Complainant Tony Dolz 621 Rushing Creek Place Thousand Oaks, CA 91360 Tel.

310 371 7500 Fax 805 435 6654 Email tony@dolz.com Web www.Dolz.com

ALLEGATIONS IN THE COMPLAINT The complaint and election challenge is based on (1) New Hampshire election laws 655 et sequitur; (2) Article 2, section 1 of the US Constitution; and (3) Help America Vote Act of 2002 New Hampshire – Election Laws. “655:14 Filing: General Provisions. The name of any person shall not be printed upon the ballot of any party for a primary unless he or she is a registered member of that party, he or she shall have met the age and domicile qualifications for the office he or she seeks at the time of the general election, he or she meets all the other qualifications at the time of filing, and he or she shall file with the appropriate official between the first Wednesday in June and the Friday of the following week a declaration of candidacy as provided in RSA 655:17.” ———————————————————————————————— “meets the all other qualifications” is a positive claim, therefore the candidate must be able to prove said qualification(s).
ELECTION LAW COMPLAINT – BALLOT CHALLENGE of CANDIDACY of BARACK HUSSEIN OBAMA by TONY DOLZ

———————————————————————————————— “655:17-b Declaration of Intent; Presidential Candidates Who File Nomination Papers. I. Declarations of intent for each candidate for president who seeks nomination by nomination papers shall be in the form provided in paragraph II. Declarations of intent required by this section shall be filed with the secretary of state, signed by the candidate, and notarized by a notary public. II. I, _________, swear under penalties of perjury that I am qualified to be a candidate for president of the United States pursuant to article II, section 1, clause 4 of the United States Constitution, which states, “No person except a natural born citizen, or a citizen of the United States, at the time of the adoption of this Constitution, shall be eligible to the office of President; neither shall any person be eligible to that office who shall not have attained to the age of thirty-five years, and been fourteen years a resident within the United States.” I further declare that I am domiciled in the city (or town or unincorporated place) of _____, county of ____, state of ____, and am a qualified voter therein; that I intend to be a candidate for the office of president to be chosen at the general election to be held on the ____ day of ____; and I intend to file nomination papers by the deadline established under RSA 655:43. I further declare that, if qualified as a candidate for said office, I shall not withdraw; and that, if elected, I shall be qualified for and shall assume the duties of said office.” ————————————————————————————————

ELECTION LAW COMPLAINT – BALLOT CHALLENGE of CANDIDACY of BARACK HUSSEIN OBAMA by TONY DOLZ

Notwithstanding the error that the above form should read “pursuant to article II, section 1, clause 5” instead of “pursuant to article II, section 1, clause 4; “‘I am qualified” and “I will be qualified …..” are positive claims, requiring proof. ———————————————————————————————— “655:43 Filing Deadline. I. Nomination papers shall be filed with the secretary of state no later than 5:00 p.m. on the Wednesday one week before the primary. Nomination papers to be filed shall be grouped by municipality. No nomination papers shall be accepted by the secretary of state unless the candidate shall have met the age and domicile qualifications for the office he or she seeks at the time of the general election and meets all the other qualifications at the time of filing; and, if a candidate for the office of governor, executive councilor, state senator, or state representative, unless the candidate shall file with the nomination papers an affidavit of qualifications as provided for in RSA 655:28 and 655:29; and if a candidate for United States senator or United States representative, unless the candidate shall meet the qualifications for office under RSA 655:3 and 655:4.” ———————————————————————————————— So that the candidate “meets all the other qualifications”, proof must be provided. ———————————————————————————————— “655:44 Objections. Nomination papers made in accordance with the provisions of this chapter shall be regarded as valid and shall
ELECTION LAW COMPLAINT – BALLOT CHALLENGE of CANDIDACY of BARACK HUSSEIN OBAMA by TONY DOLZ

be received by the Secretary of State unless objection thereto is made in writing no later than the Monday following the last day for the filing of such papers.” ———————————————————————————————— Objecting is hereby done in writing. ———————————————————————————————— “Presidential Nominations 655:47 Declaration of Candidacy. I. The names of any persons to be voted upon as candidates for president at the presidential primary shall be printed on the ballots upon the filing of declarations of candidacy with the secretary of state in the following form and signed by the candidate: “I, ____, swear under penalties of perjury that I am qualified to be a candidate for president of the United States pursuant to article II, section 1, clause 4 of the United States Constitution, which states, “No person except a natural born citizen, or a citizen of the United States, at the time of the adoption of this Constitution, shall be eligible to the office of President; neither shall any person be eligible to that office who shall not have attained to the age of thirty-five years, and been fourteen years a resident within the United States.” I further declare that I am domiciled in _____, in the city (or town or unincorporated place) of _____, county of ____, state of ____, that I am a registered member of the _____ party; that I am a candidate for the nomination for the office of president to be made at the primary election to be held on the ____ day of _____; and I hereby request that my name be printed on the official primary ballot of said _____ party as a candidate for
ELECTION LAW COMPLAINT – BALLOT CHALLENGE of CANDIDACY of BARACK HUSSEIN OBAMA by TONY DOLZ

such nomination.” ———————————————————————————————— Notwithstanding the error that the above form should read “pursuant to article II, section 1, clause 5” instead of “pursuant to article II, section 1, clause 4; “I am qualified to be a candidate for president of the United States pursuant to article II, section 1, clause 5 of the United States Constitution…..’
1.

Barack Hussein Obama, II is not a Natural Born citizen, was not qualified in 2008 and is not qualified now to be on the ballot as a Presidential candidate. In 2008, when Barack Hussein Obama ran for the U.S. presidency, he was not vetted objectively and independently; and he did not provide documentary evidence or a convincing argument of his Natural Born Citizenship status, given his acknowledgement that his father was a foreign national with foreign alliances and loyalty. The only information provided was: - Multiple versions of unvetted Internet digital images (no hard copy source document or certified copies) of a purported Certification of Live Birth. These lacked information such as doctor, witnesses, hospital and biometric data. A Hawaiian COLB could be obtained with only an affidavit from a relative, with no hard proof and corroboration of an event of native birth required. There are multiple examples of others who obtained such documentation fraudulently.

ELECTION LAW COMPLAINT – BALLOT CHALLENGE of CANDIDACY of BARACK HUSSEIN OBAMA by TONY DOLZ

- Digital

Internet

images

purporting

to

be

“birth

announcements,” with no hard copy source material or other proof. Source documents cannot now be located. These images do not contain the baby’s name, or place of birth, and the parents never lived at the address provided. - - A purported long form Certificate of Live Birth was provided 4-27-11, which appears to be a forgery (discussed later). - Requests for other vital information, such as, but not limited to: records for hospital., subsequent medical, school, vaccination, baptism, scholarship, travel, passport, immigration, Bar, legislative, employment, bank/financial, Master’s and Doctoral theses, Harvard Law Review papers, Social Security, etc., have gone unanswered and in fact, such demands were fought in court by “Obama’s” legal representatives, from Perkins Coie, White House Counsel Robert Bauer and Dept. of Justice Attorneys, who should have been prosecuting him, instead of defending him. - No evidence at all of any official vetting has ever been provided.

2. There is a preponderance of evidence (see exhibits) that Mr. Obama lacks a valid Social Security number. The Social Security number on record for Barack Hussein Obama, used by him among other instances, for real estate transactions and on his Selective
ELECTION LAW COMPLAINT – BALLOT CHALLENGE of CANDIDACY of BARACK HUSSEIN OBAMA by TONY DOLZ

Service application, has been flagged by the E-Verify citizenship and legal residence verification program as being a “no match” to a person named Barack Hussein Obama. There is substantial evidence that he is using a Social Security number from the state of Connecticut batch of numbers, a state where he never resided, which was never assigned to Obama and which returns a status of invalid by the E-Verify and Social Security Verification System (SSNVS). See exhibits 1, 4,5,6 3. Complainant herein, is Mr. Tony Dolz, a Cuban-born naturalized U.S. citizen and former candidate for the office of State Assembly Representative in the state of California. Mr. Dolz is a dedicated Constitutional patriot and civil rights leader, who is fighting an unprecedented level of corruption in the government and courts, in order to preserve the right of U.S. citizens to elect Constitutionally eligible candidates for the office of President of the United States and vote in fraud-free elections. Mr. Dolz has been exploring a run for a Congressional seat in the state of California. 4. In 2009, Mr. Dolz gained access to reports from licensed investigators Neil Sankey and Susan Daniels, which Dr. Orly Taitz presented as evidence at her presentation on Obama’s eligibility for President of the United States at the Continental Congress 2009 in St. Charles, Illinois, where Mr. Dolz and Dr. Taitz were elected delegates. The Sankey and Daniels reports show, that according to the most reputable national databases used by government, industry and private investigators, that Barack Obama has used a Connecticut Social Security number 042-68ELECTION LAW COMPLAINT – BALLOT CHALLENGE of CANDIDACY of BARACK HUSSEIN OBAMA by TONY DOLZ

4425 issued in 1977, even though he was never a resident of the state of Connecticut. In 1977, the Social Security Administration assigned Social Security numbers according to where the applicant made the application for the number. The number that Barack Hussein Obama has used most frequently since 1977 (see exhibits) is a number once assigned to an applicant in Connecticut and that applicant was not Mr. Obama. In 1977, Barack Hussein Obama was not living in Connecticut. In 1977, Mr. Obama was a 16 year old boy and a student at the Punahoa school in Hawaii, where he resided. Additionally, national databases employed in the Sankey and Daniels reports show that another person assigned the same Social Security number used by Barack Hussein Obama was born in 1890. In the time frame 1976-1977, due to changes in Social Security Administration rules, many elderly individuals, who never had Social Security numbers before, had to apply for their Social Security numbers for the first time in order to obtain Social Security benefits. It appears that the number in question was assigned to an elderly individual in Connecticut around March of 1977. The death of this elderly individual was never reported, and from around 1980-1981, this number was fraudulently assumed by Barack Obama. Exhibit 1, 5. Dr. Taitz was a delegate at the Continental Congress of 2009 (were Mr. Dolz was also a delegate). At the Congress, she had a discussion on the matter of Barack Obama's fraudulent use of a
ELECTION LAW COMPLAINT – BALLOT CHALLENGE of CANDIDACY of BARACK HUSSEIN OBAMA by TONY DOLZ

Connecticut Social Security number, with a recently retired senior deportation officer from the Department of Homeland Security, John Sampson. Mr. Sampson provided her with an affidavit, attesting to the fact that indeed, according to national databases, Obama is using a Connecticut Social Security number, even though there was no reasonable justification or explanation for such use by 16 year old Barack Hussein Obama who resided in Hawaii in and around the time the Social Security number in question was issued. Exhibit 2, Affidavit of John Sampson. 6. In 2010, Barack Obama, or his agent, posted online on WhiteHouse.gov his 2009 tax returns. As he posted those returns, he forgot to flatten the Adobe PDF file (a file format of the Adobe Corp. a graphics editing program manufacturer) and all of the layers of modification of the file became visible to the public. One of the pages contained Obama's full alleged Social Security number 042-68-4425. Taitz received an affidavit from Adobe Illustrator program expert Mr. Chito Papa, attesting to the fact that the initially posted tax returns of Barack Obama contained Connecticut Social security number 042-68-4425 and that the number was visible. Later the file was flattened (edited) and the Social Security number can no longer be seen in the document. Thousands of US citizens and individuals around the world were able to obtain and possess the original file with the Social Security number visible. Exhibit 7 7. The Selective Service has an official website. On that website, it is possible to verify if there is a match between a date of birth and a Social Security number. Using that website, Dr. Taitz was
ELECTION LAW COMPLAINT – BALLOT CHALLENGE of CANDIDACY of BARACK HUSSEIN OBAMA by TONY DOLZ

able to verify that there is a match between the birthday claimed by Barack Hussein Obama (08.04.1961) and the Social Security number issued in the state of Connecticut (042-68-4425) which is the number Barack Hussein Obama uses on his tax returns. (See exhibits, reports from three investigators and two U.S. government documents linking the birth date and the Social Security number) Exhibit 5 8. Dr. Taitz received an affidavit from a witness, Linda Jordan, According to the E-Verify system feedback, there is no

who ran an E-Verify check for Social Security number 042-684425. match between Obama's name and the Social Security number he is using in his tax returns and his Selective Service application. (See Exhibit 4 9. Dr. Taitz received an e-mail from a US Army officer, Colonel Gregory Hollister. Col. Hollister conducted an independent check and found, that indeed Barack Hussein Obama is using Social Security number 042-68-4425, issued in the state of Connecticut. Mr. Hollister queried the Social Security Number Verification Systems (SSNVS) and found that the Social Security number Barack Hussein Obama is using was never assigned to him. (See exhibit 6). It is worthy to note there is a clear pattern of Social Security fraud by Obama's family members and close associates. Recently, Obama's uncle, Onyango Obama, was arrested for drunk driving and found to be using for employment a Social Security number, even though he is an illegal alien. Illegal aliens are not allowed to
ELECTION LAW COMPLAINT – BALLOT CHALLENGE of CANDIDACY of BARACK HUSSEIN OBAMA by TONY DOLZ

apply or receive Social Security numbers and not allowed to work in the United States. Obama's aunt, Zeutuni Obama, was stealing taxpayer dollars by unlawfully living in subsidized housing and using a Social Security number assigned for state of Indiana residents, even though she is an illegal alien and was never a resident of the state of Indiana. Obama's close associate, mentor and co-board member from Annenberg Challenge, William Ayers, in his book "Fugitive Days" admitted to creating over a hundred fraudulent Social Security numbers, using names of deceased infants, who did not get Social Security numbers assigned to them before their death. 10. Since his inauguration three years ago, Obama has refused to provide to the public his valid long-form birth certificate, in spite of countless requests from individuals, academia, journalists, the media, authors, researchers, political scientist and a array of people who have a legitimate interest in getting the information; and most of all citizens who have the right to know the legitimacy of the representatives that they elect. On April 27, 2011, Obama posted his alleged long-form birth certificate on his official White House website. As it was the case with the posting online of his tax returns, he originally did not flatten the Adobe PDF file and consequently anyone with an Adobe Illustrator graphics editing program on his computer could see layers of alterations in this alleged "birth certificate", which looked like a complete joke. Adobe Illustrator comes standard as part of a suite of Adobe programs called Adobe Collection CS.
ELECTION LAW COMPLAINT – BALLOT CHALLENGE of CANDIDACY of BARACK HUSSEIN OBAMA by TONY DOLZ

The ubiquitous Adobe Photoshop is part of this suite, so it is very common for owners of Adobe programs to have Adobe Illustrator installed in their computers as part of the suite. Multiple long form birth certificates from 1961 are available. In those years, green safety paper was not available and was not used. Other birth certificates, as the one for Susan Nordyke, a child born the next day on August 5, 1961, in the same hospital, and signed by the registrar on August 11, 1961, show white paper with yellow aging stains, clear borders, raised seal and a lower serial number. Obama's alleged birth certificate is on a safety paper, which was not used in 1961, does not have a clear border, does not have raised seal and the serial number is higher than the numbers issued later by the same registrar. See Exhibit 9. 11. Dr. Taitz received an affidavit from Adobe illustrator expert Papa’s See

Chito Papa detailing his examination of the alleged Obama longform birth certificate released by Obama on April 27. Exhibit 3 Mr. Papa’s report shows layers of alteration of the alleged birth certificate. The suspect long-form birth certificate shows clear and convincing evidence that Stanley Ann D. Soetoro’s (Obama’s mother) signature was erased, whitened out and that a computer graphics editing program was used to add the text "unham Obama" and a signature "Stanley Ann Dunham Obama". According to Mr. Papa, this was done by cutting and pasting digitally and filling in the blanks with a computer graphics editing program.
ELECTION LAW COMPLAINT – BALLOT CHALLENGE of CANDIDACY of BARACK HUSSEIN OBAMA by TONY DOLZ

research provides clear and convincing evidence of fraud.

12. Dr. Taitz received an affidavit from scanning machines expert Douglas Vogt. See Exhibit 8. It shows further evidence of forgery, such as the detection of different types of ink used. Parts of the birth certificate shows grey scale scanning (containing shades grades of grey). Some parts are black and white scanning (with black and white and no shades grades of grey in between). Some parts show evidence that the scanner scanned a color object. The suspect birth certificate contains different types of fonts and kerning ratios. Kerning, in digital text editing, enables the editor to increase or reduce the space between letters and sometimes purposely encroach upon the space of other letters. Editing, as it was done on the birth certificate and documented by Mr. Vogt, is only possible with the use of a modern computer and graphics editing programs, such as the Adobe Corp.’s suite of programs, including Photoshop and Illustrator. The problem is that in August of 1961, no computers and graphics programs of this type existed – they had not been invented yet. At the time of Obama’s birth, documents were completed with typewriters. Unlike graphics programs, typewriters are built with one fixed font type and no possibility of adjusting the kerning ratios. In the case of the advanced for its day IBM Selectric typewriter, which was released in or around 1961, the operator could change the typing element, but then all fonts were in the same family of font, rather than allowing mixing of fonts. Numerous other parameters lead to the same conclusion: the “birth certificate” released by Obama is not a copy of a 1961 typewritten document, but a computer-generated forgery,
ELECTION LAW COMPLAINT – BALLOT CHALLENGE of CANDIDACY of BARACK HUSSEIN OBAMA by TONY DOLZ

created by cutting and pasting bits and pieces from different documents and filling in the blanks with computer graphics. It appears that Obama used a Social Security number of a deceased elderly individual, as well as a birth certificate number of a deceased infant. Research pointed to the fact that a child by the name of Virginia Sunahara was born in Honolulu on August 4, 1961 and passed away the next day. Recently, her surviving brother Duncan Sunahara, demanded to see her long-form birth certificate, but the Hawaii Department of Health denied the request, even though it came from a close relative. Department of Health provided Mr. Sunahara only with a computer generated short form birth certificate with a serial number, which was suspiciously out of sequence with all the other numbers issued to infants born August 4, 1961. See Exhibit 10

In spite of numerous demands, Director of Health of Hawaii, Loretta Fuddy, refuses to allow the inspection of the original birth certificate of either Obama or Sunahara, in lieu of the alleged certified copy. The Social Security Administration refuses to provide even a redacted application for SSN 042-68-4425, issued in the state of Connecticut, which Obama is fraudulently using. It is imperative that this office investigate not only Obama, but also the Director of Health Loretta Fuddy, the Registrar Alvin Onaka, the Deputy Attorney General Nagamine and the former Chairwoman of the 2008

ELECTION LAW COMPLAINT – BALLOT CHALLENGE of CANDIDACY of BARACK HUSSEIN OBAMA by TONY DOLZ

Democratic National Convention, Nancy Pelosi. her an accessory to conspiracy and fraud.

Nancy Pelosi

certified Obama's prior Certificate of Candidate which could make

Also, meriting investigation of probable cause of conspiracy to commit fraud, altering of forged documents, election fraud and Social Security fraud are: Attorney General Eric Holder; Commissioner of Social Security, Michael Astrue; number of judges involved in this affair. 13. Based on all of the above, Obama does not have valid as well as a

identification papers, which are necessary to be a candidate on the ballot, running for the US Presidency, based upon New Hampshire elections law 655-17 and others and Article 1, Section 2 of the U.S. Constitution. 14. Whereas some argue today that a Natural Born Citizen, as it is applied to the U.S. Presidency in Article II, Section 1, Clause 5, means a person born in the United States, regardless of the citizenship of the parents, there is longstanding evidence and supporting Supreme Court opinions that are clear and definitive to the contrary. Exhibits accompanying this complaint document that from the time of the adoption of the Constitution until today, the standard for a Natural Born Citizen is: one born in the country to parents who are citizens and who do not owe allegiance to other nations. The US Constitution labors in making a distinction between Natural Born Citizen and Citizen was based upon the legal definition found in "Law of Nations" by Emer De Vattel. De Vattel
ELECTION LAW COMPLAINT – BALLOT CHALLENGE of CANDIDACY of BARACK HUSSEIN OBAMA by TONY DOLZ

wrote that Natural born Citizens are ones born in the Nations to Citizens (Emer De Vattel "Law of Nations" p499, §212). A similar definition was used by John Bingham, creator of the 14th Amendment, who stated during Congressional hearings on the 14th amendment, that a "Natural born citizen is born in the U.S. territories to parents who didn't owe allegiance to other sovereignties". A supporting definition was used in the case Minor v Happerset (1875), heard by the Supreme Court, with an opinion from Chief Justice Morrison Waite. Obama's father was never a U.S. Citizen. He never even had a legal resident permit (“Green Card.”) Obama Sr. was in the U.S. for a few years on a student visa and as such Barack Hussein Obama, the son, did not satisfy the test for Natural Born Citizen status. Even if this office considering Barack Hussein Obamas alleged election law violations were to subscribe to a liberal definition of the Natural Born Citizen requirements of Article II, Section 1, Clause 5, Obama does not meet the requirements for two reasons: (1) Obama has not proven his birth in Hawaii and instead he has submitted a highly suspect computer-generated forgery rather than a valid long-form birth certificate and (2) Obama is fraudulently using a Social Security number, which was never assigned to him. This case, on the strength of the submitted evidence, shows a potentially unprecedented level of corruption and lawlessness in
ELECTION LAW COMPLAINT – BALLOT CHALLENGE of CANDIDACY of BARACK HUSSEIN OBAMA by TONY DOLZ

the federal government and in the government of Hawaii, which allowed Obama to get on the ballot in 2008. cannot continue. The petitioner, Tony Dolz, demands removal of Barack Hussein Obama from the ballot in the state of New Hampshire, in the Democratic Party primary election and demands the immediate investigation and criminal prosecution of Obama and his accomplices for election fraud, common law fraud and altering/ forgery of documents. This lawlessness

ELECTION LAW COMPLAINT – BALLOT CHALLENGE of CANDIDACY of BARACK HUSSEIN OBAMA by TONY DOLZ

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