1

1

2
3
4

SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF KINGS: CIVIL TERM: PART 27 CHRISTOPHER-EARL STRUNK,

------------------------------------------X
Plaintiff. - against Index No. 6500/2011

5 6 7 8
9

10
11

12 13 14 15 16
17

18
19

20 21 22 23 24 25

NEW YORK STATE BOARD OF ELECTIONS, JAMES A. WALSH, Co-Chair; DOUGLAS A. KELLNER, Co-Chair; EVELYN J. AQUILA, Commissioner; GREGORY P. PETERSON, Commission; DEPUTY DIRECTOR TODD D. VALENTINE; DEPUTY DIRECTOR STANLEY ZALEN; ANDREW CUOMO; ERIC SCHNEIDERMAN; THOMAS P. DINAPOLI; RUTH NOEMI COLON; in their official and individual capacities; FR. JOSEPH A. O'HARE, S.J.; FR. JOSEPH P. PARKES, S.J.; FREDERICK A.O. SCHWARZ, JR.; PETER G. PETERSEN; ZBIGNIEW KAIMIERZ BRZEZINSKI; MARK BRZEZINSKI, JOSEPH R. BIDEN, JR.; SOEBARKAH (a/k/a Ba rry+Soe t.o , a/k/a ro Barack Hussein Obama II, a/k/a Steve Dunham); NANCY PELOSI; DEMOCRATIC STATE COMMITTEE OF THE STATE OF NEW YORK; STATE COMMITTEE OF THE WORKING FAMILIES PARTY OF NEW YORK STATE; ROGER CALERO; THE SOCIALIST WORKERS PARTY; IAN J. BRZEZINSKI; JOHN SIDNEY MCCAIN III; JOHN A. BOEHNER; THE NEW YORK STATE REPUBLICAN STATE COMMITTEE; THE NEW YORK STATE COMMITTEE OF THE INDEPENDENCE PARTY;: STATE COMMITTEE OF THE CONSERVATIVE 'PARTY OF NEW YORK STATE; PENNY S. PRITZKER; GEORGE SOROS; OBAMA FOR AMERICA: OBAMA VICTORY FUND; MCCAIN VICTORY 2008; MCCAIN-PALIN VICTORY 2008; JOHN AND JANE DOES; and XYZENTITIES, Defendants.
------------------------------------------X

MOTION

360 Adams Street Brooklyn, New York August 22, 2011

SW

2

1
2

B E FOR

E HONORABLE ARTHUR M. SCHACK, J.S.C.

3 4 5 A P PEA RAN CES: CHRISTOPHER-EARL STRUNK Plaintiff Pro Se 593 Vanderbilt Avenue, #281 Brooklyn, New York 11238 STATE OF NEW YORK Office of the Attorney General Assistant Attorney General Special Litigation Counsel Attorney for Defendants All New York State Government Defendants BY: JOEL GRABER, ESQ. 120 Broadway New York, New York 10271 NEW YORK CITY LAW DEPARTMENT Assistant Corporation Counsel Attorneys for Defendants A.O. Schwarz, Fr. Joseph A. O'Hare and Fr. Joseph P. Parkes BY: CHLARENS ORSLAND, ESQ. 100 Church Street New York, New York 10007 SIMPSON, THACHER & B~RTLETT, LLP Attorneys for Peter G. Peterson BY: SARAH DUNN, ESQ. 425 Lexington Avenue New York, New York 10017 McGUIRE, WOODS, LLP Attorneys for Zbigniew Brzezinski, Mark Brzezinski and Ian Brzezinski BY: MARSHALL BElL, ESQ. 1345 Avenue of the Americas New York, New York 10105 SANDRA WILKES, R.P.R. Senior Court Reporter SW

6
7 8
9

10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25

3

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22

(Appearances

cont'd): HARRIS BEACH, PLLC Attorneys for President Barack Obarna, V1ce President Joseph Biden, Obarna for America, Obarna Victory Fund, Nancy Pelosi and Penny Pritzker BY: THOMAS J. GARRY, ESQ. 333 Earle Ovington Boulevard, Uniondale, New York 11553 RABINOWITZ, BOUDIN, STANDARD, KRINSKY & LIEBERMAN, P.C. Attorneys for the Socialist Workers Party and Roger Calero BY: DANIEL S. REICH, ESQ. 45 Broadway, Suite 1700 New York, New York 10006 CAPLIN & DRYSDALE Attorneys for John McCain, BY: RITA C. TOBIN, ESQ. BY: TOO~ E. PHILLIPS, ESQ. 375 Park Avenue New York, New York 10152 III

WILEY, REIN, LLP Attorneys for John A. Boehner BY: THOMAS W. KIRBY, ESQ. 1776.K Street NW Washington, DC 20D06 WILLKIE, FARR & GALL~GHER, LLP Attorneys for George Soros BY: JOHN R. OLLER, ESQ. 787 Seventh Avenue New York, New York 10019

"-----./

23 24 25 SW

PROCEEDINGS

4

1

THE COURT: before me. Whoever

I believe

I have ten motjons

2
3 4 5 6
7 8 9

.appears,

sort out whose who.

MR. STRUNK: THE COURT: MR. STRUNK: Strunk.

I'm self-represented. Give your appearance. My name is Christopher-Earl I live in Brooklyn and

I'm self-represented. of standing

the case is a matter a one person, that the case THE COURT: We'll

based upon my vote as

one person-one

vote, and that I believe

10
11

We just want to know who you are. believe me. You'll be

12
13

get to your.offering,

given a full opportunity MR. STRUNK: THE COURT:

to be heard.

14
15

Thank you. I'm not going to deny you that. the list.

16 17
18 19 20 attorney other Anybody

All right; now you can run through

here for the State Boa~d of Elections? MR. GRABER: general. Joel Graber. I'm an assistant and all the

I represent

the governor

state defendants. THE COURT: Help me out. You represent Besides the

21 22
23 members

of the Board of Elections.

the Board

of Elections capacity,

I see there are names in an individual

24 25

am I correct? MR. GRABER: SW Yes, your Honor.

PROCEEDINGS

5

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22
,--../

THE COURT: Kellner,

You have James Walsh, and Gregory Yes.

D9u9las

Evelyn Aquila, MR. GRkBER: THE COURT:

Peterson?

And I take it they must be the and

deputy

directors

of the State Board, Mr. Valentine

Mr. Zalen, correct? MR. GRABER: have changed, Yes. Although the individuals

we represent

the offices. Governor Cuomo,

THE COURT: Attorney Colon is. MR. GRAB~~: State, your Honor. THE COURT: now? General

You represent I don't

DiNapoli?

know who Ruth Noemi

She's a former Secretary

of

Who is the Secretary

of State

I'm trying to remember. MR. GRABER:

It keeps changing.

We don't, we don't focus on

personality.

We-Oh, on the personality. What was

THE COURT:

that song back in 1958, Personality? one. We'll focus on personality.

It was a number

MR. GRABER: defendants. THE COURT: MR. GRABER: THE COURT: SW

Those are always distinct

23 24 25

Your name again? Joel Graber. You want to -- if I can ask you a

PROCEEDINGS

6

1 2 3 4 5 6 7
I.

question because

then I notice you have, and I believe there was a Campaign Finance Board,

this is

that's

Father O'Hare. campaign.

I~ was also Father

Parkes at the

MR. ORSLAND: THE COURT: MR. ORSLAND: O-R-S-L-A-N-D. THE COURT: please? MR. ORSLAND: THE COURT:
~',: .....

Also A.O. Schwarz. He was a Corp Counsel. I'm Chlarens Orsland,

8 9 10 11 12 13 14 15 16 17 18 19 20 21 22

Can you spell that again for me,

O-R-S-L-A-N-D. First name? C-H-L-A-R-E-N-S. You're from Corp Counsel? Fiance Board. if anything I don't is

~

MR. ORSLAND: THE COURT:

I'll just say Campaign think the campaign wrong. MR. ORSLAND: THE COURT: get any money? MR. ORSLAND: that day. THE COURT:

can ask to match

No, they do judicial. I understand. How come I didn't

Leave me out.

I wasn',t there

\.___.

23 24 25

I also know I am -- okay. who -but his

For Mr. Peterson, MS. DUNN:

I'm here for Mr. Peterson SW

PROCEEDINGS

7

1 2 3
4

petition

is not returnable THE COURT: MS. DUNN:

today.

Sarah Dunn.

D-U-N-N? Yes.

THE COURT:' I thought that one was -- I thought I advanced everything. MS. DUNN: THE COURT: dismiss? MS. DUNN: THE COURT: MS. DUNN: Yes. You served it on Mr. Strunk? We did. We just filed it on Wednesday. What was that, a motion to

5
6

7 8
9

10
11

12 13 14 15 16 17
18

THE COUR,:£.:You haven't served it on the Court? MS. DUNN: THE COURT: here today. We filed it on Wednesday. I thought maybe I had everything

I thought I did.

And that's on behalf of Peter Peterson? MS. DUNN: THE COURT: caption. Zbigniew Brzezinski? MR. BElL: THE COURT: Mark Brzezinski. Yes. Okay. Zbigniew Brzezinski and Yes. So let me continue with my

19
20

21
22

23 24
25

And who did I leave out? Ian, father and two sons. SW

MR. BElL:

PROCEEDINGS

8

1

THE COURT: national security

Zbigniew

Brzezinski,

h~ was a

2 3
4

adviser Yes.

for President

Carter.

MR. BElL: THE COURT: MR. BElL: THE COURT: MR. BElL: THE COURT: MR. BElL: THE COURT: defendants?

Who are you? My name is Marshall And last name, sir? B-E-I-L, McGuire Yes. And you're for the Brzezinski from McGuire Woods? Woods. Beil.

5 6
7 8 9

10
11

12 13 14 15 16 17 18 19 20 21 22 23 24 25 America, Biden, Harris

MR. BElt:'· Yes. THE COURT: the vice president? MR. GARRY: THE COURT: MR. GARRY: THE COURT: MR. GARRY: I am, your Honor. You're alsD for the President? Yes. Mr. Garry, I know you. Then we have -- who's here for

Thomas Garry from the law firm of four defendants.

Beach on one motion, THE COURT: you represent MR. GARRY:

You represent. the vice president President Obama. Who else?

I represent

the Obama for Fund.

as well as the Obama Victory THE COURT: SW Okay.

PROCEEDINGS

9

1 2 3 4 5 6 7
I,

MR. GARRY: represent

that's on one motion.

I also

Nancy Pelosi. THE COU.RT: MR. GARRY: THE COURT: Okay. As well as Penny Pritzker. And Pritzker, okay.

I want to continue. You represent or not? MR. GARRY: THE COURT: Democratic Committee? MR. GARRY: appeared. THE COURT: Families Who's here for the Working My understanding is they have not I do not. Who represents the State the State Democratic Committee

8 9 10

-,.

11 12 13 14 15 16 17 18 19 20 21 22 23

Party, anybody? Okay. On. behalf of the Socialist Workers

Party and Roger Calero? MR. REICH: Rabinowitz, Boudin, THE COURT: MR. REICH: THE COURT: MR. REICH: That's for Socialist THE COURT: SW Daniel R~ich, Standard, R-E-I-C-H, from

Krinsky

and Lieberman.

Rabinowitz-B-O-U-D-I-N. Who else? Standard, Workers Krinsky and Lieberman.

''--

___ .r

24 25

Party and Roger Calero. for the Socialist

And that's

PROCEEDINGS

10

1 2 3 4 5 6 7
I,

Workers

Party and Roge? Calero? MR. REICH: THE COURT: Yes. Okay. And on behalf of Senator

McCain? MS. TOBIN: Drysdale. THE COURT: MS. TOBIN: McCain, 2008. We also have a motion Pro Hav Vice Admission on the calendar for the McCain Victory C for Caplin? That's a C, representing 2008 and McCain-Palin John Rita Tobin from Caplin and

8 9 10

Victory

,..__ __ -,,'

11 12 13 14 15 16 17 18 19 20 21 22 office. somewhere?

of my colleague

Todd Phillips.

And as soon as he is admitted also be representing THE COURT:

Pro Hav Vice, he would

Do I have papers

on that

MS. TOBIN: your Honor. THE COURT:

You should have them somewhere,

I have a motion

to dismiss.

Your

name is on there Ms. Tobin and Mr. Wehner. MS. TOBIN: Yes, James Wehner of our D.C.

',--",'

23 24 25 colleague motion?

THE COURT:

That's

in here to admit your

for Pro Hav Vice or what is that, a separate

SW

PROCEEDINGS

11

1 2 3 4 5 6 7 8 9 10 \.._.-. 11 12 13 14 15 l6 17 18 19 20 21 22 23 24 25 related California Mr. Wehner skilled

All right, let me see if I have it ~ere. Okay, I have a motion to admit Mr. Phillips. name on it. of the bar of And who's a I don't in Good

Let's see, I have Mr. Wehner's I see Mr. Phillips

is a member

and of the District said Mr. Phillips and a person

of Columbia.

is a individual of integrity.

attorney

doubt that. Standing bar.

And I see he has a Certificate

from the State of California

bar and the D.C.

Is there any objection Mr. Phillips for -~

to admitting

MR. STRUNK:

I object on the basis that it's transfer before in

part of the subject of the cross motion that it becomes Court. a recognized operation

this

It's also required

that they familiarize

themselves structure contention Mr. Wehner

with the rules of the Court and with the of law of the State of New York. And it's m and as

that both Ms. Tobin and Mr. Phillips, were both involved in the request

in what I characterize for judicial a related

a misstatement

intervention

in that they did not recognize

case that had

been listed and swore to that matter. THE COURT: case? SW What are you talking about? What

PROCEEDINGS

12

1 2 3 4 5 6 7
':-

MR. STRUNK: Judge Schmidt. THE COURT: MR. STRUNK: THE COURT: it again.

There is an open case before
.'

I believe

he dismissed case.

that.

It is an active I don't know if

I'll look at

I had a conversation

about an hour ago with impression. But

Judge Schmidt,

but I had a different

8 9 10

I'll look at it again. MR. STRUNK: the RGI where related case. THE COURT: his permission What does that have to do with Certainly a sworn statement in

it's clearly

stated that there is a

~-

11 12 13 14 15 16 17 18 19 20 21 22 23

for Pro Hav Vice? you tell me is

Let's assume everything correct. admitted

.

What does that have to do with him being for this particular matter? He's a member of Columbia of

the bar in good standing

of the District

and the State of California. MR. STRUNK: motion was standard My only objection is that this

after the RGI was filed and that he himself with the rules of your

should have familiarized Honor and the Court. THE COURT:

That's all I -If that's all, the lawyers of the I'm going

'--"".-

24 25

State of New York would never read my rules. to overrule. SW

PROCEEDINGS

13

1 2 3
4

MR. STRUNK: THE COURT: presented

Okay. It presented, what is is a member what's of the within

to me shows Mr. Phillips

bar in good standing the United purposes Section 22 NYCRR Hav Vice.

of two other jurisdictions and therefore for to

5
6 7

States of America,

of this particular

case and pursuant

520.11 of the Rules of the Court of Appeal section

and

8
9

690.3, I'm going to admit him for Pro

For all I know, he is going to sit next to He's admitted.

10 11 12 13 14 15 16 17 18 19 20 21 22
·~ ...

Ms. Tobin and not say anything. Congratulations. MR. PHILLIPS: THE COURT:

Thank you, your Honor. You don't have

You get a break. registration.

to pay the #350 bi-annual

Let me go back to see who's who. Okay, are. you representing not? MR KIRBY: THE COURT: MR. KIRBY: representing Thomas W. 'Kirby of Wiley Rein. What's your name? Mr. Boehner or

Thomas W. Kirby, Wiley Rein,

Speaker Boehner. Anybody here for the New York

THE COURT: State Republican Anybody

. 23

State Committee? here for the New York State Committee Party? SW

24
25

of the Independence

PROCEEDINGS

14

1 2 3 4 5 6 7 " 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Schmidt counsel, us today. covered know. lawyers Willkie,

Anybody

here'for Party?

the New York State Committee

of the Conservative Okay, represented

~ know we have Ms. Pritzker Soros? with

-- anyone here for George John Oller,

MR. OLLER:

O-L-L-E-R,

Farr & Gallagher. THE COURT: MR. OLLER: THE COURT: Willkie, Yes. You guys, one time you were the League forever. Farr and Gallagher? .

for the National MR. OLLER:

We do a little bit, not as much

as when we had the commission. THE COURT: The Obama Victory McCain, McCain-Palin Okay, Obama Fund. Fund 2008, for America we

we have McCain Victory

representatives. else I didn't get? I think I've

Anything everything.

So we have -- so we have nine opposing which is counsel, as well as Mr. Strunk before

Now, Mr. Strunk,

help me out.

You know what Ron -- I want to You have the index number case? SW on that Judge

PROCEEDINGS

15

1

MR. STRUNK: THE COURT:

29642 dash 08. Here's what I'm going to do. I

2 3
4

want -- I need about one or two minutes. to my computer Clerk's in my chambers

I want to go

and look at the County

5
6

files on that so I could see where we are on

that case.

I'll be right back.
(At this time, there was a break in the

7
8
9

proceedings

and the matter THE COURT:

subsequently

resumed.) it appears that

Okay, Mr. Strunk,

10
11

index number

29642, basically

summarized,

it appears you had am

that you, there was a case in which tried to enjoin I correct, the Electoral <ir> ~~...

it appears

12 13 14 15 16 17 18 19 20 21 22 23 24 25

College

from meeting,

among other things? MR. STRUNK: THE COURT: Among other things. Then there were various orders

issued and it appears

that the judge in 2008 -- I just this.

want to work my way through In November

of 2008 you had an Order to Show

Cause that you filed with the Court to estop the Electoral College in New York State from meeting, among

other things, about travel President

and all kinds of other things you wanted records in the State Department, in the early about

Obama's mother

60s, and it goes that to,

on and on and on. right now.

I don't want to go through Judge Schmidt declined

But anyway, SW

PROCEEDINGS

16

1

based on the decision

of the second circuit.

2 3 4 5 6 7 8
9

Then you came back a year later with an Order to Show Cause in November temporary restraining federal, of 2009 where you wanted a

order, protective

order et cetera doing

about various certain Manning, number

state and city agencies individuals

things with various Robert

who -- Pastor a them in

Dornan, Orley Taitz,

et cetera,

of people.

I'm not going to characterize
just say they're

in anyway whatsoever, the United

individuals

10
11

States and he declined

to sign that one. in this

Then you came back on the same action

12 13 14 15 16 17 18 19 20 21 22 23

year, and I have copies of the orders with notice of entry served by you, by the attorney New York office, and it appears general, State of 11th of

that on January

this year in that case you had a motion heard by Judge Schmidt, opposed and he ordered and the Attorney that the motion

for leave being General in

was denied

its entirety. Then in March of this year, on March 17th --

I'm going to try to read Judge Schmidt's
it says "All motions, office of the. Attorney also notices General,

handwriting,

of entry by. the are denied.

all motions

Mr. Strunk President

failed to join as a necessary Obama and Senator McCain, to do so expired SW

party

24
25

and the Statute of

Limitations

in -- can't quite read a

PROCEEDINGS

17

word or two that he has. handwriting there's

I don't have a grea~ to, but it appears to provide

either, but I'm trying

no purpos€

to allow the plaintiff

proof of service complaint. case. respect around.

nunc pro tunc or to amend the to me basically this is a dead it with

It appears

I don't know how else to describe to 29642. This case basically

has, is not the Electoral

It's expired.

I mean certainly

College met in 2008. in the District states, counting

And not only New York State, but and forty-nine other

of Columbia

and congress

did what they had to do in

it under the Constitution. Mr. Obama is now the President of the United

States whether is.

you like it or not.

So it is what it

So that's the situation

that we have with respect

to that. Tell me why -- I mean Judge Schmidt judge in the Special Election consolidate basically ~art. is the

So why should I

this action with an action that is of? Your Honor, the motion ,for, the a Article 78

disposed

MR. STRUNK:

Order to Show Cause was for a mandamus, under 29641. And depending complaint

upon the outcome

of that, by the

then the companion

would be determined

law of the case that was decided SW

by him in regards to

PROCEEDINGS

;;

18

1 2 3 4 5 6 7
I;.

state officers twice.

receiving

two, officers

being paid

In other words -THE COURT: You said -- I don't -- I think I don't think they get paid. They get paid per diem. That's expense money. In other

electors

get expenses. MR. STRUNK: THE COURT:

words,

if someone

resides

let's say in this county, .in and they go to after

8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25

Kings County, New York City, Brooklyn, Albany, I think the third Wednesday I believe

in December

the election meets, capital somebody

is when the Electoral in that they meet, every four years.

College

if I'm correct, in the country drives

every state So if

their car to Albany

and gets fifty expense money.

cents a mile and tolls and lunch, that's That's not compensation. MR. STRUN~: payment

It was not expense.

It was

for the day, which is different. THE COURT: All right, so be that as it may,

let's -MR. STRUNK: THE COURT: someone In any case Let's assume for argumeI}t sake state senator

is a New York City councilm~n, chosen as an elector

and they're case.

for that particular -- I mean

So you're

saying that that person Paterson

that's why you had Governor SW

in there or

PROCEEDINGS

19

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22

Mr. Cuomo when he was attorney were electors. MR. STRUNK: the same time. determined

general

because

they

They were holding

two jobs at

The law of the case, this was to the decision by Judge Schmidt,

according

and that was that -THE COURT: But he denied all these motions. Go ahead.

All right, let me hear you out. I'm sorry. say. MR. STRUNK: in other words, because electors I apologize.

Let me hear what you have to

If 29641 had been decided make a proper

in

I couldn't

complaint also as

you have so many state officers which I figured was a unusual of interest.

situation

where

there was a conflict

Now, there was THE COURT: other states, you're Is it I mean if you went to sake- you went to California, officers in
-

for argument

going to tell me that democratic are not electors MR. STRUNK:

California

in California? study California. I

I didn't

only studied New York. THE COURT: Mr. McCain In the same respect, obviously

\,,---

...

23 24 25

had one and Mr. MR. STRUNK: SW Mr. Skelos.

PROCEEDINGS

20

1 2 3 4 5
6

THE COURT: of the respective republicans,

And others who were all leaders
,,'

chambers

in the legislature

as

I'm.sorry,

slate of electors, am I correct? Yes. where,

you would

have made the argument, MR. STRUNK:

There was a decision

the decision

on

7 8
9

the law, what is done in 29641, and the attorney's presentation Executive both of the Public Officer's Law and the I

Law, and the constitution

was made in which

10
11 12 13 14 15 16 17 18 19 20 21 22 23 24 25

could then decide how to proceed ,because otherwise I didn't because

in my complaint if in fact there

know where,

had been a conflict never -- because Section

the state legislature 2,

they're

the ones under Article because College

1 -- determined and Electoral

the right to vote is a is determined by the

privilege

state legislature .. But there was nothing defined become who an elector a patriot could be~

in law which

And of course it's by habit and I

in its position

considered

it bad habit. THE COURT: You say -- maybe it's your honor political part.

because

you're a leader of a particular

that wins the mQst votes. State. If you're a member

Let's stay with New York of the political votes, party that

gets the most votes, popular this honor and you are rubber SW

the party gives you so to speak, the

stamped

PROCEEDINGS

21

1 2 3 4 5 6 7 8 9 10
"---

will of the votes -MR. STRUNK: Excuse me. The general election

is not a party and raises member

-- it's anybody

that's not a

of a party can seat. THE COURT: Correct. But technically you're

voting

on election

day for President this country.

of the United

States throughout

You don't have one.-in fifty

we really have 51 for slates of electors countries. MR. STRUNK: THE COURT: particular, were voting Fifty-one Correct. separate Whoever

elections.

11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 vote

wins that

DC or anyone

of the fifty states that you anywhere from

for a slate of electors,

three to, I forget how many electors California Most people has, so you're voting don't understand

the State of

for those electors. So then whoever those

that.

gets the most votes people become

for that state of votes, We understand

the electors.

that.

MR. STRUNK: THE COURT: for everything

In New York State. And also technically they can sake,

they like. was elected

For argument'$

when David Paterson

in 2008 and he wanted He voted.

to vote for John McCain,

that's his right.

Every elector voted in New York State for Obama. MR. STRUNK: SW And we come to the rub of the

PROCEEDINGS

22

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22
~

complaint. obligation republicans

The rub of 'the complaint to inform the electors and the democrats

is that it was my

of whom both the

that they were entering and I still believe They

into an area which was I believe uncovered,

not covered by New York State law. having to determine

were essentially

as is required of the in my sitting

under the 20th amendment candidates, complaint. properly,

the eligibility

and I had given them notice And once I found whether

they're

which was the Article

78, I could then, I had and I did not amend the under a Freedom because

a right to amend the complaint, complaint because

I went to Washington

of Information I was denied

request

to get further discovery whatsoever

any discovery

on the Department terms Now I·'

of State records where the mother

to determine

in no uncertain

was at the time of the birth.

still in court on that three years. THE COURT: jumping ahead. Subsequent that we have before the 2008 action, documents to your commencing this action to Here's a'question. Maybe this is

us today, and also subseq~ent Obama released these

President

23 24 25

from the State of Hawaii which I know it's in the motion his birth

I think was You the birth

late April. attached

papers.

as an exhibit SW

certificate,

PROCEEDINGS

23

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22
"--.-/

certificate Hawaii.

that, it was released

from the State of

MR. STRUNK: accept British that as prima subject. THE COURT: born in MR. STRUNK: THE COURT: Honolulu, you agree? MR. STRUNK: prima facie.

I don't challenge

either one.

I

,4

facie proof that his father is a

\

You're not raising whether

he was

It's all right. You believe he was born in

Absolutely,

I agree.

That's

I'm not going to challenge that it's true.

it if there's

a presumption admitted

I'm just saying that he subject.

that his father is a British THE COURT:

But I don't think anybody denies or Kenyan subject. I believe from

his father was a British

for sure when Kenyan achieved Britain MR. STRUNK: was a British subject.

its independence

Even when he was born his father

THE COURT: citizen

We agree he's not an American

at the time of his birth. MR. STRUNK: He was a student, considered he a

23 24 25 foreign couldn't

allegiant

on a student visa and therefore resident

also be a permanent SW

in the United

PROCEEDINGS

24

1

States. turnover

Therefore,

he was here on a short term only. It was clear. And to

2 3 4 5
6

for education

jump forward here, it's clear that New York State was the preventer. citizen means. Philadelphia They generated what natural born

When Chief Justice

Yates left the in 1787, he came

Constitutional

Convention

7 8
9

back and told George Clinton, of what's

"We don't want any part we've got too

going on down there because

much at stake," New York spread from the upper Peninsula river. THE constitution. MR. STRUNK: Only when Jay and Hamilton were of Michigan all the way to the Connecticut

10
11

12 13 14 15 16 17 18 19 20 21

couItf'<:

New York State ratified

the

able to yank it out of Philadelphia, which met the requirements was a natural born citizen. constitution, compromise because

it posed a rigor

of New York State, and that Wnen we ratified the

it was on our terms and it was a for it onl

only to the fact that we allowed

it was a phyric victory.

'There were already and

nine ratifications anti-federalists president

that both the fe~eralists

22
23

said we'll list with only the born, but we want all That's what the

being a natural

24
25

congressman ratification

being natural born. documents SW

were and it was put in as a pure

'.'"
PROCEEDINGS
.:

25

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23
'~

recollection unified

of afterthought.

But if they had acted they could have made

under Yates and Clinton,

that requirement

and it would be a -Let's -- we're not in 1787. That's law. Let's come to the

THE COURT: We're now in 2011.

report. So, but the way, I mean, to Judge Schmidt. It appears you're arguing this

to me that Judge Schmidt

more or less has resolved

these issues. in 2008, it's sort of The egg is broken. again. not trying to

Also with what occurred like humpty-dumpty. It's done.

You can't put it 't5'§,ck together MR. STRUNK: overturn suggest an election. it.

I'm not, certainly

I would be a fool even to

We don't have a law in the State of New else in the country. going to to It's

York, nor is there a law anywhere Everybody

is on their best honqr that they're candidate

submit a certified

to be on the ballot

meet the requirement filing on your honor. nobody

of a natural born citizen. You're a citizen. there's nobody There's

there to verify, unless

taking

responsibility submission court.

I come in three days after the and challenge it in

of that certification

24 25

After three days Mickey Mouse has to take responsibility. SW

is on the ballot. There is no

So somebody

PROCEEDINGS

26

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22
~---.........-

law under the 20th amendment. of the state running federal officer

'" It's the Supreme Court election for a The Supreme

the specific

representing

that state.

Court of the State of New York has original jurisdiction elections over all elections. There are no federal

per se.

There is no law coming out of the

legislature. executive. Honor.

There is no law coming out of the Therefore, the buck stops with you, your

THE COURT: Truman.

Thank you for making me Harry

MR. STR\lJ'NK:I don't want it to repeat again in 2012, and that's already Socialist announced Worker been announced by the

Party the candidates

and it's been for 2012. hasn't

by Mr. Obama that he's running THE COURT: However,

the convention

met in Charlotte,

North CaroliDa. for a moment all your arguments Let's

Let's assume are valid. assume you're ballot

I haven't made any assumptions.

for the sake of argument asking

one of the things

for me to enjoin him from being on the in 2012.

or slate of electors MR. STRUNK: THE COURT: There's

23 24 25

Which would go to part one. Here's my question since a democratic for you. convention has

r

SW

PROCEEDINGS

27

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 ----16 17 18 19 20 21 22 23 24 25

not yet met, not until next summer, no candidates enjoining for 2012.

technically for

there's

Isn't it premature

Mr. Obama from being on the ballot? MR. STRUNK: I think there are steps to be I'm being injured. good to me when

taken before.

We're being injured. You look pretty injured. that.

THE COURT:

you say you're personally physical ahead. MR. STRUNK: THE COURT: little joke. sense,

I know, not in the I'm sorry, but go

I understand

I didn't mean -I said I'm sorry. I made a

I s~b~Gldn't do that, but go ahead. Well, look, I've been called I did it because I understand you said you what you're

MR. STRUNK: THE COURT: were personally saying. .MR. STRUNK: one of 300 million

injured.

I'm the ,only one in the country,

or however many, minus the -You and I are two of many. I'm the only one in the State of

THE COURT: MR. STRUNK:

New York who went to court in 2008 .. It was a learning curve problem problem. and shame on me for not handling the

But the record shows around the country that ahead of most

I'm ahead of, head and shoulders attorneys

who tried this, and I know all of them and SW

PROCEEDINGS

28

that they're Federal

still running

around

Federal

Cou~t as if Our

Court had jurisdiction.

They don't.

elections where

are run by the State, and Supreme Court is And right now we have no

the buck stops.

responsibility who's

being taken by the Board of Elections and republicans. And if I for the

run by the democrats

may add, the democrats people. advice Two people

was actually behind

the lawyer

<:

actually

the scenes giving and

for the election

of both Mr. McCain --

Mr. Obama,

and that I believe THE COURT:

You're talking

about Mr. Garry or

are you MR. STRUNK: THE COURT: MR. STRUNK: THE COURT: MR. STRUNK: Society of Jesus. No, Douglas Oh. He is very much I see.
---

Kellner.

of the Province

of the

He represented

them and he had it in

his interest

to recuse himself

and to make sure that carried out in

their ministerial terms of enforcing

tasks were righteously

the only rule which appears

in the which

State of New York, which was on their website they repeated, Article 2, Section

1, Clause 5, which
or vice president

says "No candidate

for president

shall be on the ballot unless SW

they meet that

PROCEEDINGS
~.'

29

1 2 3 4 5
6

requirement."

It was on their honor. Excuse me one more moment.

THE COURT:

(At this time, there was a pause ,in the proceedings and the matter THE COURT: can continue. I just I believe that -- I told my son subsequently resumed.) Go ahead. You

Sorry, continue.

7
8 9

MR. STRUNK: before

I came here today, he's going to vote for the our vote means behind

first time next year, I don't believe very much anymore because the scenes. has dropped expectation elections president's Our voting off.~We
~~'~:' :~'I'

10 11 12 13 14 15 16 17 18 19 20 21 22 23

it's all manipulated

rate of turn out for election

no longer have a reasonable participation in the for the

of individual

and certainly

the ballot

is picked

race and that even puts a greater on the Board of Elections of eligibilitY,under to check that 2, Section And it's Party

responsibility the requirement 1, Clause already

Article

5 are met, and that was not done. by the Socialist

been admitted

Workers

that it had. been done and it was admitted could be eligible citizen parents Mr. McCain. for president unless

that nobody

they had two of

at birth.

That was the condition Painfully

I voted for Mr. McCain. But nonetheless,

I voted

r
I

24 25

for Mr. McCain. challenge

when he did not admitted that

Mr. Obama, when he had already SW

PROCEEDINGS

30

1

he had a British challenge person-one that.

born lather, Mr. McCain Therefore, my contract

did not
"

2 3
4

to vote, one I can't a

vote, where

I cannot

sell my vote,

give it away. other

I can go to jail for that. It means something

There's

5
6

side to my vote.

in the State New

of New York and it better mean something York State is in dire condition sustain Upstate, being a voting assembly

because

7 8
9

politically.

We cannot

where people

do not vote. they are not Putting

New York is emptying properly,

out because

10
11

represented

that's

germane.

that aside -THE COURT: for someone So essentially your argument is

12 13 14 15 16 17 18 19 20 21 22 23 24 25

to run for president

of the United States it says you have that not only

under Article

2 of the constitution,

to be a natural born citizen. you have to be born. within America, citizens,

That means

the United

States of

but both your parents is that what you're MR. STRUNK: THE COURT:

have to be natural born ~aying?

Yes, your Honor. What if for argument's sake

Mr. Obama's

father would have been naturalized? He would be naturalized. So in other words, your parents

MR. STRUNK: THE COURT: have to be citizens? MR. STRUNK: SW

Yes, and as spelled

out in New

PROCEEDINGS

31

1

York State law and specifically history Section of law that's

in regards

to our law

2 3
4

found in the real property

18, that'€ the only location is mentioned and there's

that the natural a basis of

born citizen legislative convey natural

5
6

action to that basis where you cannot rights to anybody who is not

a piece of mining born. Natural

7
8 9

born is also defined

by the U.S.

Supreme

Court in 1824 as it relates

to the transition where law in our on to a

10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25

of the property

rights after the revolution So in other domestic property

family would inherit. surrogate,

in our law which passes there's a definition

family member,

in New York State

law which clearly of nations

defines

that it's blood and soil law

definition

and I say law of nations because It is the" on

it's big letters basis

in. the U.S. Constitution.

of how we carried

on trade, how we carried

commerce, revolution

how we were able to borrow money to run the that we had to operate under international to exist as

law that was commensurate a nation after we broke

with our ability from the king. which

So all this I deem them

comes to bear to the legislature lazy, you know, bad habits. Mr. Goldwater

was the last one on the ballot He was born in

in 64 who was not born on U.S. soil. SW

PROCEEDINGS

32

1 2 3 4 5 6 7
I..

the territory

of Arizona. Listen, I'm not going to debate

THE COURT: Barry Goldwater .. MR. STRUNK: had prepared

This is in LBJ's papers.

They --

a challenge

in the event that Goldwater became a state in 1912. was born.

THE COURT:

Arizona

I'm not sure what year Mr. Goldwater MR. STRUNK: THE COURT: For purposes 1901 or 2. Whenever.

8 9 10

Doesn't matter.

of this, let's assume he was think he was that old when he

~

11 12 13 14 15 16 17 18 19 20 21 22 23 24 25

born in 1912 -- I didn't ran for president. territory Depending American
&-: ..:

=:

Be that as it may, it was American in 1828. it's to argue about

since the treaty of Guadalupe

on where he was born in Arizona, territory. Even going far afield

about Senator Goldwater, Senator McCain, States Navy. and mother States.

and you have a argument

his father was on active duty in United I'm assuming his father

I didn't check,

were natural born citizens linking Treaty

of the United

You're

a little bit of the to try to claim he's ~ot a far fetched?

Hay-Bunau-Varilla natural

born citizen. MR. STRUNK:

Isn't that a little No, not at all.

He was born in base. They

the Republic didn't

of Panama, not on a military at that point.

have a hospital SW

PROCEEDINGS

33

1

THE COURT: and mother

Thank you.

Why are his, father they voluntaril

2 3
4

in 1936 in Panama? £e got orders

Because

went to Panama? father.

to go to Panama, his

5 6 7
8 9

MR. STRUNK: is that the senate, THE COURT:

That is really --

a fact.

The fact

the U.S. Senate

I read that resolution.

I wasn't

aware of it but I read about it in your papers. MR. STRUNK: argument on territory All right. I accepted So I took it, the it at the time and I

10 11 12 13

voted accordingly. wasn't --:;,.".

I wasn't

aware of the treaty.

THE COURT: actually

Well,

fortunate

or unfortunate, life

I

14
15 16 17 18 19 20 21 22 23
}

am aware of that treaty. history

In my previous

I taught American never you're

and Mr. Bunau-Varilla

had

set foot there in his life. aware. MR. STRUNK: THE COURT:

I don't know if

I was stationed Mr. Bunau-Varilla was a tool of

preference.

They're

trying to get Panama to cut a deal six days. And.I know

with the U.S. so he's assigned that history history. The point because

I once studied

u.S. diplomatic

24 25

I want to make, McCain.

Senator McCain's He's ordered by the

father, he became Admiral SW

PROCEEDINGS
:~ ..
"

34

1 2 3 4 5 6 7 8 9 10
~--

navy department, assignment don't

you're assigned.

Whatever

hlS

r'

was in Panama and his wife goes, she's -~ I I don't know how long So Senator

know, she gets pregnant.

he was in Panama prior to Senator McCain. McCain, official in that his parents, business

his father goes on States and is a member

for the United

of the United

States Navy and that's why his father was of that he's States?

there and you're arguing because disqualified to be president

of United

MR. STRUNK: certified

I'm arguing

that he had been that he was a defined

11 12 13 14 15 16 17 18 19 20 21 22

by the senate.

I know unanimously

was natural born bill introduced

'a'rfd

that there simultaneously

in the house which essentially

that, that you need two citizen parents that was never carried constitutional was a problem forward.

to do such, but to do a

They wanted

amendment.

They recognized

that there

in thedefinitio~

and they recognized forward. But the sense

that and it was never carried resolution Clinton was sponsored

by Mr. Obama and by Mrs. against Mr. McCain. that

who were candidates THE COURT:

Maybe they had a realization with John McCain born citizen

even though you can disagree politically,

;

23 24 25

he is also a natural

of the

Uni ted Sta-tes. MR. STRUNK: SW My injury, I voted £or McCain.

PROCEEDINGS

35

1 2 3 4 5 6 7 8 9 10
~

THE COURT: MR. STRUNK: challenge exercise. THE COURT: challenged

Is that a injury? My injury is he did not that whole

Mr. Obama after he went through

You're

saying he should have

Mr. Obama's presidency? MR. STRUNK: Absolutely, he violated and the ballot. his agreement with The

onus is on me because me.

You can't challenge McCain,

the eligibility

until he's up

to be sworn.

since everybody

in Congress, so it mail j

11 12 13 14 15 16 17 18 19 20 21 22 23 24 25

since they didn't want to know about anything, was my r-e spons i.b.i-Ff't.y . within 72 hours. THE COURT: the president. because

I fired him by registered

I saw your letter that you fired agree with you

I guess he didn't

I
I

he's still there. MR. STRUNK: I'm an ~agle scout. I became an

eagle scout in 1959. THE COURT: life scout. Congratulations. I was only a

It's true.

I praise 'you for that. But that shapes my thinking if we as a

MR. STRUNK: individual.

I mean, what are we as a country

don't abide by the law? ~HE COURT: a country. SW That's right,

I'll agree.

We are

PROCEEDINGS

36

1

MR. STRUNK: is my life and my vote. anything

After all, the only thing I have And if my vote doesn't mean

2
3 4

and the~ can run around and not make a THE COURT: But in looking at your complaint, right,

5
6 7 8 9

and I read, you know, I think it's 45 pages, your complaint? statements But then you come out with

-- let's take Mr. Obama. To me he's President

You refer to him Obama. I mean you

as Soebarkah.

come out with what I call conclusions.

I don't know

10
11

what it's based upon that he's, in paragraph he's "a Madrasah trained radical

24, that

Sunni Muslim by birth

12
13

right." MR. STRUNK: record. THE COURT: morning He's a Muslim. I hear on Sunday That's a matter of public

14 15
16

he goes to church. MR. STRUNK: When I went to Washington on a

17
18

case to determine his birth, already passport

where the mother

was at the time of other than I Her

19
20

I had not drawn

a conclusion

knew his father was a British application

subject.

21
22

had on it Soebarkah.

I ~as the

one who got that name Soebarkah. of that. I am entitled

I was the originator There was nobody about doing this.

23 24 25

to use that.

else in the country who had thought I was the first one in the country. SW

PROCEEDINGS

37

Now, Soebarkah, of the region, son of Soetoro. THE COURT: conclusion

'" also if you use the language of the son, who's the

is a conjunction

How could you come to the Sunni Muslim? that's what his records of individuals who

that he's a radical MR. STRUNK: Because

show and that's what the testimony were in class with him show. stringent stringent -- he spoke Arabic

He practiced

the most the most and that

and he practiced in the Mosque,

rigors of attendance of public record.

is a matter

THE COURT":''c: what's But Muslim? MR. STRUNK: a Muslim. There's

wrong with being

nothing

wrong with being

There is nothing THE COURT:

wrong with it. that

Well, you make a statement that's the majority

Sunni Muslims

-- I mean,

of Muslims

and Shia and others.

But you say that -- let me get in

the exact quote that you had here, a Muslim, paragraph 24, I have "a Muslim

is a'liar by training,

never to be trusted." MR. STRUNK: THE COURT: millions Al takia. Meaning there are hundreds of none

of ,people in the world who are Muslims,

of them are to be trusted by virtue SW

of the fact they

PROCEEDINGS

38

1

.,.
are Muslim? MR. STRUNK: detailed discussion THE COURT: MR. STRUNK: Koran. THE COURT: statement defamed I don't either. But you make a If we were to get into a

2
3

of the Koran -I don't know too much. I don't want to discuss the

4 5
6 7

8
9

in your complaint. of Muslims.

Seems to me like you

hundreds

10
11 12 13 practiced

MR. STRUNK:

Mr. Obama is one of the most

liars that I've ever seen in my short 64

years of life. THE COURT: MR. STRUNK: I've heard Nixon, in my lifetime, and he doesn't word. Okay. And nobody challenges his lies.

14 15
16

I've heard everybody

from Eisenhower liar

and that Mr. Obama is a consummate get called out Qn it. Nobody says a

17
18 19 20 21

He's trained. Franklin

It's his training. Davis as a FBI stringer was

Marshal

very much involved

in the training

of Mr. Obama after and

year ten when he, when he was sent by his mother grandmother to Chicago for therapy.

22
23 24 25

His background the Jesuit from recovery

went to Father Galluzzo, Priest who- helped of his substance

Greg Galluzzo

in his rehabilitation abuse problems.

But that's neither

SW

PROCEEDINGS

39

1 2
3 4

here nor there. you've

The point is that lying is a~art which
I
• I

got to learn and Mr. Obama has been taught how

to lie and he's one of the best liars that ,I have ever seen, including Bill Clinton who blushes when he lies.

5
6

THE COURT: Clinton reading things and Obama. the papers,

Let me move along from Bill There's because something else concerns me a number of

7
8
9

you mention

about the Muslims. What I find fascinating, first of all you

10 11 12 13

said there was a connection McCain

there where you say Cindy I don't know if she is. faith, Cindy McCain.

says she's a Catholic.

I think you said'~We' s Catholic MR. STRUNK: of Budweiser. THE COURT: her a Catholic

She is the largest distributor

14
15 16 17 18 19 20 21 22 23 24 25

I know that.

That doesn't make

necessarily. It's th~ connection that counts.

MR. STRUNK:

You don't get those connections. THE COURT: Anheuser-Busch, Catholic. I don't know if the

I don't know if the Busch family is

I don't care. MR. STRUNK: THE COURT: That's big business. That's big business I wouldn't selling beer. be sitting

If I had a Anheuser-Busch-ship here. I would be counting SW

my money.

Let's put

PROCEEDINGS

40

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22

~nheuser-Busch

to the side. and you get into

You said she's a Catholic this whole riff OT rant, whatever about the Catholic Vatican.

you want to call it the and I'm

church and Father O'Hare,

You go on and on about the Vatican,

seeing this book I can't avoid, a very thick book in front of me. It says Vatican Assassins as a title, ·but is

it seems to me you have this theory a conspiracy and it always

that everything

falls back to Rome. of public

MR. STRUNK: record. THE COURT: MR. STRUNK:

That's a matter

Oh, okay. What the key is here, Ms. McCain for a Jesuit run school

is on the Board of Directors where her children

are going to school. Could very well be. I don't

THE COURTt know. MR. STRUNK: to the magazine the time.

And they have a tight connection which was unbeknownst to me at

America

I would not have voted

for him if I had

known because anybody

I was warned by my friend Bob Dornan that with the magazine America is not a Bob

associated

-~-~.

23 24 25

friend of this country. Dornan nobody

And that's Bob Dornan.

is one of the top Jesuit people can challenge, SW

in this country

and this was said on a radio

PROCEEDINGS

41

1 2 3 4 5 6 7 8 9 10
'~~,--~--

program

which

I was on for two hours.

It's available he and

to anyone who listens. I both voted

His take on Mr. McCain,

for Mr. McCain because

we could not see he did

our way clear of voting

for Mr. Obama because and we relied on

not have two citizen parents, Mr. McCain, horse, the old war horse,

the old glue factory to protect in di

that he would do what was necessary as voters,

our interest

Mr. Dornan down in Virginia

Fairfax where he's from and me here, and Mr. McCain not follow through. discovery compelling background Manchurian advantage required didn't In fact, it turns out in the to the Jesuits it was so

11 12 13 14 15 16 17 18 19 20 21 22 23 24 25

of the connection

that wheh I started

really digging putting

into the up two

of this scheme of defraud, candidates

at once, which would take in our law which and we

of New York State's weakness honesty. We require

to have honesty

get it. THE COURT: Your case is more the Davinci

Code. MR. STRUNK: book. THE COURT: Frankenheimer, With all due respect Candidate to John to The Davinci Code is a phoney

the Manchurian

according

you and the school of the Vatican, describes

by that way it

the gist of your argument. SW

PROCEEDINGS
$,'

42

1 2 3 4

MR. STRUNK: THE COURT: Manchurian Candidate MR. STRUNK: THE COURT: MR. STRUNK: THE COURT: MR. STRUNK: point, but
--

Frankenheimer. He directed movie. The old. With Frank, not Denzel. Frankenheimer. 1962 movie. I was aware of the movie at that the original

5
6

7 8
9

10
11

THE COURT: MR. STRUNK: Sinatra. THE COURT: MR. STRUNK: you've brought
--

Okay, forget it. This is the one with Frank

12 13 14 15 16 17 18 19 20 21 22
,.~.

And Laurence

Harvey. Now

The Queen of Diamonds.

THE COURT: Candidate.

You mentioned

Manchurian

They have it in th~ movie. MR. STRUNK: THE COURT: I've used it as a pejorative. I understand that, and I think argument,

the Davinci Code, to make some interesting that's a work of fiction.

At least. I think it's a wor

of fiction. MR. STRUNK: a work of fiction. into this area. SW The Manchurian Candidate was not

23 24 25

The work -- I don't want to get

PROCEEDINGS

43

1
2 3 4

THE COURT: understand

Let's not get into anal?gies. arguments but it seems to

I

you have various

all come back to Rome. MR. STRUNK: State and whether No, it comes back to New York in the Supreme Court of who's going

5
6

I have standing

of the State of New York on the question to take the responsibility not been done. THE COURT: to enforce

7
8 9

the law which.has

Okay, that's your argument. before

I

10 11 12 13

want to make one observation defendants in this particular You made ~ elections what's cetera, country,

I hear from all the

case on their motion. earlier about rigged

statement

and about how everything

is pre-ordained,

14
15 16 17 18 19 20 21
22
\

going to happen, et cetera.

you don't have a choice et how you feel about this for half hour you have made

Despite

you have now spoken

approximately, statements

in which to put it mildly,

which

I'll say, you know, that are not, are President of the United and

not in favor of Mr. Obama, States, others. detained.

and you made statements You haven't

about Mr. McCain

been handcuffed,

you haven't been

You're going to walk out of this room a free Despite whatever in this you

"'---"

23 24 25

man, and I'll let you go on. think,

you have a right to your opinion I just want to say that. SW

country.

PROCEEDINGS

44

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22
',--- ....

MR. STRUNK: THE COURT: MRA STRUNK: the appeals increasing

Thank you, your Honor. Okay. What my observation is, judge, in and

court back in 2002, 2003 was interested the confidence of the general population

the judiciary. thought

I participated

in testimony

in what I in the

was necessary

to increase

participation

confidence Forget they're

of the general public

in our judiciary. overpaid and

the federal court.

They're

THE COURT: That's

Oh, I'll disagree

with you there.

the federat'-;-;: not the New York State it's That's what you're MR. STRUNK: talking about now.

judiciary.

The judiciary

is the only place

that a citizen from beginning

can make a argument to end. Guess wh9t?

from soup to nuts,

THE COURT: Have you stopped? MR. STRUNK: judiciary. speech.

I'm letting you.

That's why I'm here.

I love the

That's the only place -I get my freedom of

There was an arrest on the weekend Somebody standing on a soap box because reserve.

in NYU.

23 24 25

he was going on with

about the £ederal that.

I don't get involved

I just sue them. SW

PROCEEDINGS

45

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 council. longer Mr. Obama expedited damages. terms, the case. either?

THE COURT:

So you don't have Ron Paul

-"

MR. STRUNK: ring kisser.

Ron Paul, I frankly think is a of a argument. He's not in

He's a bookend

THE COURT:

I~m not going there.

He's one of the new people. MR. STRUNK: Ron Paul said in no uncertain myself in front of I wouldn't paraphrased. be I

"I'm not going to embarrass by challenging

my colleagues

Mr. Obama.

able to live with myself," can't find anybody THE in

or something

couiT!:

In essence,

you want me to enjoin and you want about various

from being on the ballot discovery, as I notice,

And I see you also want me to enjoin your with our

claim that the Jesuits have interfered election law. MR. STRUNK: standing matter That is a matter which there's Quinn.

which is a Quinn

Christine

that shows -- Christine THE COURT:

I show speaker

of the city

\..._.-c

23 24 25

MR. STRUNK: Mr. Obama.THE COURT: SW

She was an elector

for

Okay.

PROCEEDINGS

46

1 2 3 4 5 6 7 8 9 10 '--/
11

MR. STRUNK: of the Campaign at six dollars to including

She also chose the participants
.'

Finance Board who then gave out money for everyone dollar of taxpayer to run. candidate for money

Ms. Quinn got money

THE COURT: council. MR. STRUNK: THE COURT: Mr. Obama, McCain

She did as a member

That's right. But I don't believe for campaign that boards.

got money

MR. STRUNK: against Mr. Paterson

What opened my eyes in my case is that when he took over for thrown out for messing

12 13 14 15 16 17 18 19 20 21 22 23 24 25

Mr. Spitzer who wa'~,: essentially with Wall Street,

that's clear that's what Mr. I don't think that's actually,

THE COURT: but let's work on -MR. STRUNK:

Mr. Paterson's

aides who read and made the said is a

all of his work and all of his,papers necessary proposals

of what Mr. Paterson

Jesuit priest,

and as a Jesuit priest, Only God relieves

you don't quit

the Jesuit order. requirement.

you of that

So that that opened up my eyes seeing doing controlling the governor office.

what was a Jesuit priest

of the State of New York in the governor's ·THE COURT: You're talking

about Mr. O'Byrne is that what

who used to be the governor's SW

secretary,

PROCEEDINGS

47

1

you're

talking

about? Mr. Paterson. I thought he resigned the

2 3
4

MR. STRUNK: THE COURT: priesthood? MR. STRUNK: to divorce

5 6 7
8 9

There's

no such thing.

You have

the priesthood. THE COURT: That's between Mr. O'Byrne, I don't the

Jesuits

and God.

I'm not going there. My understanding

know

what happened former priest.

there.

was he was a

10
11

MR. STRUNK: words,

You have to be -- in other of the Holy See,

12 13 14 15 16 17 18 19 20 21 22 23 24 25

the Jesui -tt";c3'rdera militia is

and since 1984 -THE COURT: inquisition I know we can bring back

going over here and to file the reformation else. It's not 1900 anymore. It's

and everything 2011.

MR. STRUNK: time is unbroken.

The time is, the time is, the

There is no -- they are here for the

same reason as they were in 1540 when they did the Council on Trent. THE COURT: I have the gist. There's -- I

want to give each defendant, an opportunity

just as I have given you

to be heard, to be heard. Well, my primary cause of action

MR. STRUNK: SW

PROCEEDINGS

48

1 2 3 4 5 6 7 8 9 10

here is that one person-one in the State of New York. They're somebody elections not turning out.

vote has been trampled

on

People are not voting now. They've got to know that when

is put on the ballot,

the entire board of not

does their job, and they're THE COURT:

Mr. Strunk, we are a democracy can choose in an election. And

which means

that people

isn't it also that people MR. STRUNK: votes. THE COURT:

can choose not to vote?

If they want to waste their

-,.

11 12 13 14 15 16 17 18 19 20 21 22 Australia.

I know it's -- if people

choose

not to go as a derrtcYe:racy, you're coerce them or mandate MR. STRUNK:

saying we should have to vote?

that people

That's how it's done in

THE COURT: MR. STRUNK: State Election primary

I know, another Under Article

country. III, New York has as its It

Law, the Board of Elections participation

duty to increase

in election. playing

has failed and it has failed because they're democrat tweedle dum, tweedle

dee apd not enforcing

the

law the way it's written THE COURT:

and the way --

r

23 24 25

Okay, I have the gist of your okay, if

argument. - I want to hear from the defendants, I may? Thank you. SW

,

"\.

__ ....-.

PROCEEDINGS

49

1 2 3 4

MR. STRUNK: THE COURT:

Thank you. Thank you.

The reason why I let you go on, I want to be sure that you are able to be given the opportunity be heard. MR. STRUNK: THE COURT: here thinking Whatever I wasn't Thank you. I don't want you to walk out of going to listen to you. is going to be, it will be. to be But to

5
6

7
8 9

the decision

10
11

at least I want you to have the opportunity heard.

12 13 14 15 16 17 18 19 20 21
22

I list,'ft~"think ine sets of lawyers n The order in which they announce don't

in order. why

their appearance, to

I do it that way, and ask the people

Mr. Graber, clients?

you want to speak first on behalf

of your

MR. GRABER:

Thank Y9u, your Honor.

The State would like to defer to the defendants who had made motions. THE COURT: it is Orsland Okay. That1s f~ir. So then

on behalf

of the Corp. Counsel? Yes, your Honor. I know that beliefs.

MR. ORSLAND: Mr. Strunk

23

is very sincere -THE COURT: MR. ORSLAND: SW

in his political

24
25

I'll agree with you there. Never have I seen any brief in

PROCEEDINGS

50

1

which we see no cause of action. no questions,

And if the Court has

2
3

I'd like to rest on that brief. I really have no questions. I

THE COURT: think your papers to Mr. Strunk.

4 5 6 7
8 9

are going to lay it out, particularly others. It appears

I looked at several

to me in my own mind you have in your, I don't know, that Campaign O'Hare, Finance Board, forgetting about Father

Father Parkes, whatever

they have to do with

the election. MR. ORSLAND: I think you can -THE COURT: They're
);j>;::,_,~'~

10
11

I think we have nothing

to do.

12 13 14 15 16 17 18 19 20 21 22 23 24 25 our motion briefed. should

They don't do matching

money.

not involved. MR. ORSLAND: MR. STRUNK: Correct. It's individuals. I have a -- I

say slate of electors. THE COURT: MR. ORSLAND: THE COURT: That's neither Yes. All right, on behalf we have Ms." Dunn. been·-we just filed of here nor there.

Mr. Peterson

I believe

MS. DUNN:

I haven't

on Wednesday

so it hasn't been fully

THE COURT: On behalf

I'll take a look. of the Brzezinskis. SW

PROCEEDINGS

51

1 2 3 4 5 6 , 7 8 9 10
\ '-.__/

MR. BElL:

Thank you, your Honor. in the

We've also laid out our argument papers. We have problems our defendants with injuries

anQ the

defendants,

can be sued in New York but issue there. rights to

I think there's

a very important

Mr. Strunk has his first amendment stand up and speak. THE COURT: MR. BElL: He certainly does.

But I think the defendants

here as

well have a right to participate precedents right,

in advice and advice that

11 12 13 14 15 16 17 18 19 20 21 22

and a lawsuit which will exercise

and it's

v~f:y

important

that their rights be

protected

by the case being dismissed. THE COURT: The point to be made despite and numerous in prison for his

beliefs

about Mr. Obama, Mr. McCain

defendants, his beliefs.

he's not going to be-thrown

He's going to wa~k out of this courtroom else. I gave him his opportunity to be

like everybody heard because

that's what we do in court, and the family has a right to

father and sons, the Brzezinski their opinions too.

MR. BElL: be challenged Supreme

And it's important

that they not that right. like The

-~--"

23 24 25

in court for recognizing

Court has recognized

this and a lawsuit

this does affect

their ability SW

to go forward if it's

PROCEEDINGS

52

1
2

repeated

and these lawsuits

become

routine.

The case

should be dismissed THE COURT: MR. GARRY:

very quickly

on merits.

3 4 5
6

All right Mr. Garry. On behalf of my client, we would to 3211 in CPLR. we'll I tried to

rely upon the argument Your Honor doesn't

made pursuant

have any questions, I don't have any.

7 8
9

THE COURT: question Mr. Strunk.

Okay, Mr. Reed, is it? MR. REICH: THE COURT: MR. REHt}ti filed a motion Reich. Mr. Reich. On behalf of the SWB, we also and I could

10 11 12 13

and rest on our papers, in addition

14
15 16 17 18 19 20 21 22 23

argue as to codefendants

to that that I in fact doesn't in

just want to make clear that Mr. Strunk make any allegations his complaint that our clients

did anything

other than run f~r president. They exercised, other than

THE COURT: exercise criminal neither

their rights as citizens or violation

to run and it's not a Well, it's

or civil action.

here nor there. Mr. Calero is one of three hundred million to do. your Honor. Thank you.

Americans

who did what he's entitled -MR. REICH: THE COURT: SW That's correct,

24
25

I understand

that.

PROCEEDINGS

53

1

Okay, Ms. Tobin. MR. PHILLIPS: On behalf arguments you. THE COURT: All right. Thank you. we have Thank you, your Honor. entities, we.laid out our Thank

2 3
4

of McCain

in our brief and we'll rest on that.

5
6

7 8
9

And on behalf Mr. Kirby. MR. KIRBY: our papers. THE COURT:

of Mr. Boehner

The same, your Honor.

We rest on

10
11

Thank you. you're here on

12 13 behalf

And Mr >f'Oller, I believe of Mr. Soros. MR. OLLER: on our papers as well.

14
15 16

Yes, your Honor.

We would rest

I would add one point,-and is a private citizen.

that is Mr. Soros to be part of from hi

17
18 19 20 21 22 23 24 25

He's not alleged No relief allegations

the government apart

in anyway.

is sought

from the conspiracy grounding.

which have no

natural

As far as I can tell from the gave money to

complaint Mr. Obama.

against Mr. Soros is that.he

THE COURT:

I know, it's a sin.

I guess he's but a lot

a big, he gives money not only politically, of charities. SW

PROCEEDINGS
"'",

54

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23
'-._/

MR. OLLER:

In any case, Mr. Soros is alleged and we would ask

to be in cahoots with Rupert Murdoch for a swift decision. THE COURT:

There are a lot of arguments

that

Mr. Soros would believe -are strange

about him in this.

Any other
Mr. Strunk, you have anything else you want

to add now that you've heard the defendants? MR. STRUNK: this case. Well, there are three aspects as to whether of or

The first being threshold

not I had a, my vote represents contract

even under common law, vote

law whetn"~r my vote as one person-one a contract with Mr. McCain

represents

or his electors

when they voted, obligation

and whether

or not he has an And he had the to do that and

to challenge of anybody

his opponent. in the country

best standing he didn't

do it. Now, that's an important element of my case or not New

because

then comes the question

of whether

York State has -- I haven't because argument they haven't

responded

to the State an

responded,

so I reserve

in that regard.

But there is no law that all a lot of high powered you can do this because It's just like The Inside

of these learned attorneys you're told

attorneys,

24 25

their clients the law. SW

not breaking

PROCEEDINGS

55

1 2 3 4 5 6
"

Job. make

You can go ahead and do the derivatives~and

we'll

sure that you're not going to have any down side so that their clients, Mr. Boehner, Ms~

whatsoever

Pelosi and the representative Party,

of Socialist

Workers

they put in their certification could challenge

knowing very

well that whoever

had to do it within

7 8 9 10 11

three days or else it was up to the, it was up to the Board of Elections. Actually democrats and republicans on the

sit there and say should we let the democrats ballot, should we let the republicans do it.

on the ballot. So

They didn't

Now they didn't break the law.

"~~

12 13 14 15 16 17 18 19 20 21 22
###BOT_TEXT###lt;,

where do we standf"'inthe State of New York?

Well, we they

stand pretty much like the 51 other states because don't have other laws that THE COURT: MR. STRUNK: THE COURT: states. MR. STRUNK: treated In our law, Washington, Fifty and DC. Thank you~ Fifty. We agree there's

fifty

DC is

as a state in this regard~ THE COURT: MR. STRUNK: Correct. In that sense, law. I use that

23 24 25

chronologically.

That's

Now, New York State is the first to define what a natural born citizen SW is. And it can be found

PROCEEDINGS

56

1

through

the legislative

intent of the formati~ns

of the

2 3
4

real property whole

law, Section

18 which they only raise the nature of New York State it's in So New York

law and the venerable

law, the New York council will substantiate depth and it goes back four hundred years.

5
6

State of all the states should be the one and only state to set the definition citizen is by reading do that? a law. of what a natural born And why didn't the Board

7 8
9

of Elections

10
11

Well, they were part of a scheme to defraud me and the voters, those who decided to vote who out

12 13 14 15 16 17 18 19 20 21 22 23

haven' t given up ;,r,)'cAnd

there are a lot of people

there who have given up and they don't want to be a part of what's going on. But as a eagle scout, I'm to go the ten

going to be prepared, points.

if necessary,

I'm a boyscout. THE COURT:

I am not going to back down. to scout law,

There ar~ 12 points

not ten. MR. STRUNK: THE COURT: are 12, not ten. Well, I've broken get too two. well, there

I wouldn't

I'll take judicial Certainly

notice of that. is

MR. STRUNK: that a citizen

the requirement

stand up and defend Tomorrow

his vote even when could We

24
25

it's only a privilege.

the legislature 2, Section 1.

take all this away under Article SW

PROCEEDINGS

57

1

won't have a right to vote for the president. the legislature decision depends on us as citizens

.":~-

But when

2 3
4

to make a

and cast our vote with a reasonable of winning and participating in a leveled not involving with

expectation playing

5 6 7 8
9

field by the Board of Elections, their requirement and republicans.

it to uphold the democrats

and then working All of the other

finance boards which result these three candidates, officers. They're respond document can't

in the certification become duty.

of quasi

those candidates

10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25

Their duty is a quasi fiduciary

on a ballot.

They have just as much duty to of that
I

to their "tifi'volvement, submission to just as Senator Goldwater

had to do in '64. Here we they

find any other candidate and the socialist

on the ballot. workers admitted

have three,

were on in 2004 and admit they can be a green card and run for president. fiduciary And they b~come and that's a party for state action.

responsibility,

They did a sworn statement

and they have just as much their action as the

duty to show up in court and defend Board of Elections, and they have
-7

THE COURT:
Socialist Worker
MR.

With all due respect, here.

with the

Party, they're

STRUNK:

The Board of Elections

is not

here.

They haven't

shown up on any case in three SW

%

PROCEEDINGS
~.:

58

1

years. receipt,

They didn't even sign the certified that's the hubris there. They're

return working with

."

2
3
4

the post office department, explanation electronic on serving tracking.

so they have a plausible Thank God for

something.

5
6

Your Honor, what it comes down to, it's a scheme to defraud me personally. attorney. I'm not representing I'm not here as an a class. I can't. that I was the and So

7 8
9

my vote and my knowledge

and my discovery

10
11

used in the scheme to put the plan through commercial the Council club of Chicago

which is Penny Pritzker and everything

12
13

on FO'~'@lgn Relations,

that's

in The Inside Job. THE COURT: of the Vatican I'm sorry, I forgot CFR is a part

14 15
16

conspiracy. It's not.- It's part of the fact is a, Harding Borah

MR. STRUNK: when we survive. Lodge -THE COURT: Treaty of Versailles. MR. STRUNK: survived that.

17
18 19 20

When -- Hard~ng

You're going back into 1918.

21 22 23 24
25

Treaty of Versailles.

We

World War I did not end -It was an act of Congress. Because we didn't want --

THE COURT: MR. STRUNK: THE COURT: SW

And World War II ended by the

PROCEEDINGS

59

1 2 3 4 5 6 , 7 8 9 10
'~'

ability

of Congress, MR. STRUNK:

December

21, 1946. about the Council operation They on

I'm talking

Foreign because

Relations we refused

was set up as a parallel to join the League the Council

of Nations.

intentionally

created

on Foreign Relations That's a matter

as if it were the League of fact. THE COURT: Leagues? members

of Nations.

Is it a Council

on Foreign

The organization

have -- and that I know they do as a private

and they do whatever

11 12 13 14 15 16 17 18 19 20 21 22 23 24 25

organization. MR. STRONK: intention United to resemble But they were set up with the the League of Nations because in the

States refused

to give up its sovereignty us back to the

that they were intent on turning Europeans as we were before Now, the European the Lisbon

the revolution. Un~on needed money until It was finalize

Treaty came along in 2009.

last year and they now have what is known as a Musolini Structure, There's a Ultramontane Syndicalist Structure. the

a partnership

of syndicates.between

government, Musolini

the capital

and labor, and that is what the

Structure

was, and that's what hit My understanding, we also did

THE COURT:

that in the United States under the NRA in 1933 and 34. SW

PROCEEDINGS

60

1

I know that. MR. STRUNK: THE COURT: nor there. Okay. MR. STRUNK: Foreign made Relations But certainly the Council on By Cordosa. In 1935, but that's neither here

2 3
4

5 6
7

is a body which was intentionally and bring us into

to shadow the League of Nations

8
9

it as the United

States; all that is, it came directly There is a seamless the United Nations between the United and

from the United Nations. connection there's Nations between

10
11

and before connection

a seamless

12 13 14 15 16 17 18 19 20 21 22 23

and the H~'fy See is what, with Edmund Walsh out who sat there at the Versailles he was in the Wilson that. He oversaw the of Treaty

of Georgetown arrangement

for Wilson,

administration, defeating

he oversaw

of the Russian train.

Christians

and the putting

Lenin on a Russian Stalin

Father Walsh had Joseph party in 1922, 23,

as the head of the communist

and it was a direct Georgetown Affairs,

result of Edmund Walsh out of over the Versailles Treaty

who presided

a presiding

structure

of the Jesuit Order as the man

it remains

now shared with David Rockefeller,

living on many body parts. The point is that Father O'Hare most important Jesuits SW is one of the

24
25

in the world at this point

PROCEEDINGS

61

because

he controls

the body which has been directing of $16 trillion in the last

the structure

of transfers

four years for European

banks and in Asia in order to

stave off the crises that your client Mr. Cuomo, after getting brought rid of Glass Stegal in 1999, that was all to have somebody who had

about and they needed

dual allegiance. Mr. Dunham,

I call him the black Irishman

Irishman,

the black

had a dual relationship. and visited his Isles.

He even stayed relatives'

in Windsor

Castle

graves and backgrounds

in the British

The man has dual allegiance the European coming

in the European,

Europe an

strnc't'urewhich was connected Commerce

to his

out of the Chicago it through

Club which is of the European the control to

aggrandizing Union.

the structure

And oil, the Chevron Astor

Trust,

of oil which is what's going on now from Thailand all the way to Nigeria. and I wanted I mea~ that's

the big picture

to limit it to that.

I could take it into think it was

Wall Street and I can do it but I didn't necessary. THE COURT: to tell me? MR. STRUNK: Well, there's Is there anything

else you need

the question brings

of

the scheme- of defraud which certainly money flooding

in foreign Whether

into the bank of J.P. Morgan. SW

PROCEEDINGS
.'

62

1 2 3 4 5 6 7 8 9 10

or not Obama is a natural bringing raisers citizen, it in because the requirement whereas

born citizen

or not, he was to his fund must be a
"

he did not declare that anybody

donat~ng

Mr. McCain

did and others did.

NOW, it's -- there was a -- it's a prima facie fact he was willing where to get foreign money from

ever since he had dual allegiance.

With Europe

you knew where he was coming financed against amounts Odinga

from and he had already

in 2006 when they were in genocide He personally -far all the money gave large

the Christians. of money

0

11 12 13 14 15 16 17 18 19 20 21 22 23 24 25

as a U.S. Senator

THE COU~T~: We're getting MR. STRUNK: into the THE COURT: We're getting

-- for bringing

far afield

from

Mr. Obama being on the ballot. MR. STRUNK: scheme to defraud. The secQndary issue is their

If in fact you find that you could and one foreign citizen to be

have a one citizen parent a natural bQrn citizen,

the case is done.

But there is

no, there is nothing you. a -~HE COURT: your complaint.

in New York StQte law, and we need and it takes

The buck stops with you, your Honor,

Maybe

I overlooked

something

ln

I know you quoted SW

in Article

2 of the

PROCEEDINGS

63

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22
"-__/

U.S. Constitution,

and I looked at the Constitution. born citizen·of of the

.'

It said you had to have been a natural the United people natural States to be accepted

with exception

born -- the first eight presidents born, but they were -MR. STRUNK: THE COURT: Grandfathered in.

were not

Van Buren is the first natural, grandfathered the first eight.

but the constitution They didn't time. Where orally

know who they were going to be at that that, but here's my question. do you explain what you had to say

I understand in your papers
~;.;;~ '''-;!>'-

about theihterpretation,

about the fact that territory has

both parents

of a person born on American in your complaint? In the response

to be -- where

MR. STRUNK:

to Mr. McCain I present a

and Mr. Obama which is combined background historically,

together,

an argument

not in my words, what natural

but of those who were involved born is. THE COURT: that. this.

in defining

Oh, now I'm'seeing

where you have all of

So I'm going to have to look. through

23 24 25 Fletcher

Is this where you're quoting a-nd others? MR. STRUNK: SW Fletcher

from, Henry

as a historian

was --

PROCEEDINGS
.e-

64

1 2 3 4 5 6 , 7 8 9 10
~

THE COURT: you're making

I know, in 1919. about,

I see where -

your argument

about Mr. Bingham. was the sponsor of

MR. STRUNK: the 14th Amendment. THE COURT: reply papers. MR. STRUNK: desperately

Mr. Bingham

I "11 look further

at that

.in

your

But here, what New York needs in the country born citizens We have a needs an and

is to regain it's position

since we were the ones to define before we enjoined the federal

natural

structure.

11 12 13 14 15 16 17 18 19 20 21 22

structure

of law and I think the legislature sd~it can do the proper
'¥';/'-~-~

interpretation

legislation

put it in place by the 2012 election. THE COURT: Anybody Okay, I understand. else?

have anything

Thank you. I'm going to reserve. decision. from me. MR. STRUNK: that, the references Your Honor, may I offer some of in that paperwork? This is the You'll hear

book that I have a disk for.

\._/

23 24 25

(Continued on next page to include

Jurat.)

*

*
SW

*

*

PROCEEDINGS

65

1

THE COURT: MR. STRUNK:

I don't need your book. " Okay. Thank you. please. We're

2
3 4

COURT OFFICER: to clear the courtroom, lunch.

I'll ask everyone
closing for

5
6

(At this time, the matter REPORTER'S I hereby and accurate certify copy CERTIFICATION

concluded.)

7 8
9

that the foregoing

is a true

10
11

held in the above

12 13 14 15 16 17 18 19 20 21 22 23 24 25

-r'S'ANDRA WILKES, RPR Senior Court Reporter

SW