Amended motion for reconsideration
April 27, 2010
.S. District Court
District of Columbia
Notice of Electronic Filing
The following transaction was entered on 4/27/2010 at 10:58 AM and filed on 4/27/2010
Case Name: TAITZ v. OBAMA
Case Number: 1:10-cv-00151-RCL
Filer: ORLY TAITZ
WARNING: CASE CLOSED on 04/14/2010
Document Number: 25
Amended MOTION for Reconsideration by ORLY TAITZ (Attachments: # (1) Appendix Notice of motion for reconsideration)(TAITZ, ORLY)
1:10-cv-00151-RCL Notice has been electronically mailed to:
Alan Burch firstname.lastname@example.org
ORLY TAITZ email@example.com
Dr. Orly Taitz, esq.
29839 Santa Margarita Parkway, STE 100
Rancho Santa Margarita CA 92688
Tel: (949) 683-5411; Fax (949) 766-7603
UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF COLUMBIA
Dr. ORLY TAITZ, ESQ, PRO SE §
Plaintiff, §HONORABLE ROYCE LAMBERTH
v. § Civil Action: 10-151 RCL
§ MOTION FOR
Barack Hussein Obama,
§ MOTION FOR LEAVE OF COURT
§ TO FILE A SECOND AMENDED
§ COMPLAINT WITH
§ PRESIDENTIAL CANDIDATE
§ AND VICE PRESIDENTIAL
Defendant. § CANDIDATE ON THE BALLOT
§ IN 2008 ELECTION AS ADDITIONAL PLAINTIFFS
MOTION: REQUEST TO FORWARD TO THE ATTORNEY GENERAL ERIC HOLDER REQUEST FOR APPOINTMENT OF A SPECIAL PROSECUTOR TO INVESTIGATE AND PROSECUTE MULTIPLE ACTS OF SOCIAL SECURITY FRAUD, PERJURY, IDENTITY THEFT, FRAUD AND OTHER POSSIBLE FELONIES PERPETRATED BY MR. BARACK HUSSEIN OBAMA.
ORAL ARGUMENT REQUESTED AS MATTERS OF LAW AND FACT ARE AT ISSUE
Plaintiff would like to start this motion for reconsideration with reference to your remark in your latest order regarding Plaintiff’s quixotic quest.
Yes, Taitz would agree that it is extremely difficult to be a person, an attorney, who brings forward evidence, showing that the sitting president of the United States is committing multiple felonies and needs to be criminally prosecuted, however if Your Honor will be so kind to review some historic events, Your Honor will see that some events considered quixotic at a time, were correct, just and successful in the long run.
When Susan B. Anthony undertook a cause of voting rights for women, many laughed and considered her quest to be quixotic, yet she succeeded and we see today a first female Speaker of the House, female Presidential and Vice Presidential candidates and female senators and congresswomen as a direct result of her quixotic quest.
When a young woman by name Golda Meir set on her quest to build a Jewish state after six million Jews were killed in the Holocaust, many considered her actions quixotic, yet she succeeded and became the mother of the state of Israel.
When Margaret Thatcher and Ronald Reagan set on the quest to defeat the Communist Soviet Union, many considered them as Don Quixote and Sancho Panza, yet they succeeded, and the iron curtain was lifted, the Berlin Wall fell and free people marched through the Brandenburg gate.
Today it might seem an impossible quest, but Taitz is fighting to make sure that the Constitution of the United States of America does not turn into a Dulcinea, who is never rescued by her Prince in Shining Armor.
Plaintiff wants to make sure, that she, as well as three hundred and five million American citizens are not treated as brain-dead robots, as a herd of sheep by Barack Hussein Obama who went through life with multiple Social Security numbers, who is sitting in the White House today using the Social Security number 042-68-4425 (which was assigned in the state of Connecticut to another individual born in 1890), who never provided any vital records that would be admitted in any court of law, and who does not even possess a valid long form birth certificate with the name of a doctor, name of a hospital and signatures; who has allegiance to three other Nations and god knows who else. Plaintiff is not asking your Honor to tilt windmills, but rather uphold the US Constitution, that your Honor took an oath to protect.
Motion: Request to Forward to the Attorney General Eric Holder for appointment of a special prosecutor to investigate and prosecute multiple acts of Social Security Fraud, Perjury, Identity Theft, Fraud and other possible felonies perpetrated by Mr. Barack Hussein Obama.
On 12/21/94, when your Honor reviewed evidence presented and found that Mr. Ira Magaziner has committed perjury, your honor contacted Eric Holder, prosecutor at that time, and asked him to start an investigation of Mr. Magaziner for perjury and criminal contempt. Your honor also asked Attorney General Janet Reno to appoint an independent counsel to investigate the affair. According to the US Constitution, nobody is above the law. Millions of American citizens are following this case, as are Millions around the World. Even if your Honor does not find injuries sustained by the Plaintiff to be sufficient and the connection to Barack Hussein Obama to be strong enough, your Honor clearly has seen evidence of numerous felonies committed by Barack Hussein Obama:
1.Social Security Fraud 42 USC §408 (a)(7)(B), which is punishable under title 18 with up to 5 years in prison for each offense (Investigator Sankey shows some 39 different Social security numbers used);
2.Conspiracy to defraud the United States 18 USC §371, which carries up to five years in prison for each offense;
3.Perjury 18 USC §1621 with up to five years in prison for each offense
There are other crimes committed such as elections fraud, voter fraud, identity theft, that any other US citizen would have been convicted of and serving a lengthy prison term for the above crimes. Plaintiff is asking your Honor for equal treatment of the law for Mr. Obama, just as your Honor has treated other parties and any other citizen, and to forward the request to the US Attorney’s Office and Attorney General Eric Holder for appointment of a special prosecutor to investigate multiple felonies perpetrated by Mr. Obama.
Motion for leave of court to file a second amended complaint with two additional plaintiffs: Presidential candidate from American Independent Party on the 2008 ballot Ambassador Dr. Alan Keyes, and Vice Presidential Candidate on the ballot in 2008 election Gail Lightfoot.
Motion for reconsideration is allowed when there is an error of fact or law. While typically Quo Warranto is utilized by interested parties, who challenge the franchise of the government, §16-3502, does not specifically limit quo warranto to such parties, whereby Your Honor is not statutorily precluded from granting Taitz Quo Warranto.
§ 16-3502. Parties who may institute; ex rel. proceedings.
The Attorney General of the United States or the United States attorney may institute a proceeding pursuant to this subchapter on his own motion or on the relation of a third person. The writ may not be issued on the relation of a third person except by leave of the court, to be applied for by the relator, by a petition duly verified setting forth the grounds of the application…
As an attorney for plaintiffs, Keyes, Lightfoot and others, Taitz has submitted Quo Warranto requests to the Attorney General and US Attorney, who have not responded. Therefore, Taitz is asking for leave of the Court to proceed under Quo Warranto, and in case your Honor does not grant Quo Warranto to the Plaintiff, she moves for Leave of Court to file a Second Amended Complaint with two additional plaintiffs: Presidential candidate from American Independent Party in 2008 election Ambassador Dr. Alan Keyes, as well as Gail Lightfoot, a Vice Presidential candidate for a write in Presidential Candidate Ron Paul.
Additionally, Ambassador Keyes was a senatorial candidate in the state of Illinois. Plaintiff previously submitted to this Court the March 25th Official report of the National Assembly of Kenya. Page 31 of the report contains a statement of the minister of Lands James Orengo, clearly indicating Mr. Obama was born in Kenya, and there is no evidence of Mr. Obama going through proper immigration procedures after his birth. As such, not only is Mr. Obama’s Natural Born status in question, but his citizenship in general is in question, and whereby, Ambassador Keyes has suffered particularized damage in losing both the senatorial and presidential elections to one who is not entitled to hold office, which indicates clear standing.
Motion for this Honorable court to grant Plaintiff sua sponte admission to US District Court bar without local attorney movant.
Typically, admission to this court requires a sponsor/movant local attorney or a local counsel for pro Hac Vice. Due to the sense of fear associated with a legal action, implicating a sitting president, the damage by slander and libel of Taitz has chilled the opportunity to secure a local attorney as a pro Hac Vice movant; however Your Honor can authorize her acceptance to the court Sua Sponte without such pro hac vice movant. She requests Sua Sponte authorization of acceptance to this bar in order to represent above mentioned additional plaintiffs and opportunity to file a Second Amended Complaint on their behalf.
Commerce Clause claims
Your Honor has stated that the First Amended Complaint was filed prior to Patient Protection Act being signed into law, which signifies lack of standing. However, standing exists not only in relation to current injury; it exists in relation to imminent injury as well. Taitz has filed her First Amended complaint after the bill was approved by both houses of Congress and the injury was imminent, which suffice for standing. In the alternative Taitz is seeking a leave of Court to file a Second amended Complaint based on Amended Patient Protection Act, since the original act was modified through the process of reconciliation in Senate and House of Representatives, wherefore making any complaint in regards to the initial Patient Protection Act, moot.
Your Honor has stated that the FOIA complaint has failed since Taitz did not wait until April 9th for the administrative remedies to be exhausted. As there was no response to the FOIA request by April 9 th and none was received by today, April 26th, Taitz is moving this Honorable court for a leave of court to file a Second Amended Complaint for FOIA relief, due to the fact that by today, April 26th administrative remedies were exhausted and no relief was provided.
Fraud and RICO claims
Similarly, Taitz is seeking a leave of court to file a second amended complaint on these causes of action, more fully pleading reliance and damages based on 10th, 9th, 5th and 1st amendment with reference to the pattern of multiple crimes with more than two predicate acts of the enterprise, as well as more fully plead standing on the issues of fraud in relation to her Taxpayer standing and her Whistleblower status.
/s/ DR ORLY TAITZ ESQ
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