of [Exhibit March 30, 2010, FIS denying NOAH’s Application for Political Asylum] DOJ is a FRAUDULENT Department. (0) Furthermore, DOJ also states in its FRAUDULENT [ECF 11 and 10] another FRAUD in page 2 lines 14-16 “Additionally, Noah alleges, on March 22, 2010, he executed and signed three copies of an oath or affirmation renouncing United States nationality in the city of Kemi, Finland,See [Exhibit DECLARATION of March 22, 2010, before the Notary Public in the City of Kemi] (p) Furthermore, DOS also states in its FRAUDU FRAUD in page 2 lines 16 -17 that ENT [ECF 11 and 10] another “[alnd sent copies of the declaration and of his U.S. passport to the U.S. Embassy in Helsinki, Finland.” See [Exhibit forwarded the May 6, 2010 email to US Embassy on October 22, 2018 reply on page 3 to US Embassy Helsinki Finland with a copy of US Passport, Signed Form DS-4080 of Renunciation of US Citizenship, and NOAH’s Notarized DECLARATION of Oath/A{ffirmation of the Renunciation of the US Citizenship] Therefore, the Obama-Biden and their DOJ are FRAUDS, Traitors, and International Criminals. (q) In addition and in spite of the Fraudulent Obama-Biden and their DOJ did not deny paragraph 18 of NOAH’s [ECF 1] but tried to cause confusion, please see [Exhibit of May 26, 2010 Registered receipt of NOAH’s mail letter to US Embassy NOAH’s receipt of his Registered mail to the US Embassy in Helsinki Finland [5-26-2010 letter to US embassy Helsinki confirming email of May 6, 27, 2010 by Registered mail] (®) Another FRAUD of the FRAUDULENT PERJURIOUS Obama-Biden and the FRAUDULENT DOJ in DOS’s [ECF 11 and 10] you see in page 3 line 1 and 2, DO FRAUDULENTLY states that, “Two months later, in October 2010, Finnish authorities arrested Noah for being in Finland illegally.” Actually on October 14, 2010, Germany forcibly transported NOAH from Frankfurt, Germany to Helsinki, Finland escorted by two FBI Agents, and delivered him to the Finnish Border Guard in Vantaa Airport, Helsinki, Finland, see [Exhibit order of deportation from Frankfurt Germany] Therefore, the US DOJ is a FRAUDULENT Department has no credibility, and Pembina Port of Entry committed frauds on the government of Canada on September 12, 2018, when Chief of Pembina Port of Entry stated that NOAH is a naturalized citizen of the USA. WHEREFORE, NOAH prays the Honorable Court to grant his Application for leave to Appeal. Respectfully Submitted, SAAD OAK ‘Saad Sadoon NOAH.