Civil Action: 10-151 - REPLY TO OPPOSITION TO PRELIMINARY INJUNCTION - ORAL

ARGUMENT REQUESTED
Dr. Orly Taitz, esq
29839 Santa Margarita Parkway, STE 100
Rancho Santa Margarita CA 92688
Tel: (949) 683-5411; Fax (949) 766-7603
E-Mail: [email protected]
UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF COLUMBIA
Dr. ORLY TAITZ, ESQ, PRO SE §
Plaintiff, §HONORABLE ROYCE LAMBERTH
§ PRESIDING
v. § Civil Action: 10-151 RCL
§
Barack Hussein Obama, § REPLY TO OPPOSITION TO
§
§ PRELIMINARY INJUNCTION
§
§ORAL ARGUMENT REQUESTED
§
Defendant. §
Motion for leave of court to add Ronald Machen , JR, US Attorney, Rudolph Contrehras,
Assistant US Attorney, Alan Burch, Assistant US Attorney as additional defendants and
add a Cause of Action for RICO-Racketeering Influenced Corrupt Organizations as an
Additional cause of action in the first Amended Complaint.

1. RICO
One of the reasons for need for recusal of the US attorney’s office, is a conflict of interest
between the interests of the main client of the US Attorney’s office-People of the United States
of America and interests of the Defendant Barack Hussein Obama.
The number one function of the US Attorney’s office is to protect us, the public from criminal
activity, violation of criminal statutes, fraud and treason.
I have presented in my Quo Warranto complaint not only ample evidence of Barack Obama
usurping the position of the President and Commander in Chief, but of him violating federal
statutes, defrauding Social Security and engaging in identity theft in using social security number
042-68-4425.
I have provided affidavits from licensed investigators, as well as an official Selective Service
printout, showing him using this Social Security number, even though it was assigned to another
individual, born in 1890 and assigned in CT between 1976-1977, while Obama resided in HI,
and in light of the fact that Obama was never a resident of CT.
This evidence is so overwhelming, that it doesn’t even require additional investigation.
• Pursuant to US Code Title 18, Part 1, Chapter 1 § 4 – Misprision of Felony
• § 5-121.05. Compromise of felony ; withholding information; receiving
compensation from person arrested or liable to arrest; permitting escape.
It is unlawful for any private detective, or any member of the police force, or for
any other person to compromise a felony or any other unlawful act, or to
participate in, assent to, aid or assist any person suspected of crime to escape a full
judicial examination by failing to give known facts or reasonable causes of
suspicion, or withholding any information relative to the charge or suspicion from
the proper judicial authorities; or in any manner to receive any money, property,
favor, or other compensation from, or on account of, any person arrested or subject
to arrest for any crime or supposed crime; or to permit any such person to go at
large without due effort to secure an investigation of such supposed crime. And for
any violation of the provisions of this section, or either of them, such member of the
police force, or private detective, or other person guilty thereof, shall be deemed as
having compromised a felony , and shall be thereafter prohibited from acting as an
officer of said police force, or as a private detective, and shall be prosecuted to the
extent of the law for aiding criminals to escape the ends of justice.
Title 18, Part 1, Chapter 1 § 3. Accessory after the fact:
Whoever, knowing that an offense against the United States has been committed, receives,
relieves, comforts or assists the offender in order to hinder or prevent his apprehension,
trial or punishment, is an accessory after the fact. Except as otherwise expressly provided
by any Act of Congress, an accessory after the fact shall be imprisoned not more than one-
half the maximum term of imprisonment or (notwithstanding section 3571) fined not more
than one-half the maximum fine prescribed for the punishment of the principal, or both; or
if the principal is punishable by life imprisonment or death, the accessory shall be
imprisoned not more than 15 years.
US attorneys’ actions in not prosecuting this matter goes beyond mere negligence, it falls within
the realm of misprision of felony, compromising of felony and aiding and abetting commission
of felony, predicate acts, which will tie in the above US attorneys to Mr. Obama and sufficient
for RICO legal action.
These actions of Obama and US attorneys have exposed me to further severe emotional distress,
assaults, insults, death threats, and numerous hate crimes relating to my legal actions,
representing my clients and myself and trying to protect the public at large from this massive
fraud committed by Obama and currently aided and abetted by US attorneys.
2. As felonies were reported, the court itself cannot ignore those issues and obligated to
investigate
Evidence reported in the complaint and the application for preliminary injunction provides
affidavits of licensed investigators as well as Selective service official printout, which clearly
indicate use of multiple social security numbers, social security fraud, identity theft, fraud as
well as high likelihood of a number of other white color crimes by the defendant. At this point if
the court does not grant the application or dismisses the complaint, the court itself will be guilty
of aiding and abetting all of the above crimes and misprision of felonies. As such the court has
no other alternative, but to proceed with the discovery, and proceed expeditiously.
3. The court is entitled to obtain Defendant’s Records.
The defendant intentionally misrepresents the complaint by claiming that the plaintiff is not
entitled to the Defendant’s records quoting Freedom of Information Act.
This is a case of Quo Warranto. The defendant is an attorney, who during the campaign
represented himself as a constitutional scholar and a constitutional professor. As such he is
surely aware of the fact that Quo Warranto has existed for some 700 years before the Freedom of
Information act was ever enacted.
I have requested that the Attorney General and US attorney fulfill their duties and verify
Obama’s qualifications under Quo Warranto. As they breached their duties, I am asking the court
to grant me Ex Relator Status, step in the shoes of these derelict US attorneys, who didn’t do
their job, which we, the tax payers, have paid them to do. As the court grants me Ex Relator
status, I will be entitled to obtain all the necessary records to prove or disprove Obama’s
legitimacy. This shows that the Defendants assertion that I have no Entitlement to records is an
absurd and was brought to confuse Your Honor.
4. Defendant’s claim that my complaint is a non-justiciable political question, is a complete
absurdity and was brought to mislead Your Honor.
About a third of the brief, 4-5 pages is completely irrelevant, as those are devoted to the
mechanisms of the elections and removal of the president from office. I have never asked your
Honor to remove Mr. Obama from office. All I have asked for, is discovery, and based on this
discovery, a declaratory relief, declaring whether Mr. Obama has indeed qualified to office or
not per Quo Waranto and per Article 2, Section 1 of the Constitution. Did he provide valid
records or did he defraud the voters, Electors and Congress? This is the whole purpose of Quo
Warranto. Quo Warranto was used for hundreds of years. It is codified in DC statutes as
explained in the complaint. The Department of Justice and US Attorneys’ office in the Central
District of CA argued that the District of Columbia is the proper jurisdiction and Judge David O.
Carter has dismissed the Quo Warranto in CA, noting that he doesn’t want to “rob the District of
Columbia of its’ Jurisdiction.” We are now in the correct jurisdiction, I applied correct statutes.
After the discovery and trial, your Honor will make a Declaratory Relief, whether the defendant
was qualified based on Quo Warranto or whether he occupied his position based on fraud. After
the declaratory relief the Congress and Senate will be able to proceed with impeachment and
removal. I am providing, as exhibits, letters I have received from Senator McCain, Mr. Obama’s
opponent in the 2008 general election, and a letter from senator Sessions received by one of my
supporters. Both letters state that they cannot get involved, while the matter is being decided by
the courts, as this will be seen as an ethical violation and interference with the work of another
branch of the government. As the District of Columbia is a proper jurisdiction and Congress
cannot get involved until there is a judicial determination and declaratory relief, it is not only
your right your Honor to adjudicate, it is not only a justiciable issue, but as the Chief Judge
for the US District Court for the District of Columbia, you have a duty to exercise your
jurisdiction, as according to the undying words of Justice Marshall, not exercising
Jurisdiction, where it lies, is a treason to the Constitution.
Moreover, I have presented evidence of felony committed by the defendant in his use of
multiple Social Security numbers, as well as clear evidence of his use of the Social Security
number of at least one deceased individual. Your Honor, as an officer of the court, you have an
obligation to proceed, as not doing so will expose Your Honor to the liability of aiding and
abetting commission of felony and misprision of felony. Your Honor has no other choice, but to
proceed with the discovery.
5. Standing
As I have stated previously, this complaint is a motion for leave of court for Ex Relator status in
Quo Warranto. DC statute does not require any particular standing or any damages for Quo
Warranto, therefore standing and damages are moot points, brought by the defendant to
simply muddy the issues.
Muddy the issues, is probably the operative term to characterize the opposition brief, as it didn’t
address any issue, didn’t address any law or any injury. It was written specifically to skirt the
issues, misrepresent the facts and belittle and denigrate me in the eyes of the court. Very telling,
is a remark on page 8,line 1, calling application for preliminary injunction rambling. I have to
state that the opposition brief definitely goes beyond rambling, it goes into the territory of assault
on the intelligence of each and every American, and there are millions of Americans following
this case. The opposition brief did not address any fact or any law presented in the application.
The defense claims that I didn’t suffer any injury. The defense can’t find any injury in the
Obama administration applying pressure on different agencies intimidating and harassing me and
my plaintiffs and investigators. They could not find any harm in daily death threats, vandalism,
tampering with my car and endangering my family, constant assaults coming from the media,
which became the regime propaganda machine, from the law enforcement and US attorney’s
office itself refusing to investigate any crimes against me, or from use of the Judiciary as a tool
to intimidate me and endanger my law license.
What exactly will it take for the Department of Justice to concede that indeed I was harmed or in
imminent danger of being harmed? Do I need to be actually crucified? Knowing the modus
operandi of Holder Department of Justice, I am not sure even that will be enough. They might
still find some reason to state that there was no harm, no injury. They probably will state that the
nails were not long enough, who knows…
The extent of damages and indifference and unwillingness to act by law enforcement and the
Department of Justice has prompted me to file a complaint with the UN commission for Human
Rights defendants.
To summarize the issue of damages standing, I have enumerated my damages in grand detail in
the complaint, however I did not need to show any damages, as Quo Warranto statute does not
require one seeking ex realtor status any particular standing or damages.
6. Additional standing as a Republican candidate for the position of Secretary of State of
California
Currently I am running as a Republican for the position of the Secretary of State of California. I
have previously on multiple occasions requested from the current Secretary of State Debra
Bowen, a Democrat, information regarding Mr. Obama’s eligibility. I believe that Ms. Bowen
has refused to verify Mr. Obama’s eligibility and refused to provide me and my clients,
candidates on the ballot in 2008 election, pertinent information for political reasons. There was
no justification in her refusal to verify Mr. Obama’s vital records and eligibility. I have filed
legal actions in the state of CA on behalf of my client Ambassador Alan Keyes, presidential
candidate on the ballot in Keyes et al v Bowen et al, as well as on behalf of vice presidential
candidate for Ron Paul, Ms. Gail Lightfoot. On December 12, at 4:40PM, before the electoral
vote I have filed with the Supreme Court on behalf of Gail Lightfoot et al an application for stay
of the electoral vote Lightfoot et al v Bowen 08A524 . Chief Justice John Roberts has decided to
hear this case in the conference of all nine Justices on January 23, however inexplicably the case
was erased from the docket on January 21st. After complaints from the public the case was re-
entered on the docket, however at a later date, as I questioned Justice Scalia about the case, he
had no knowledge of the existence of the case. I have addressed this matter with Justice Roberts
on March 13, 2009. (youTubeOrlyTaitzAddressingJohnRoberts). After nearly a year I did not
hear from Justice Roberts or any of the law enforcement in relation to erasing of my case from
the docket.
All the above facts show that I in good conscience exhausted all means available, and Quo
Warranto is the only legal action available to resolve the issue of eligibility and suspected fraud
committed by the defendant in the 2008 Presidential election.
7. Traceability of injury
The defense is stating that the injury of $20,000 sanctions is not traceable to the defendant. Let’s
try it again slowly.
I never had any sanctions assessed against me: never before and never after. I never had
any reprimand against me. I have a perfectly clean record. The only time in my life, when I
was sanctioned by the court, is where Judge Land stated that my representation of the members
of US military questioning Barack Obama’s legitimacy to presidency is frivolous, and due to that
he sanctioned me.
Let’s see, what did he find frivolous? I forwarded to Judge Land reports from licensed
investigators, showing that Obama used multiple social security numbers, none of which were
issued in Hawaii, where he claims he was born, and where he was raised. Who is usually using
multiple social security numbers of others? Typically people, who were not born in this country,
are the people, who do not have a valid social security number and need to resort to stealing the
Social Security numbers of others.
I presented information that Obama refused to unseal his original birth certificate and all other
vital records, and the fact that the state of Hawaii statute 338-17 allows a foreign born child of
Hawaiian resident to get a Hawaiian birth certificate, as well as the fact that statute 338-5 allows
one to get a birth certificate of one relative based on a statement of one relative only without
any corroborative evidence. This evidence is at least sufficient evidence to order discovery.
Clearly there is nothing frivolous in bringing an action on behalf of the members of the military
seeking to verify Obama’s legitimacy in light of all the above facts.
Who sealed his original vital records, who is refusing to unseal them? Obama!
Who is using social security numbers of deceased individuals and numbers never assigned?
Obama!
Judge Land is a federal employee and as such works for the Chief Executive in the Federal
government, Obama. Does the assistant US attorney have to be Albert Einstein to be able to
trace the connection between Barack Obama’s social security fraud, his obfuscation of all of his
records, my bringing this issue to court and the decision by judge Land to use $20,000 in
sanctions to silence me? I believe traceability is very clear and I don’t need to belabor on this
any further.
8. Background of the case
About a third of the brief is dedicated to the background of the case, which was completely bent
out of shape and the truth was misrepresented. I don’t need to write 5-6 page of the background.
I can summarize the background of the case in one sentence. Obama’s legitimacy for presidency
was never adjudicated on the merits, no discovery was done, since no judge so far had the guts to
hear the case on the merits.
We don’t need to go far. A year ago Attorrney John Hamenway, 30 year veteran of JAG and
State department foreign corps have brought to this district court Obama eligibility issue
Hollister v Soetoro. Obama was named by the last name he used in Indonesia, Soetoro, since
there is no record of him legally changing his name back to Obama, and there is a high
likelihood that Obama was inaugurated and sworn in under the name, which is not legally his.
Judge James L. Robertson came up with a decision, that the proper prima facia evidence should
not be viewed and discovery and trial should not go on, since Obama’s legitimacy for presidency
“was twittered and massaged on the blogs”. The whole country didn’t know whether to laugh or
to cry reading this opinion of a Federal judge. To add insult to injury Judge Robertson has
threatened attorney Hemenway with sanctions. Same modus operandi, as I experienced with
Judge Land. The only difference was, that older Judge Robertson had enough life wisdom,
common sense and experience to stop short of actually assessing those sanctions, he stopped at
repriment, which Hemenway is currently appealing in the Court of Appeals. Younger and more
eager to get promotions Judge Land actually assessed those sanctions. Regardless of nuances
both decisions are upfront to basic law and Constitution and decency. Today Judge Robertson is
known through the blogosphere, through the Internet as a twitter judge. As I have filed my
complained with the UN and has given some 700 interviews all over the World. Attorney, judges
and public around the World are buffled and bewildered at what is happening in the US. Clearly
Judge Robertson knows that twittering and massaging on the blogs is not a proper form of
evidence, that there is a need to unseal the original birth certificate and all the other vital records.
So what is the explanation to such indefensible decisions? The only reasonable explanation, is
that not only attorneys like I and Hemenway were threatened, but Federal Judges themselves
were threatened and intimidated by the Obama regime, by the Obama administration, that there
was some fear of retaliation from Holder department of Justice, from Pelosi Congress.
Here is another example. I am forwarding a transcript of the July 13 hearing in Keyes et al v
Obama in front of judge David O. Carter in the Central District of CA (as more plaintiffs were
later added to the case, and the plaintiffs were listed in alphabetical order, it was renamed as
Barnett et al v Obama et al). At a time when Judge Land claimed that Obama illegitimacy cases
are frivolous, a more experienced judge David O. Carter was stating on the record time and again
that this case is very important for the military and for the country as a whole, and it needs to be
heard on the merits. Judge Carter has scheduled the case for trial for January 26, 2010 in CA.
Later, on October 1, 2009 Obama administration was able to place as a law clerk with judge
Carter one Sidharth Velamoor, an attorney who is still listed as working for Perkins Coie,
Obama’s defense firm, the firm of Robert Bauer, Chief White House Legal Counsel. From
October 1 the attorney for the defense firm was doing legal research for the presiding judge and
drafting orders. Is it surprising to you Your Honor to find out that judge Carter has suddenly
changed his opinion and decided that he no longer has jurisdiction, even though he was adamant
he had it before. I suddenly felt that I was immersed back in the nightmare of the dictatorial
regime of the Communist Soviet Union, from which I escaped earlier. There were other
interesting connections and correlations between Mr. Velamoor and Mr. Obama. Both of them
are officially graduates of Columbia university, however different legal directories show
Velamoor graduating either from Columbia law school or Commenis law school in Bratislava
Slovakia and some 400 students attending Columbia same time as Obama and taking same
courses as Obama can’t remember seeing him there. Yet another interesting fact: both came from
the same small community of Mercer island, WA. While Obama claims, that his mother lived on
HI in 1961-1962, official records of the university of HI show her as dropping out at this time.
She was nowhere to be found for nine months from December 1960 to end of August 1961,
when she reappeared on Mercer island and enrolled as a student in University of Seattle
Washington for Fall and winter quarters of 1961-1962. Nothing about Mr. Obama seems to be
true. A lot about Mr Obama is questionable an a reason for deep concern. What I am doing
today is equal to a new civil rights movement, a movement to reassert civil rights of the US
citizens to have their cases heard in the court of law based on the Constitution, based on clear
evidence, proper original valid records, not based on twittering, not based on intimidation of
judges and attorneys. If Obama regime is successful in silencing attorneys like me, working pro
bono to uphold the constitutional freedoms, then we don’t have a Constitution, then we have a
dictatorship, a tyranny.
Your Honor the choice is clear: you can be one of those judges who summarily dismissed each
and every pleading by Thurgood Marshall, not willing to rock the boat and the establishment, or
you can be Judge Earl Warren of the 21st Century and uphold the system of Justice and the
Constitution.
Fraud is a fraud, regardless of who perpetrates it, whether it is perpetrated by one forging
documents to get a deed to a house or a lease to the White House. No one is above the law. The
Nation is watching and the Nation is waiting. UN committee for Defenders of the Human Rights
is watching and waiting for your decision. After I have done over 700 interviews all over the
World, the World is watching and waiting for your decision. Your decision can be one of
obfuscation of all of vital records of one sitting in the White House, it can be a decision of
aiding and abeting Social Security Fraud and Misprision of Felony of Social Security Fraud and
Identity theft by Mr. Obama, or it can be a decision of upholding the law. Your decision can
signify further persecutions of me, as a decedent fighting Obama regime, or it can be a decision
putting an end to persecutions. The decision is yours and the Nation is watching and the World is
watching.
Wherefore the plaintiff respectfully requests this Honorable court to deny the defendant’s motion
to dismiss and grant her application for injunctive relief as stated above.
/s/ DR ORLY TAITZ ESQ
By:__________________________________
Dr. Orly Taitz, Esq. (California Bar 223433)
Attorney for the Plaintiffs
29839 Santa Margarita Parkway ste 100
Rancho Santa Margarita CA 92688
Tel.: 949-683-5411; Fax: 949-766-7603
E-Mail: [email protected]
PROOF OF SERVICE
I CERTIFY THAT TRUE AND CORRECT COPY OF THE ABOVE PLEADINGS WAS
SERVED on 02.12.10 by First Class Mail.
Alan Burch, Assistant United States Attorney for the District of Columbia
555 4th str.,N.W.
Washington D.C. 20530
/s/Orly Taitz
Dr. Orly Taitz Esq
29839 Santa Margarita PKWY
Rancho Santa Margarita CA 92688
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