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1 IN THE UNITED STATES DISTRICT COURT

2 FOR THE SOUTHERN DISTRICT OF INDIANA


3 INDIANAPOLIS DIVISION
4
Menes Ankh El and Ogbonna Shakur
5
El on behalf of all registered Nationals Case: 1:23-cv-01098
6 of the Moorish Republic Nation
Plaintiff
7
v. Rule 60(b) Motion for Relief from
8
UNITED STATES f/k/a/ United States Judgment.
9 in Congress Assembled,
10 The United States of America
Defendant.
11
12 The Moorish Republic Nation wishes to bring Ourselves within Rule 60(b),
13 which applies if “any other reason justifying relief” is present. (see Klapprott v.
14 United States, 335 U.S. 601. In support of this Motion, We state the following:
15 On August 3, 2023 this Court dismissed this action stating that it did not
16 have subject matter-jurisdiction. To date, we have not received the initial order or
17 the final order.
18 Our first claim for relief in this action is that the “Registered Moorish
19 Republic Nationals are not United States citizens or citizens of any state of the
20 United States of America.” As We consider the Defendants in this action a foreign
21 occupying nation or corporation, Title 28 U.S.C. § 1330 gives this Court subject-
22 matter jurisdiction.
23 As We do not consider ourselves U.S. or State citizens of any of the United
24 States of America this raises a federal question. As this is also an issue pertaining
25 to U.S. citizenship, and the reach and function of the 14th Amendment, there is a
26 federal question to be answered. That question sits squarely in the subject-matter
27 jurisdiction of this Court pursuant to Title 28 U.S.C. § 1331.
28 Also, pursuant to Title 28 U.S.C. § 1346, the United States is a Defendant in
29 this action. §(a)(2) of this title gives the Court subject-matter jurisdiction, as this
30 action does not exceed $10,000, and is founded upon the Constitution. Also, as this

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31 action also deals with the immigration and naturalization statutes, this Court has
32 jurisdiction due to this being an act of Congress. As We are also claiming our
33 Indigenous connections to the land that the United States is currently occupying,
34 §(f) also firmly places this action within the subject-matter jurisdiction of this
35 Court.
36 Our second claim for relief is that “the Nationals of the Moorish Republic
37 have the human right to their Moorish Nationality and the Moorish Republic
38 government.” Although these particular statutes were inadvertently left out of the
39 jurisdictional statement, Title 28 U.S.C. §§ 1350, 1367(a) would also give this Court
40 jurisdiction. As Our second claim revolves around the treaties of the United States,
41 §1350 places this action in the jurisdiction of this Court. §1367(a) would also give
42 this Court supplemental jurisdiction.
43
44 WHEREFORE, We, the Moorish Republic, the Plaintiffs, respectfully request that
45 this Honorable Court grant Our request for relief and rescind its order of dismissal.
46
47 Respectfully submitted,

48 /s/Menes Ankh El
49 Menes Ankh El,
50 Chief Representative of the Moorish Republic
51 on behalf of the Nationals of Moorish Republic
52
53 CERTIFICATE OF SERVICE
54 I certify that this document was electronically filed with the U.S. District Court for
55 the Southern District of Indiana, Indianapolis Division on November 2, 2023.

56 /s/Menes Ankh El
57 Menes Ankh El

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