taitz v obama (qw) - 29 - reply to opposition - dcd-04502981918.29.0
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Case 1:1 0-cv-00151-RCL Document 29 Filed 05/19/10 Page 1 of 11
Dr. Orly Taitz, esq29839 Santa Margarita Parkway, STE 100Rancho Santa Margarita CA 92688Tel: (949) 683-5411; Fax (949) 766-7603E-Mail: [email protected]
UNITED STATES DISTRICT COURTFOR THE DISTRICT OF COLUMBIAr. ORLY T AITZ, ESQ, PRO SEPlaintiff, HONORABLE ROYCE LAMBERTH
v.Barack Hussein Obama,
Defendant.
PRESIDING Civil Action: 10-151 RCLREPL Y TO 05.11.10 OPPOSITION TO MOTION FOR RECONSIDERATION
Motion for Reconsideration is allowed and granted when new evidence ispresented and when there was a mistake of fact or law in the previous order.Three new facts are making an order for reconsideration justified and urgentlyneeded.On May 17,2010 Taitz has received a letter from Holder department of Justicedemanding $20,000 (Exhibit 1) for filing a legal action on behalf of CaptainRhodes, which Judge Land erroneously considered frivolous. This fact showsthat indeed damages and not conjectural, but rather imminent and substantial,which makes the complaint for fraud filed by Taitz, proper and justified. Taitz hassubmitted to this court a transcript ofthe assembly of the republic of KenyaMarch 25,2010 session, where Minister of Lands, James Orengo, clearly statedthat Obama was born in Kenya. Affidavits from former senior deportation officerwith the department of Homeland security John Sampson, as well as investigatorSusan Daniels and retired Scotland Yard investigator Neil Sankey and officialrecords of Selective Service show Obama using Social Security number _4425, which was assigned in the state ofCo=ecticut to another individual born in1890, which is consistent with all the other evidence of Obama's foreign birth andneed to use a stolen social security number. All of this evidence points to the fact
Taitz v Obama. Reply to Opposition to Motion for reconsideration 1
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Taitz v Obama. Reply to Opposition to Motion for reconsideration 2
that Barack Hussein Obama indeed committed massive fraud by submitting his
candidacy for the position of the President. It was foreseeable, that proud
members of US military, particularly officers will rise and revolt and demand
disclosure of the original birth records of the Commander in Chief to ascertain ifthe orders coming from him down the chain of command are legal, as well as
explanation, as to why Obama is using stolen social security numbers. It was
foreseeable, that those members of the military will hire an attorney. It was
foreseeable that such attorney will be persecuted for representing members of the
military standing up to this massive fraud perpetrated by Obama. Current letter of
demand of $20,000 and threat to pursue enforced collection against you directly
flaws from the fraud committed by Obama. As such, this new evidence shows
that Taitz has proper standing to sue Obama for fraud, as she was a foreseeable
victim, foreseeable plaintiff and she suffered damages as a result and as a
foreseeable consequence of fraud committed by Obama.
Additionally, new evidence presented in the form oftodays article in Mother
Jones magazine Exhibit 2 shows that there was a concerted effort of intimidation
and harassment of Taitz. Previously in her complaint Taitz presented evidence of
her car being tampered with, a group of convicted felons, convicted forgers were
working in unison and were submitting perjured affidavits, that looked prepared
by the same law firm, as well as art work, despicable in nature with a commondesire to intimidate and harass Taitz and her whole family and pressure her to
give up her legal pursuit of fraud committed by Obama and her campaign for the
position of CA secretary of state. Defense claimed that all of those incidents were
unrelated and did not show concerted effort or damages. Recent article by
Washington burro correspondent Stephanie Mencimer shows that artist Dan
Lacey, who painted despicable art work series Birther Orly Taitz, showing
Taitz nude, with her legs spread, giving birth and holding bloody placenta, which
were sent to her children, posted on the Internet and a local paper, did not work
on his own accord. Dan Lacey admitted, that he was commissioned, paid by
someone to do this, it was a clear attempt to intimidate Taitz and pressure her to
withdraw as a candidate. As far as damages are concerned $20,000 is only the tip
of the iceberg, as immeasurable emotional damage was caused to Taitz and her
whole family. Lacey refused to provide the reporter Stephanie Mencimer with the
name of the person who hired him, who paid him, however during the depositions
and upon subpoena this information will be available and will be provided to
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Taitz v Obama. Reply to Opposition to Motion for reconsideration 3
court. At the onset of the litigation Taitz cannot provide all the evidence and is
not obligated to do so. Taitz has showed sufficient evidence to show that she has
standing to proceed. This particular evidence is crucial, as it shows concerted
effort. At this time Taitz cannot state with certainty who paid Dan Lacey,however it is common knowledge, that Billionaire George Soros, one of the
biggest backers of Obama, through his organization Moveon.org, has
commissioned numerous artists to promote Obama and denigrate his opponents
and critics. Only discovery will provide the names of all the Jane Does and John
Does involved. At the end of the day Watergate was unraveled by tracing the
moneys received, the bank accounts of the Watergate burglars, ObamaFraudGate
will be fully exposed by tracing the bank accounts of individuals who were
involved in intimidation and harassment of Taitz, her family and others and the
bank accounts of individuals and organizations that commissioned them, as well
as tracing financial transactions correlating to multiple social security numbers
found in the National databases for Barack Obama, Barry Obama and Michelle
Obama as well as multiple current job employments listed in the dossiers.
1. Yet another fact, that became known after the original order was issued, isthe fact that Obama has appointed Solicitor General Elena Kagan to the
position of the Supreme Court judge. Many wondered why would the
President appoint a candidate, who never worked as a judge, not even as asmall claims court judge, not even as a traffic court judge. This fact becomes
less perplexing in light of the following information: Taitz forwarded to
Kagan, as a solicitor general, not only her pleadings of Lightfoot v Bowen,
submitted to the Supreme Court and distributed by Chief Justice John Roberts
for conference of all nine justices, not only Quo Warranto submitted to the
Supreme Court, but also all the dossiers sent to Attorney General Holder.
Kagan was sworn to uphold the Constitution and act on behalf of the People of
the United States of America, as a solicitor, top advocate for the United States
of America, not as a private attorney for Obama, she received information
regarding the fact that Obamas Social Security number was assigned to
another individual, that the certification of life birth provided by Obama to the
public could not be considered genuine without analyzing the original, yet she
did not take action and remained silent. In light of all of the above a question
begs to be asked: was there a quid pro quo, was the appointment to the
Supreme Court a thank you for her silence? This new development makes it so
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Taitz v Obama. Reply to Opposition to Motion for reconsideration 4
much more important to proceed with discovery in this case, see the evidence.
Otherwise we might end up with a justice of the Supreme Court who was
aiding and abetting the most outrageous felonies this nation has ever known.
Opposition to motion for reconsideration also includes a challenge to adding
former Presidential Candidate Allan Keyes and Vice presidential Candidate Gail
Lightfoot, questioning standing. Standing in this case is quite clear. If one ran in
the presidential election, which was won by a candidate, committing fraud, party
that lost has suffered damages in the form of lost election. Moreover, Ambassador
Keyes ran against Obama in senatorial election in 2004. Taitz has noved this
honorable court to grant her privilege to represent these clients without asignature of the local counsel. In extraordinary circumstances a presifing judge
can grant Pro Hac Vice or admission to the court without a signature of the local
counsel, only with a signature of the presiding judge. As most attorneys are
simply paralyzed with fear to stand up to the sitting president and establishment,
this constitutes such extraordinary circumstance.
Wherefore,
Plaintiff respectfully moves to grant her motion for reconsideration.
EXHIBIT 1Demand of $20,000 from the Department of Justice
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Taitz v Obama. Reply to Opposition to Motion for reconsideration 5
2.
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Taitz v Obama. Reply to Opposition to Motion for reconsideration 6
EXHIBIT 2May 18 2010 article from Mother Jones magazine, confirming that artist Dan Lacey was
commissioned (paid) to paint harassing pictures of Dr. Orly Taitz ESQ, Republican candidate for
CA Secretary of State.
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The Birther Queen Bee and the Painted
Pancake ByStephanie Mencimer
| Tue May. 18, 2010 3:00 AM PDT
Dan Lacey
Case 1:10-cv-00151-RCL Document 29 Filed 05/19/10 Page 6 of 11
http://motherjones.com/http://motherjones.com/user/login?destination=node/60182http://motherjones.com/user/registerhttp://motherjones.com/about/interact-engage/free-email-newsletterhttp://motherjones.com/about/interact-engage/free-email-newsletterhttp://motherjones.com/about/interact-engage/free-email-newsletterhttp://motherjones.com/bloghttp://motherjones.com/category/primary-tags/culturehttp://motherjones.com/category/primary-tags/culturehttp://motherjones.com/category/primary-tags/food-aghttp://motherjones.com/category/primary-tags/food-aghttp://motherjones.com/category/primary-tags/politicshttp://motherjones.com/category/primary-tags/politicshttp://motherjones.com/category/primary-tags/politicshttp://motherjones.com/authors/stephanie-mencimerhttp://www.faithmouse.com/about_page.htmlhttp://www.faithmouse.com/about_page.htmlhttp://motherjones.com/authors/stephanie-mencimerhttp://motherjones.com/category/primary-tags/politicshttp://motherjones.com/category/primary-tags/food-aghttp://motherjones.com/category/primary-tags/culturehttp://motherjones.com/bloghttp://motherjones.com/about/interact-engage/free-email-newsletterhttp://motherjones.com/user/registerhttp://motherjones.com/user/login?destination=node/60182http://motherjones.com/ -
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Taitz v Obama. Reply to Opposition to Motion for reconsideration 7
Orly Taitz, the queen bee of the birther movement, sounds distraught. Im going through hell, she says. The California
dentist-lawyer had called to tell me about what she says is a campaign to scare her family so that shell abandon her quest to become
Californias next Secretary of State. She says shes endured death threats and an attempt to tamper with her car. But this time, she
says, her opponents have gone too far. The final straw? An elaborate oil painting of a nude Taitz, legs splayed, giving birth to a
pancake.
First, a little back-story. For two years, Taitz has been demanding that Californias secretary of state request more evidence that
President Obama is truly an American-born citizen. In March, she got herself on the ballot to run for the job in the Republican
primary. But since declaring her candidacy, Taitz says that Obama supporters have been targeting her childrenshe has two in high
school and one in collegevia their Facebook pages with disturbing messages and images of their mother.
Exihibit A, says Taitz, is a series of paintings of her by Dan Lacey, the so-called pancake painter, who achievedminor
celebrity during the 2008 presidential race for his numerous depictions of a naked, muscular Obama perched atop a unicorn. Hes
also painted Sarah Palin, John McCain and Mother Theresa, among other famous figures, with a pile of pancakes atop their heads.
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But Taitz doesn't feel flattered to be in such company. She maintains that the painting titled Orly Taitz, Pancake Birther
actually portrays her holding a placenta rather than a pancake. "This is really despicable, sh e says, theorizing that one of her many
political enemies put Lacey up to the work. But she says shes more concerned about the effect the paintings are having on he r
children.
For his part, Lacey quips, "I thought all of these were rather sweet paintings of her giving birth so I don't know why her family
would be upset. Perhaps her children now suspect that they are actually pancakes." He confirms that some of the original Taitz
paintings were commissioned (though he won't say by who). But most of them, he says, were his own inspiration. Lacey listed the
paintings on eBay, where one sold for about $200. "Orly remains a popular auction subject, he explain s, "though not quite as
popular as Michael Jackson."
Case 1:10-cv-00151-RCL Document 29 Filed 05/19/10 Page 7 of 11
http://www.faithmouse.com/about_page.htmlhttp://www.nytimes.com/2009/05/31/arts/design/31pain.html?_r=1%20http://www.nytimes.com/2009/05/31/arts/design/31pain.html?_r=1%20http://www.nytimes.com/2009/05/31/arts/design/31pain.html?_r=1%20http://cgi.ebay.com/ws/eBayISAPI.dll?ViewItem&item=260605315530&ssPageName=STRK:MESELX:IThttp://cgi.ebay.com/ws/eBayISAPI.dll?ViewItem&item=260605315530&ssPageName=STRK:MESELX:IThttp://cgi.ebay.com/ws/eBayISAPI.dll?ViewItem&item=260605315530&ssPageName=STRK:MESELX:IThttp://cgi.ebay.com/ws/eBayISAPI.dll?ViewItem&item=260605315530&ssPageName=STRK:MESELX:IThttp://cgi.ebay.com/ws/eBayISAPI.dll?ViewItem&item=260605315530&ssPageName=STRK:MESELX:IThttp://www.nytimes.com/2009/05/31/arts/design/31pain.html?_r=1%20http://www.nytimes.com/2009/05/31/arts/design/31pain.html?_r=1%20http://www.faithmouse.com/about_page.html -
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Taitz v Obama. Reply to Opposition to Motion for reconsideration 8
The famously litigious dentist
has not sued Lacey, saying she fears that doing so would only bring him more publicity. But she has used the paintings in a legal
filing against someone else: her opponent in the GOP primary for secretary of state, Damon Dunn. In March, Taitz sent a criminal
complaint to the Orange County registrar of voters accusing Dunn of voter fraud and demanding an investigation into alleged
intimidation aimed at her and her children. Taitz observes in the complaint that Dunn, a former NFL player, had never voted until
nine months before deciding to run for the states top elections position. She also accuses him of having been registered a D emocrat
in Florida until just a few months before he declared his candidacy in the Republican primarya fact his campaign has conceded.
Taitz believes Dunns campaign is merely one cog in a larger conspiracy to keep her out of office. Her letter to the registrar
includes a reference to the Lacey paintings and emails sent to her kids:
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Taitz v Obama. Reply to Opposition to Motion for reconsideration 9
These e-mails were clearly sent with the intent to cause severe emotional distress to my children and to me and with an attempt
to harass my whole family, and to intimidate me into dropping out of the race for the Attorney General [sic]. While the e-mail was
signed as coming from Damon Dunn, I actually dont believe that Mr. Dunn personally sent these e -mails. I believe these e-mails
were sent by his supporters or by supporters of Mr. Obama, as I currently have an active legal action in the Washington DC Taitz v
Obama 10-cv-151-RCV.
One of the Facebook messages allegedly sent to Taitzs children came from someone pretending to be Dunn. It said:
Will you be visiting your mum in jail after she's sent there for approving of, publishing and encouraging her supporters to issue
death threats against the family members (little children) of federal court judges in order to intimidate and coerce them into ruling in
her favor?
Another, which went to her husband, read:
Is there some reason her family (ie you) haven't put her into some form of treatment centre for her full blown paranoid
delusional state at this point?
In her complaint against Dunn, Taitz also mentions voicemail messages that have been left on her cell phone and offers to
submit them to law enforcement for verification. She says one caller told her that, the best thing you can do for America, is slid
[sic] your wrists, you fucking bitch.
This isnt the first time Taitz has complained of harassment. In December, in one of her many lawsuits challenging Obamas
legitimacy, she insisted that someone had tampered with her car (she included an explanatory drawing).
But for all the vilification that Taitz describes, shes keeping her eyes on the prize. If she prevails in her bid for office, shell
become the gatekeeper for the entire California elections system, meaning that Obama will have to go through her to get his name
on the presidential ballot in 2012. And Taitz is emphatic about her intentions if she wins. She writes, "If I become Secretary of
State, I will demand proper original vital records from Obama." Pancakes or no pancakes.
Stephanie Mencimer is a staff reporter in Mother Jones' Washington bureau. For more of her stories, click here. You can also
follow her on twitter.
/s/ DR ORLY TAITZ ESQBy:__________________________________Dr. Orly Taitz, Esq. (California Bar 223433)
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http://tpmmuckraker.talkingpointsmemo.com/2009/12/new_orly_taitz_filing_in_dismissed_case_i_get_deat.phphttp://www.motherjones.com/authors/stephanie-mencimerhttp://www.twitter.com/smencimerhttp://www.twitter.com/smencimerhttp://www.motherjones.com/authors/stephanie-mencimerhttp://tpmmuckraker.talkingpointsmemo.com/2009/12/new_orly_taitz_filing_in_dismissed_case_i_get_deat.php -
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Taitz v Obama. Reply to Opposition to Motion for reconsideration
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Attorney for the Plaintiffs29839 Santa Margarita Parkway ste 100Rancho Santa Margarita CA 92688Tel.: 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 05.18.10. on
Alan Burch, Assistant United States Attorney for the District of Columbia
555 4th
str.,N.W.
Washington D.C. 20530
/s/Orly Taitz
Case 1:10-cv-00151-RCL Document 29 Filed 05/19/10 Page 10 of 11
mailto:[email protected]:[email protected]:[email protected]:[email protected] -
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Taitz v Obama. Reply to Opposition to Motion for reconsideration
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Dr. Orly Taitz Esq29839 Santa Margarita PKWYRancho Santa Margarita CA 92688
Case 1:10-cv-00151-RCL Document 29 Filed 05/19/10 Page 11 of 11