Tag Archives: October 6

William Cellini trial opening statements, October 6, 2011, Stuart Levine drug use, Where is Tony Rezko?

William Cellini trial opening statements, October 6, 2011, Stuart Levine drug use, Where is Tony Rezko?

From The Chicago Tribune October 6, 2011.

“Defense, U.S. disagree if Cellini was shaking down or helping”

“After listening to a federal prosecutor for nearly 40 minutes lay out how Springfield power broker William Cellini allegedly plotted to extort campaign cash from a Hollywood producer, veteran attorney Dan Webb stood up and put a decidedly different spin on the story.

Cellini was only trying to help an old friend, Webb insisted Wednesday to the jury. And in the end, he did, Webb maintained.

“This story does have a happy ending,” Webb said with emphasis as Cellini’s long-awaited trial started in earnest following the selection of 12 jurors and four alternates.

The longtime statehouse insider is charged with trying to shake down producer Thomas Rosenberg in 2004 for a $1.5 million contribution to the campaign of then-Gov.Rod Blagojevich.

Cellini was no innocent victim of circumstances, contended Assistant U.S. Attorney Gregory Deis in his opening remarks to jurors.

“The defendant didn’t slip, fall and find himself in the middle of an extortion,” he said. “He was in. Eyes wide open.”

Cellini’s federal trial on fraud and attempted extortion charges marks the last of the corruption cases arising from the scandal that toppled Blagojevich and many of his top aides.

On Wednesday, two rows of supporters, many of whom had traveled from Springfield, sat behind Cellini, 76, who has wielded influence behind the scenes in Springfield for four decades.

Webb attacked what he called six flaws in the governnment’s evidence, including the fact that Rosenberg won’t testify that Cellini directly asked him for money. Webb also said that it was Rosenberg who called Cellini for help when his investments at the Teachers’ Retirement System, or TRS, were threatened.

Webb also blasted Stuart Levine, the prosecution’s key witness, as unreliable. He warned jurors that they would be stunned by Levine’s “secret life” of serious drug abuse and “24-hour binge parties.”

But the prosecutor noted that secretly recorded phone calls between Levine and Cellini prove that Cellini was deeply involved in the extortion plot.

Deis portrayed Cellini as a consummate insider with access and influence who could simply pick up a phone and reach decision-makers in state government.

In a low and serious tone, Deis explained how Cellini’s longtime connections in state politics set the stage for the alleged 2004 plot.

After more than a quarter-century of Republican rule in the governor’s office, Democrat Blagojevich’s election posed a dilemma for Cellini, according to the government.

But he secretly made a deal with two of the governor’s key advisers, Antoin “Tony” Rezko and Christopher Kelly, that he would raise campaign money for Blagojevich to keep his influence at TRS, the prosecutor alleged. Levine was a corrupt member of the TRS board.

The government alleges Cellini had a financial reason for the move — an investment company he controlled made millions of dollars in fees from TRS.

At one point Deis noted Cellini’s considerable power by referring to his Downstate nickname — “the pope.”

Cellini, wearing a bright pink tie, sat calmly with his hands folded neatly on the defense table as the two sides told jurors what they believe the evidence will be as the trial unfolds over the next several weeks.

On a screen in the courtroom in the U.S. Dirksen Courthouse, Webb flashed a litany of Levine’s flaws, called him a con man and then listed five illegal drugs abused by Levine.

Webb told the jury of “24-hour binge parties” in hotels, including the infamous “Purple Hotel.”

“You’re gonna be flabbergasted by Stuart Levine’s secret life,” Webb told jurors.

The sordid details had played out at Rezko’s 2008 trial. Levine was a key witness for the government then as well.”

Read more:

http://www.chicagotribune.com/news/local/breaking/chi-jury-selected-for-trial-of-powerbroker-william-cellini-20111005,0,6016446,full.story

Tony Rezko does not have a drug problem, but he does have a Obama problem.

Where is Tony Rezko?

William Cellini trial jury selected, Opening statements Thursday, October 6, 2011, Teachers’ Retirement System extortion plot

William Cellini trial jury selected, Opening statements Thursday, October 6, 2011, Teachers’ Retirement System extortion plot

The jury has been selected in the William Cellini trial and opening statements are expected Thursday, October 6, 2011.

From the Chicago Tribune October 5, 2011.

“A jury has been selected for the trial of Illinois powerbroker William Cellini.

Cellini, 76, is accused of conspiring to shake down the Oscar-winning producer of “Million Dollar Baby” for a campaign contribution to former Gov. Rod Blagojevich.

Prosecutors say Cellini wielded influence over the Teachers’ Retirement System and plotted with top Blagojevich advisers and a corrupt TRS board member to try to extort a $1.5 million campaign contribution from producer Thomas Rosenberg.

The plot was hatched in 2004 after it was discovered that Rosenberg hadn’t contributed to Blagojevich’s campaign despite his investment firm’s extensive business with TRS.

The case is the last trial stemming from a federal investigation of the ousted governor, who was convicted of corruption earlier this year and is awaiting sentencing.”

Read more:

http://www.chicagotribune.com/news/local/breaking/chi-jury-selected-for-trial-of-powerbroker-william-cellini-20111005,0,2439807.story

“The case is the last trial stemming from a federal investigation of the ousted governor”

Perhaps not. Patrick Fitzgerald, Eric Holder  and Barack Obama should be next.

Glenn Beck interview by New York Times, Weaknesses and failures, Glenn call me, Citizen Wells open thread, October 6, 2010

Glenn Beck interview by New York Times, Weaknesses and failures, Glenn call me

“Why has Obama, for over 2 years, employed numerous private and government attorneys to avoid presenting a legitimate birth certificate and college records?”…Citizen Wells and millions of concerned Americans

Glenn Beck is a likeable guy. I am not here to bash Glenn Beck, but to wake him up out of a stupor of ignorance or arrogance.

From the New York Times September 29, 2010.

“Glenn Beck was sprawled out on his office couch a couple of weeks ago, taking — as self-helpers like to say ­— an inventory. “I think what the country is going through right now is, in a way, what I went through with my alcoholism,” he told me. “You can either live or die. You have a choice.” Beck, who is 46, was in the Midtown Manhattan offices of his production company, Mercury Radio Arts, which is named for Mercury Theater, the company created by Orson Welles. He had just finished his three-hour syndicated radio show and was a few hours away from his television show. It was a Wednesday afternoon in the middle of September, and Beck had just returned from a week’s vacation in the Grand Tetons followed by a quick hop to Anchorage, where he and Sarah Palin appeared at an event on Sept. 11.”

“WHILE THE RIGHT has traditionally responded to its aggrieved sense of alienation with anger, Beck is not particularly angry. He seems sorrowful; his prevailing message is umbrage born of self-taught wisdom. He is more agonized than mad. He is post-angry.

Beck rarely speaks with the squinty-eyed certainty or smugness of Rush Limbaugh or his fellow Fox News hosts Bill O’Reilly and Sean Hannity. He often changes his mind or nakedly contradicts himself. “When you listen and watch me, it’s where I am in my thinking in the moment,” Beck told me. “I’m trying to figure it out as I go.” He will sometimes stop midsentence and recognize that something he is about to say could be misunderstood and could cause him trouble. Then, more often than not, he will say it anyway.

In the middle of his analogy to me about his own personal crash and the country’s need to heal itself, Beck looked at his publicist with a flash of alarm about how I might construe what he was saying. “He is going to write a story that I believe the whole country is alcoholics,” he said. And then he went on to essentially compare his “Restoring Honor” pageant at the Lincoln Memorial to a large-scale A.A. meeting. “When I bottomed out, I couldn’t put it back together myself,” Beck told me. “I could do all the hard work. I could do the 12 steps. But I needed like-minded people around me.”

He needed support, just as responsible Americans need it now to reinforce the principles and values that the founders instilled and that, he says, have since decayed. “You need people to be able to reach out and connect and say, ‘Let me help hold you when you’re stumbling, and you hold me when I’m stumbling, because what we’re going through now is a storm of confusion.’ ” Fans approach Beck and give him hugs. Do people feel they can hug Limbaugh?”

“Beck is constantly admitting his weaknesses and failures, which he wields as both a crutch and a shield. “Maybe Glenn’s transparency is what keeps him out of trouble,” says Robert Beath, Beck’s drama teacher at Sehome High School in Bellingham, Wash. Beath, who was fond of Beck as a teenager, said Beck appears to now think that his revelations grant him license. “When he says, ‘I am not perfect,’ he seems to escape accountability for his various points of view. Yet he expects others to be accountable for their point of view without seeming to allow them the ‘I am not perfect’ exception.””

Read  more:

http://www.nytimes.com/2010/10/03/magazine/03beck-t.html?_r=2&pagewanted=all

Glenn Beck is not perfect, nor are any of us. It is the human condition. However, when you make a mistake, admit it, humble yourself. Glenn, deciding not to cover the Obama eligibility issues is bad enough. It is your decision. However, to criticize and belittle those questioning Obama’s eligibility, including many in the military, military officers such as LTC Terry Lakin and then not cover the Lakin court martial, that is unexcusable and un American.

Glenn Beck, admit your mistakes.

Glenn Beck, call me.

US dollar, Dropped in oil trading?, October 6, 2009, Arab states, China, Russia, France, The demise of the dollar, New world order

From the United Kingdom Independent, October 6, 2009:

“The demise of the dollar”

“In the most profound financial change in recent Middle East history, Gulf Arabs are planning – along with China, Russia, Japan and France – to end dollar dealings for oil, moving instead to a basket of currencies including the Japanese yen and Chinese yuan, the euro, gold and a new, unified currency planned for nations in the Gulf Co-operation Council, including Saudi Arabia, Abu Dhabi, Kuwait and Qatar.

 Secret meetings have already been held by finance ministers and central bank governors in Russia, China, Japan and Brazil to work on the scheme, which will mean that oil will no longer be priced in dollars.

The plans, confirmed to The Independent by both Gulf Arab and Chinese banking sources in Hong Kong, may help to explain the sudden rise in gold prices, but it also augurs an extraordinary transition from dollar markets within nine years.”

“The decline of American economic power linked to the current global recession was implicitly acknowledged by the World Bank president Robert Zoellick. “One of the legacies of this crisis may be a recognition of changed economic power relations,” he said in Istanbul ahead of meetings this week of the IMF and World Bank. But it is China’s extraordinary new financial power – along with past anger among oil-producing and oil-consuming nations at America’s power to interfere in the international financial system – which has prompted the latest discussions involving the Gulf states.

Brazil has shown interest in collaborating in non-dollar oil payments, along with India. Indeed, China appears to be the most enthusiastic of all the financial powers involved, not least because of its enormous trade with the Middle East.

China imports 60 per cent of its oil, much of it from the Middle East and Russia. The Chinese have oil production concessions in Iraq – blocked by the US until this year – and since 2008 have held an $8bn agreement with Iran to develop refining capacity and gas resources. China has oil deals in Sudan (where it has substituted for US interests) and has been negotiating for oil concessions with Libya, where all such contracts are joint ventures.”

Read more:

http://www.independent.co.uk/news/business/news/the-demise-of-the-dollar-1798175.html

Berg lawsuit, Berg is outraged, Obama hides behind legal issues, Obama and DNC attorney files motion, Obama Indonesian, Illegal alien, Philip J Berg statement, October 6, 2008

Philip J Berg has issued a statement in response to the motion filed on Monday, October 6, 2008 by Obama and the DNC. Here is Mr. Berg’s statement:

Berg Outraged: Obama & DNC file motion to delay discovery until after defendants motion to dismiss is decided

Berg is “Outraged” that Obama & DNC Hide Again Behind Legal Issues as their attorney files a Motion for Protective Order to “not” Answer Admissions & Production of Documents while Betraying Public in not Producing Documents proving Obama is “qualified” to be a candidate for President.

It is believed Obama is an “illegal alien”

For Immediate Release: – 10/06/08

(Contact info and pdf of press release below) 

Country is Headed to a Constitutional Crisis

(Lafayette Hill, Pennsylvania – 10/06/08) – Philip J. Berg, Esquire, the Attorney who filed suit against Barack H. Obama challenging Senator Obama’s lack of “qualifications” to serve as President of the United States, announced today that Obama and Democratic National Committee [DNC] filed a Joint Motion for Protective Order to Stay Discovery Pending a Decision on the Motion to Dismiss (which was) filed on 09/24/08.

While legal, Berg stated he is “outraged as this is another attempt to hide the truth from the public; it is obvious that documents do not exist to prove that Obama is qualified to be President.” The case is Berg v. Obama, No. 08-cv-04083.

Their joint motion indicates a concerted effort to avoid the truth by attempting to delay the judicial process, although legal, by not resolving the issue presented: that is, whether Barack Obama meets the qualifications to be President.

It is obvious that Obama was born in Kenya and does not meet the “qualifications” to be President of the United States pursuant to our United States Constitution. Obama cannot produce a certified copy of his “Vault” [original long version] Birth Certificate from Hawaii because it does not exist.”

Help Philip J Berg get the truth from Obama:

http://www.obamacrimes.com

Voice your outrage here:

http://obamaimpeachment.org

Larry Sinclair, Nashville TN, October 6, 2008, Sinclair blog radio show, Town Hall Meeting, Obama, McCain, Obama drug sex encounter November 1999

Larry Sinclair is in Nashville TN for the McCain and Obama Town Hall Meeting and to share his story of a drug sex encounter with Obama in November 1999. Sinclair will also share his telephone encounter with Donald Young and inform the public about the Philip J Berg lawsuit.

Larry Sinclair will host his blog talk radio show from Nashville tonight at 6:00 PM Central time. Here is the link to the radio show:

http://www.blogtalkradio.com/Obamas-2Night-Stand

Here is a recent post from Larry Sinclair’s website:

“Monday, October 6, 2008

GOOD AFTERNOON FROM VANDERBILT & BELMONT UNIVERSITIES

Let me start by extending a Thank You to the Belmont University Office of Campus Security for your kind assistance today.

I have spent the last couple of hours dropping off DVD’s of the NPC press conference along with contact cards to the Nashville colleges and Universities as well as some Nashville media outlets.

I have also spent time driving through these areas and am pleased with the amount of interest in what is posted all over the car. Even in front of Al Gore’s offices in the Loews Plaza!

The below pictures are from the press parking lot at Belmont University. Fox News looks to shuttle their staff in a single van while NBC has these two SUV’s plus three more in the parking lot.
Tuesday October 7, 2008 we will yet again bring a story to the American voter that has no idea who the real Barack Obama is. I was asked this morning by Vanderbilt, “Why is this just now coming out a month before the election?” I advised them because the national media has refused to report the story to the American people. I provided them copies of the NPC PC DVD!”
Read more from Larry Sinclair here:

Philip J Berg, October 6, 2008, Motion for Leave to File an Amended Complaint, Obama Indonesian, DNC, FEC, the fraudulent tactics of Obama, citizenship status

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 


Here is the text of the Philip J Berg Motion for Leave to File an Amended Complaint. The PDF version can be found here:
http://www.americasright.com/

UNITED STATES DISTRICT COURT

FOR THE EASTERN DISTRICT OF PENNSYLVANIA

PHILIP J. BERG, ESQUIRE ::

Plaintiff,

 

:

vs.

 

: CIVIL ACTION NO. 08-CV-4083:

BARACK HUSSEIN OBAMA, a/k/a :

BARRY SOETORO, a/k/a :

BARRY OBAMA, a/k/a : JURY TRIAL DEMANDED

BARACK DUNHAM, a/k/a :

BARRY DUNHAM; THE :

DEMOCRATIC NATIONAL :

COMMITTEE; THE FEDERAL :

ELECTION COMMISSION; THE :

SECRETARY OF THE :

COMMONWEALTH, :

PENNSYLVANIA DEPARTMENT OF :

STATE; PEDRO A, CORTÉS, :

Secretary of the Commonwealth in his :

Official Capacity; DIANE FEINSTEIN, :

Chairman of the U.S. Senate, :

Commission on Rules and :

Administration in her Official capacity; :

U.S. SENATE, COMMISSION ON :

RULES AND ADMINISTRATION; and :

DOES 1-50 INCLUSIVE ::

 

Defendants. :

FIRST AMENDED COMPLAINT

FOR DECLARTORY AND INJUNCTIVE RELIEF

PRELIMINARY STATEMENT

1. Article II, Section I of the United States Constitution, states in particular part, “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.”

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2. “The general doctrine of our Constitution is, that the executive power of the nation is

vested in the President; subject only to the exceptions and qualifications, which are

expressed in the instrument.” 7 Works of Alexander Hamilton, J. C. Hamilton ed.

(New York: 1851), 76, 80–81 (emphasis in original), U.S. Constitution, Article II

(Hamilton and Madison.)

3. Plaintiff is a life long Democrat who had always been proud of his Party. Plaintiff is

a licensed attorney in good standing and has taken an oath to uphold the United States

Constitution. Plaintiff has donated money and billable hours to Democratic

Presidential candidates as well as to the Democratic National Committee. Plaintiff

has relied on the Democratic National Committee’s [hereinafter “DNC”] promises to

uphold our Constitution, which includes properly vetting our Presidential Nominee

and ensuring our Party’s Nominee is eligible to serve as President of the United

States pursuant to Article II, Section 1 of our United States Constitution.

4. Plaintiff has trusted the Federal Election Commission [hereinafter “FEC”] that they

would ensure our Presidential and Congressional candidates are eligible for the

positions which they were seeking and running a fair and legitimate campaign

process. Plaintiff has relied on the FEC, DNC and all our Elected Office Holders to

uphold our Constitution and to ensure an illegal alien and/or a naturalized citizen

would not be able to secure the position of President of the United States.

5. The Democratic National Party is supposed to represent Democratic Americans in

seeking Honest Leadership, Open Government, Real Security, Energy Independence,

Economic Prosperity, Educational Excellence, a Healthcare System that works for

Everyone and Retirement Security. The Democratic Party is supposed to represent

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and protect the interests of working Americans and guaranteeing personal liberties for

all. This includes securing a Democratic Nominee on the Presidential Election ballot

who represents the Democratic vision and who is qualified and eligible to run for

Office of the President pursuant to the qualifications of the United States

Constitution.

6. The actions of Barack Hussein Obama [hereinafter “Obama”], a U.S. Senator, in

running for President of the United States, knowing he is not eligible, have been

taken entirely without authorization under the United States Constitution, completely

ignoring the qualification and procedures created by the United States Constitution he

is purporting to enforce.

7. Should Obama be elected into the Office of the Presidency based on a fraudulent

scheme by way of malfeasance and negligence on his part failing to reveal material

information and evidence proving his ineligibility as a result of his non-citizenship or

non “natural born” status his election into Office of the President will be declared

void. Plaintiff as well as other Democratic Americans will suffer Irreparable Harm as

they will have been deprived of their right to cast their vote for an eligible

Democratic Presidential Nominee who can secure the Office of the President of the

United States.

8. Moreover, Obama and his campaign brought in donations in excess of $450 Million

Dollars by fraudulent means.

9. The DNC, FEC, Pennsylvania Secretary of the Commonwealth, Department of State

and the U.S. Senate, Commission on Rules and Administration have allowed

Obama’s fraudulent scheme and failed to take any action to protect Plaintiff and/or

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other American citizens. The DNC, FEC, Pennsylvania Secretary of the

Commonwealth, Department of State and U.S. Senate on Rules and Administration

refused to investigate Obama’s eligibility to hold the Office of the Presidency and

refused to comply with the Freedom of Information Act [hereinafter “FOIA”] and

turn over documents, which were demanded to prove Obama’s eligibility to hold the

Office of the Presidency to Plaintiff and the American Citizens.

10. Furthermore, the Secretary of the Commonwealth, Pennsylvania Department of State,

should have never allowed Obama on the ballot without the proper verification that

Obama was eligible to serve as the President of the United States. The Pennsylvania

Secretary of the Commonwealth, Department of State, has refused to supply

documents pertinent to satisfy Plaintiff and other voter’s doubts regarding Obama’s

eligibility.

11. There are unanswered questions as to where Obama was actually born, in the United

States or abroad, registering his birth in Hawaii. There are further unanswered

questions regarding Obama’s United States Citizenship, if he ever held such, being

expatriated and his failure to regain his citizenship by taking the oath of allegiance

once he turned eighteen (18) years of age. There are additional unanswered questions

regarding Obama’s “natural” citizenship status in Indonesia and if in fact Obama ever

took the steps necessary and filed the appropriate immigration paperwork to become

a “naturalized” citizen of the United States. Furthermore, there are unanswered

questions into Obama’s multi citizenships with foreign countries, which he still

maintains. To date, Obama has refused to prove he is qualified under the U.S.

Constitution and his eligibility to run as President of the United States.

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JURISDICTION AND VENUE

12. This case arises under the Constitution and laws of the United States and presents a

federal question within this Court’s jurisdiction under Article III of the Constitution

and 28 U.S.C. § 1331.

13. This Court has jurisdiction pursuant to 28 U.S.C. § 1343. Civil rights and elective

franchise.

14. This court has further jurisdiction pursuant to 5 U.S.C. § 702

15. This Court has authority to grant declaratory relief pursuant to the Declaratory

Judgment Act, 28 U.S. C. § 2201.

16. Venue is proper in this Court under 28 U.S.C. § 1391(b).

PARTIES

17. Plaintiff, Philip J. Berg, Esquire [hereinafter “Plaintiff”], is an adult individual with a

business address of 555 Andorra Glen Court, Suite 12, Lafayette Hill, PA 19444-

2531.

18. Defendant, Barack Hussein Obama, a/k/a Barry Soetoro, a/k/a Barry Obama, a/k/a

Barack Dunham, a/k/a Barry Dunham [hereinafter “Obama”] is an adult individual

with an office address of 713 Hatch, Senate Office Building, Washington D.C.

19. Defendant, The Democratic National Committee [hereinafter “DNC”] is a

corporation with a principal address of 430 S. Capitol Street SE, Washington, DC

20003.

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20. Defendant, The Federal Election Commission [hereinafter “FEC”] was created in

1975 by Congress to administer and enforce the Federal Election Campaign Act

[hereinafter “FECA”]. The FEC is a Governmental Agency with a principal address

of 999 E Street, NW, Washington, DC 20463.

21. Defendant, Secretary of the Commonwealth, Pennsylvania Department of State,

Bureau of Commissions, Elections and Legislation, is a State Governmental Agency

over the Pennsylvania Commonwealth’s electoral process as well as Campaign

Finance, Commissions and Legislation with a principal address of 210 N. Office

Building, Harrisburg, PA 17120.

22. Defendant, Pedro A. Cortés, [hereinafter “Cortés”] sued here in his official capacity,

serves as Secretary of the Commonwealth, for the Pennsylvania Department of State,

located at 210 N. Office Building, Harrisburg, PA 17120, and has primary authority

over the Pennsylvania Commonwealth’s electoral process as well as Campaign

Finance, Commissions and Legislation.

23. Defendant, The U.S. Senate, Commission on Rules and Administration is a

Governmental Agency responsible for investigations into the qualifications of the

President and Vice President candidates Federal elections. The U.S. Senate,

Commission on Rules and Regulations is a Governmental Agency with a principal

address of 305 Russell Building, United States Senate, Washington D.C. 20510.

24. Defendant, Diane Feinstein, [hereinafter “Feinstein”] sued here in her official

capacity as Chairman of the U.S. Senate, Commission on Rules and Administration

located at 305 Russell Building, United States Senate, Washington D.C. 20510 and

has primary authority overseeing the ethics, campaign and election reform.

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STANDING

25. Plaintiff has standing to bring suit against Defendants pursuant to the following:

(1) Plaintiff has Standing pursuant to 5 United States Code. §702;

(2) Plaintiff has Standing pursuant to

 

FEC v. Akins, 524 U.S. 11 (1998);(3) Plaintiff has Standing Pursuant to 8 U.S.C. §1481(b);

(4) Plaintiff has Standing under 5 U.S.C. §552, et seq. (FOIA);

(5) Plaintiff has Standing pursuant to 28 U.S.C. §1343, Civil Rights

and Elective Franchise;

(6) Plaintiff has Standing under the Promissory Estoppel Doctrine; and

(7) Plaintiff has Standing pursuant to Federal Question Jurisdiction.

FACTUAL ALLEGATIONS

26. Since the beginning of the U.S. Constitution, in order to run for Office of the

President, you must be a “natural born citizen” U.S. Constitution, Article II, Section

1.

27. The DNC has pledged and promised Plaintiff and all Democratic individuals they

believe that our Constitution, our courts, our institutions and our traditions are proper

and work.

28. The DNC pledged and promised Plaintiff and all Democratic individuals they will

ensure our Constitution is not a nuisance and have assured Plaintiff and democratic

individuals the United States Constitution is the foundation of our democracy. It

makes freedom and self-governance possible and helps to protect our security. The

Democratic Party has pledged and promised Plaintiff and other Democratic

individuals they will maintain and restore our Constitution to its proper place in our

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government and return our Nation to the best traditions, including their commitment

to government by law.

29. Based on the DNC’s promises and assurances, Plaintiff and other democratic

individuals have donated money in good faith to the DNC and other Democratic

Presidential Nominees. Money donated to the DNC is used to

 

plan the Party’squadrennial presidential nominating convention; promote the election of eligible

Party candidates, pursuant to the United States Constitution, Article II, Section I, with

both technical and financial support; and works with national, state and local party

organizations, elected officials, candidates and constituencies to respond to the needs

and views of the Democratic electorate and the nation.

30.

 

The Democratic National Party is supposed to represent Democratic Americans inseeking Honest Leadership, Open Government, Real Security, Energy Independence,

Economic Prosperity, Educational Excellence, a Healthcare System that works for

Everyone and Retirement Security. The Democratic Party is supposed to represent

and protect the interests of working Americans and guaranteeing personal liberties for

all. This includes securing a Democratic Nominee on the Presidential Election ballot

who represents the Democratic vision and who is qualified and eligible to run for

Office of the President pursuant to the qualifications of the United States

Constitution.

31. The FEC is the independent regulatory agency charged with administering and

enforcing the federal campaign finance law. The FEC has jurisdiction over the

financing of campaigns for the U.S. House, the U.S. Senate, the Presidency and the

Vice Presidency. The FEC is also responsible for the Administration, enforcement,

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and formulation of policy; exclusive jurisdiction of civil enforcement; Congressional

authorities or functions with respect to elections for Federal office.

32. The PA Department of State is under the leadership of the Secretary of the

Commonwealth, Pedro A. Cortés, and the mission of the Department of State is to

promote the integrity of the electoral process.

33. Secretary of the Commonwealth, Pennsylvania Department of State, Bureau

of Commissions, Elections and Legislation oversees the Commonwealth’s electoral

process as well as Campaign Finance, Voter Registration, Office of Notary Public,

Commissions and Legislation. The U.S. Senate, Commission on Rules and

Administration also carries the responsibility of investigating any corrupt practices of

our politicians. They are responsible for verifying the credentials and qualifications

of Members of the Senate, contested elections and acceptance of incompatible

offices. Moreover, in addition to the verification of a candidates qualifications,

eligibility and credentials, they are responsible for Federal elections generally,

including the election of the President, Vice President and Members of the Congress.

34. The U.S. Senate, Commission on Rules and Regulations has failed to perform their

duties in verifying and investigating Obama’s citizenship status and his eligibility.

35. In vetting the Presidential candidate, among other things, the PA Department of State,

Bureau of Commissions, Elections and Legislation, the DNC and FEC are required to

ensure the eligibility requirements pursuant to our Constitution are met and the

Presidential nominee, if elected, is qualified and eligible to serve pursuant to our

United States Constitution.

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36. Obama is a representative of the Democratic People. However, Obama must meet

the Qualifications specified for the United States Office of the President, which he

must be a “natural born” citizen. Additionally, Obama must be at least a

“naturalized” citizen to hold his Office of U.S. Senator for Illinois. Unfortunately,

Obama is not a “natural born” citizen, nor is he a “naturalized” citizen. Just to name

one of the problems, Obama lost his U.S. citizenship when his mother married an

Indonesian citizen, Lolo Soetoro who legally “acknowledged” Obama as his son in

Indonesia and/or “adopted” Obama, which caused Obama to become a “natural”

Indonesian citizen. Stanley Ann Dunham Soetoro relocated herself and Obama to

Indonesia wherein Obama’s mother naturalized in Indonesia. This is proven by

Obama’s school record with the student’s name as “Barry Soetoro”, Father’s name:

Lolo Soetoro, M.A., and Citizenship: Indonesia.

37. There appears to be no question that Defendant Obama’s mother, Stanley Ann

Dunham, was a U.S. citizen. It is also undisputed, however, that his father, Barack

Obama, Sr., was a citizen of Kenya. Obama’s parents, according to divorce records,

were married on or about February 2, 1961.

38. Defendant Obama claims he was born in Honolulu, Hawaii on August 4, 1961 and it

is uncertain in which hospital he claims to have been born. Obama’s grandmother on

his father’s side, his half-brother and half-sister all claim Obama was born not in

Hawaii but in Kenya. Reports reflect that Obama’s mother traveled to Kenya during

her pregnancy; however, she was prevented from boarding a flight from Kenya to

Hawaii at her late stage of pregnancy (which, apparently, was a normal restriction, to

avoid births during a flight). By these reports, Stanley Ann Dunham Obama gave

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birth to Obama in Kenya, after which she flew home and registered Obama’s birth.

There are records of a “registry of birth” for Obama, on or about August 8, 1961 in

the public records office in Hawaii.

39. Upon investigation into the alleged birth of Obama in Honolulu, Hawaii, Obama’s

birth is reported as occurring at two (2) separate hospitals, Kapiolani Hospital and

Queens Hospital. The Rainbow Edition News Letter, November 2004 Edition,

published by the Education Laboratory School did a several page article of an

interview with Obama and his half-sister, Maya. The Rainbow Edition News Letter

reports Obama was born August 4, 1961 at Queens Medical Center in Honolulu,

Hawaii. More interesting in February 2008, Obama’s half-sister, Maya, was again

interviewed in the Star Bulletin, and this time, Maya states Obama was born August

4, 1961 in Kapi’olani Medical Center for Women & Children.

40. Plaintiff is informed, believes and thereon alleges a research team went to Mombassa,

Kenya, and located a Certificate Registering the birth of Barack Obama, Jr. to his

father, a Kenyan citizen and his mother, a U.S. citizen.

41. Even if Obama was, in fact, born in Hawaii, he lost his U.S. citizenship when his

mother re-married and moved to Indonesia with her Indonesian husband. In or about

1965, when Obama was approximately four (4) years old, his mother, Stanley Ann

Dunham, married Lolo Soetoro, a citizen of Indonesia, whom she had met at the

Hawaii University, and moved to Indonesia with Obama. Obama lost his U.S.

citizenship, when his mother married Lolo Soetoro, and took up citizenship of and

residency in Indonesia. Loss of citizenship, in these circumstances, under U.S. law

(as in effect in 1965) required that foreign citizenship be achieved through

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“application.” Such type of naturalization occurred, for example, when a person

acquired a foreign nationality by marriage to a national of that country. Nationality

Act of 1940, Section 317(b). A minor child follows the naturalization and citizenship

status of their custodial parent. A further issue is presented that Obama’s Indonesian

stepfather, Lolo Soetoro, either signed an acknowledgement acknowledging Obama

as his son or Lolo Soetoro adopted Obama, giving Obama natural Indonesia

citizenship which explains the name Barry Soetoro and his citizenship listed as

Indonesian.

42. Obama admits in his book, ”

 

Dreams from my father” Obama’s memoir(autobiography), that after his mother and Lolo Soetoro were married, Lolo Soetoro

left Hawaii rather suddenly and Obama and his mother spent months in preparation

for their move to Indonesia. Obama admits when he arrived in Indonesia he had

already been enrolled in an Indonesia school and his relatives were waiting to meet

him and his mother. Lolo Soetoro, an Indonesian State citizen, could not have

enrolled Obama in school unless Lolo Soetoro signed an acknowledgement

acknowledging Obama as his son, which had to be filed with the Government. Under

Indonesian law, when a male acknowledges a child as his son, it deems the son, in

this case Obama, as an Indonesian State citizen. Constitution of Republic of

Indonesia, Law No. 62 of 1958 Law No. 12 of 2006 dated 1 Aug. 2006 concerning

Citizenship of Republic of Indonesia, Law No. 9 of 1992 dated 31 Mar. 1992

concerning Immigration Affairs and Indonesian Civil Code (Kitab Undang-undang

Hukum Perdata) (KUHPer) (Burgerlijk Wetboek voor Indonesie) states in pertinent

part,

 

State citizens of Indonesia include: (viii) children who are born outside of legalZ:\Forms\Obama, First Amended Complaint 100608

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marriage from foreign State citizen mother who are acknowledged by father who is

Indonesian State citizen as his children and that acknowledgment is made prior to

children reaching 18 years of age or prior to marriage;

 

Republic of IndonesiaConstitution 1945,

 

As amended by the First Amendment of 1999, the SecondAmendment of 2000, the Third Amendment of 2001 and the Fourth Amendment of

2002,

 

Chapter X, Citizens and Residents, Article 26 states, “(1) Citizens shall consistof indigenous Indonesian peoples and persons of foreign origin who have been

legalized [sic] as citizens in accordance with law. (2) Residents shall consist of

Indonesian citizens and foreign nationals living in Indonesia

 

.”43. Furthermore, under the Indonesian adoption law, once adopted by an Indonesian

citizen, the adoption severs the child’s relationship to the birth parents,

 

and theadopted child is given the same status as a natural child, Indonesian Constitution,

Article 2. Thus, where Obama was actually born and what his mother’s citizenship

status at the time of this birth is irrelevant.

44. The laws in Indonesia at the time of Obama’s arrival did not allow dual citizenship.

If an Indonesian citizen married a foreigner, as in this case, Obama’s mother was

required to renounce her U.S. citizenship and was sponsored by her Indonesian

spouse. During this time, Indonesia was a Police State. The public schools did not

allow foreign students, only citizens were allowed to attend as Indonesia was under

strict rule and decreed a number of restrictions; therefore, in order for Obama to have

attended school in Jakarta, which he did, he had to be a citizen of Indonesia, as the

citizenship status of enrolled students was verified with Government records.

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45. Obama was enrolled by his parents in a public school, Fransiskus Assisi School, a

public school, in Jakarta, Indonesia. Plaintiff has received copies of the school

registration in which it clearly states Obama’s name as “Barry Soetoro,” and lists his

citizenship as Indonesian. Obama’s father is listed as Lolo Soetoro, Obama’s date of

birth and place of birth are listed as August 4, 1961 in Hawaii, and Obama’s Religion

is listed as Islam. This document was verified by

 

Inside Edition, whose reporter,Matt Meagher, took the actual footage of the school record. At the time Obama was

registered the public schools obtained and verified the citizenship status and name of

the student through the Indonesian Government. All Indonesian students were

required to carry government identity cards, or

 

Karty Tanda Pendudaks, as well asfamily card identification called a

 

Kartu Keluarga. The Kartu Keluarga is a familycard which bears the legal names and citizenship status of all family members.

46. Since Obama’s birth was legally acknowledged by Lolo Soetoro, an Indonesian

citizen, and/or Obama was adopted by Lolo Soetoro, which the evidence supports,

Obama became an Indonesian citizen

 

and bears the status as an Indonesia naturalchild (natural-born). For this reason, Obama would have been required to file

applications with the U. S. State Department and follow the legal procedures to

become a naturalized citizen in the United States, when he returned from Indonesia.

If Obama and/or his family failed to follow these procedures, then Obama is an

illegal alien.

47. Regardless of whether Obama was officially adopted, (which required a Court

process), by his Indonesian stepfather, Lolo Soetoro, or his birth was acknowledged

(which only required the signing of a governmental birth acknowledgement form),

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by Lolo Soetoro, one of which had to occur in order for Obama to have the name

Barry Soetoro and his citizenship status listed as “Indonesian”, in either and/or both

cases Obama’s name was required to be changed to the Indonesian father’s name, and

Obama became a natural citizen of Indonesia. This is proven by the school records

in Jakarta, Indonesia showing Obama’s name as Barry Soetoro and his citizenship as

Indonesian.

 

Again, the registration of a child in the public schools in Jakarta,Indonesia was verified with the Government Records on file with the Governmental

Agencies.

48.

 

The Indonesian citizenship law was designed to prevent apatride (stateless) orbipatride (dual citizenship). Indonesian regulations recognize neither apatride nor

bipatride citizenship.

49.

 

In addition, since Indonesia did not allow dual citizenship neither did the UnitedStates, Hague Convention of 1930.

50. In or about 1971, Obama’s mother sent Obama back to Hawaii. Obama was ten (10)

years of age upon his return to Hawaii.

51. As a result of Obama’s Indonesia “natural” citizenship status, there is absolutely

 

noway Obama could have ever regained U.S. “natural born” status, if he in fact ever

held such. Obama could have

 

only become naturalized if the proper paperwork wasfiled with the U.S. State Department, in which case, Obama would have received a

Certification of Citizenship.

52. Plaintiff is informed, believes and thereon alleges Obama was never naturalized in

the United States after his return. Obama was ten (10) years old when he returned to

Hawaii to live with his grandparents. Obama’s mother did not return with him, and

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therefore, unable to apply for citizenship of Obama in the United States. If

citizenship of Obama had ever been applied for, Obama would have a Certification of

Citizenship.

53. Furthermore, Obama traveled to Indonesia, Pakistan and Southern India in 1981. The

relations between Pakistan and India were extremely tense and Pakistan was in

turmoil and under martial law. The country was filled with Afghan refugees; and

Pakistan’s Islamist-leaning Interservices Intelligence Agency (ISI) had begun to

provide arms to the Afghan mujahideen and to assist the process of recruiting

radicalized Muslim men–jihadists–from around the world to fight against the Soviet

Union. Pakistan was so dangerous that it was on the State Department’s travel ban

list for US Citizens. Non-Muslim visitors were not welcome unless sponsored by

their embassy for official business. A Muslim citizen of Indonesia traveling on an

Indonesian passport would have success entering Indonesia, Pakistan and India.

Therefore, it is believed Obama traveled on his Indonesian passport entering the

Countries. Indonesian passports require renewal every five (5) years. At the time of

Obama’s travels to Indonesia, Pakistan and India, Obama was twenty (20) years old.

If Obama would have been a U.S. citizen, which he was not, 8 USC §1481(a)(2)

provides loss of nationality by native born citizens upon “taking an oath or making an

affirmation or other formal declaration of allegiance to a foreign state…after having

attained the age of eighteen years”, in violation of 8 U.S.C. §1401(a)(1). Since Lolo

Soetoro legally acknowledged Obama as his son and/or adopted Obama, Obama

was a “natural” citizen of Indonesia, as proven by Obama’s school record.

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54. Plaintiff is informed, believes and thereon alleges Obama stated his citizenship as a

“Kenya Citizen” when he applied for and was accepted at Columbia University.

Obama has refused to release any records from Occidental College, Columbia

University, Harvard Law School and any of his medical records.

55. Plaintiffs as well as many other democratic American citizens have requested proof

of Obama’s citizenship status, however to no avail. Obama has promised to be an

open and honest candidate, however, refuses to remove any doubts from Plaintiff’s

and all the other democratic minds and prove his eligibility to serve as President of

the United States.

56. Plaintiff’s civil rights under the due process rights and equal protection of the laws

secured by the U.S. Constitution, Fourteenth (14 ) Amendment

 

th have been violated byObama’s illegal campaign and will continue to be violated if Obama is allowed to

continue his campaign and if elected, assume the position of President of the United

States. The DNC and FEC have allowed Obama to continue his campaigning,

knowing these issues have arisen and have failed to take and/or instigate the proper

investigation into said matters to protect Plaintiff and other registered voters.

Therefore, the only option Plaintiff had to secure and protect his civil rights was to

bring action before this Honorable Court. Moreover, our laws which protect Plaintiff,

a legal registered voter, and other registered voters from fraudulent campaign

schemes have been violated by the Defendants, 2 U.S.C. §437c, 2 U.S.C §437(g).

Plaintiff has standing to bring suit pursuant to 5 U.S. C §702, as well as 8 U.S. C

§1481(b).

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57. Plaintiff’s rights guaranteed under the Liberty clause of the Fourteenth (14

 

th)Amendment of the United States Constitution have already been violated. It has been

announced in the main stream media that Obama’s “briefing” has already begun into

our National Secrets, our Nations Top Secrets, which Obama is not privy too and in

violation of our National Security, as Obama is not a legal citizen of the United

States. This has placed Plaintiff and other citizens of the United States in grave

danger. Plaintiff’s Liberty as guaranteed will further be violated if Obama is allowed

to be voted into and assume the position of President of the United States; Plaintiff

will be further damaged and is in serious jeopardy.

58. Plaintiff filed the within action on or about August 21, 2008 against Defendants

seeking Declaratory and Injunctive Relief, declaring Obama an illegal alien and/or

only a “naturalized” citizen ineligible to serve as President of the United States and

enjoining the PA Department of State, Bureau of Commissions, Elections and

Legislation, the DNC and FEC from placing Obama’s name on the ballot and

prohibiting Obama from further campaigning to be elected as President of the United

States, a position he is ineligible to hold.

59. Plaintiff faxed a copy of the original complaint to Obama, the DNC and FEC on

August 22, 2008 prior to the hearing on the TRO before this Honorable Court.

Defendants were further served by personal service on September 4, 2008. Neither

the DNC nor Obama have supplied any type of proof of Obama’s citizenship status

and/or eligibility to serve as President of the United States.

60. Plaintiff has asked for a simple resolution. Plaintiff has asked that Obama supply a

genuine certified copy of his original long version “vault” Birth Certificate, A

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Certification of Citizenship and a certified copy of his Oath of Allegiance. If in fact

Obama can prove his “natural born” citizenship status, which he

 

cannot, then he hasnot been prejudiced in anyway, but instead Plaintiff has been protected and his civil

rights secured. However, if Obama is unable to supply said documentation, then he

needs to withdraw his candidacy, again which will eliminate Plaintiff’s deprivations

and instill Plaintiff’s constitutionally protected safeguards and rights.

61. There is absolutely

 

no other way for Plaintiff to ensure his constitutionally protectedrights. The only option Plaintiff had was to bring this action. This is the first time in

American History a “naturalized” citizen and/or illegal alien have been allowed to

campaign for the Office of President of the United States. There are not any other

ways to establish or determine the legal status of our Presidential Candidates, whether

Republican and/or Democratic. The FEC and DNC have refused to verify and

furnish Plaintiff with Obama’s eligibility or lack thereof. Plaintiff has standing to

challenge any person(s) citizenship and/or nationality status pursuant to statute, 8

U.S. C. §1481(b).

62. The Federal Bureau of Investigation (FBI) does not perform background checks

and/or verify their eligibility on our Candidates to hold Office. According to the FBI,

once a candidate is voted into Office of Congress, they are members of Congress and

therefore they are given a Secret Clearance, again, without any type of background

check and/or verification processes performed.

63. Plaintiff, as well as other Democratic voters have and are suffering the total loss of

confidence in the DNC primary process because of the massive cheating and

skewering of rules to make an illegitimate ineligible candidate the nominee in

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violation of DNC rules and the U.S. Constitution, robbing voters of their voices and

votes. Plaintiff and millions of other Democratic voters have lost all trust in the

integrity of the PA Department of State, Bureau of Commissions, Elections and

Legislation, the FEC and Democratic Party leaders by the total failure of the DNC to

perform the most basic of functions by insisting any candidates produce

basic documents in vetting their eligibility, especially after there were repeated

requests demanding Obama’s eligibility be proven with certified legitimate

documents which had not been forged. This failure to perform even the most basic of

due diligence has shattered Plaintiff’s faith, along with millions of

Democratic voters, in the Democratic system.

64. Plaintiff has been damaged financially for all monies donated, billable hours spent

supporting the Democratic candidates, taxes paid by Plaintiff which went to the

Secret Service for their protection of Obama for the past twenty (20) months and for

the financial costs and time expended of this litigation, when Defendants could have

very easily investigated, verified and obtained proof of Obama’s eligibility to serve as

President of the United States, if in fact he is eligible.

65. Plaintiff has suffered damage to his reputation and discrimination as a result of

attempting to protect his rights and verify the eligibility of Obama to serve as

President of the United States. Plaintiff has been repeatedly called a racist and

verbally assaulted for bringing forward this lawsuit against Obama. Plaintiff is not a

racist and is a paid Life Member of the NAACP. Obama himself stated to a crowd of

his supporters,

 

“I need you to go out and talk to your friends and talk to yourneighbors. I want you to talk to them whether they are independent or whether they

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are Republican. I want you to argue with them and get in their face”

 

, as quoted in anewspaper article published in the San Francisco Gate, by Kathleen Hennessey,

Associated Press Writer, on September 17, 2008. Obama is promoting attacks on

non-supporters, which is creating racial tension and violence in our communities, of

which Plaintiff has been victim too.

66. Plaintiff has attempted to obtain the verification and proof requested herein by way of

requests, filing this action, Admissions and Request for Production of Documents

served upon Defendants September 15, 2008 and by Subpoenas served upon agencies

who could supply the documentation to prove Obama’s citizenship status. To date,

Plaintiff has not received anything. Plaintiff has received five (5) letters from

agencies that were served with subpoenas claiming they need Obama’s signatures to

comply and/or the confidentiality of the documents were protected from disclosure to

third parties under 5 U.S. C. § 552. The Freedom of Information Act (FOIA), 5

U.S.C. § 552(a) allows for the disclosure of documents. If the documents contain

confidential information, the Agency is required to redact the confidential part, e.g.

social security number.

67. Further damages to Plaintiff, if Obama is voted into the Office of the President and

allowed to assume said position, in violation of Article II, Section of our Constitution

as he is not a “natural born” citizen, it would be Unconstitutional. Plaintiff would

suffer further damages as any act or action that Obama executes is Unconstitutional.

This would create massive litigation and a complete disarray of our government and a

Constitutional crisis.

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68. Furthermore, the DNC has made specific promises to uphold our Constitution and to

protect the Democratic people; however, they have failed, which constitute damages

under “Promissory Estoppel”.

69. Plaintiff does not have any other means of redress. The issues presented are critical

in order to protect the rights of Plaintiff. Furthermore, there are not any specific

administrative remedies outlined in our laws pertaining to the challenge of a

Presidential candidate who in fact is not a qualified citizen to serve as our President

of the United States pursuant to our United States Constitution.

70. If Obama is allowed to continue his campaign and is elected as our President of the

United States it will be unconstitutional to allow him to serve. Further, if the issues

of Obama’s citizenship status are ignored and he is allowed to assume the position of

President of the United States, anything Obama enters into and/or signs while in

Office will be void, as Obama is not constitutionally eligible to hold the Office of

United States President.

71. Due to the urgency of these issues, Plaintiff is requesting waiver of the Government

Claim requirement.

72. Plaintiff is requesting through this lawsuit an Order for Obama, the DNC, the FEC,

the U.S. Senate, Commission on Rules and Administration and the Pennsylvania

Department of State, Bureau of Commissions, Elections and Legislation to

immediately turn over to Plaintiff the following documents:

(a) A certified copy of Obama’s “vault” (original long version) birth

certificate;

(b) All reissued and sealed birth certificates of Obama;

(c) A certified copy of Obama’s Certification of Citizenship;

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(d) A certified copy of Obama’s Oath of Allegiance taken upon age of

majority; and

(e) Certified copies of Obama’s Admission forms for Occidental College,

Columbia University and Harvard Law School.

COUNT ONE

(Against All Defendants)

Violation of the United States

Constitution, Article II, Section I

73. Plaintiff hereby incorporates Paragraphs 1 through 72 as if fully set forth herein.

74. The United States Constitution, Article II, Section I, Clause 4, Qualifications, Office

of President, 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.”

75. Obama does not and has not been eligible to be constituted a United States “natural

born” citizen and has failed to obtain and/or maintain “naturalized” citizenship status.

76. Obama, if born in Kenya would have made him a citizen of Kenya. Furthermore,

because of the 1940 Naturalization Act, June 1952, Obama’s mother would have had

to be nineteen (19) in order for Obama to be a “natural born” United States citizen.

Obama’s mother was only eighteen (18) when she had Obama and therefore was not

old enough to meet the residency requirements under our laws at the time of Obama’s

birth and be able to register her son’s birth as a “natural born” citizen.

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77. Even if Obama would have been able to be registered as a U.S. “natural born” citizen

in Hawaii, which was not legally permissible, he lost his citizenship in the United

States when his mother married Lolo Soetoro, a citizen of Indonesia, and became a

naturalized citizen in Indonesia and set up residency in Indonesia with her new

husband. Minor’s follow their custodial parent’s citizenship status.

78. Moreover, Obama’s Indonesian step father, Lolo Soetoro, signed a Government

acknowledgement form acknowledging Obama as his son and/or legally adopted

Obama, either of which changed Obama’s citizenship status to a “natural” citizen of

Indonesia. Thus, Obama could have only obtained Naturalized citizenship status in

the United States, if in fact he and/or his family filed the proper immigration

paperwork after his return to the United States from Indonesia.

79. Obama’s Indonesian citizenship status is proven on his school record with a public

school in Jakarta Indonesia, which he attended. Obama’s school record clearly states

his name Barry Soetoro, his citizenship, Indonesian, his religion Islam. This

information was verified by the public schools in Jakarta upon registration of the

student with the Indonesian Government. Indonesia did

 

not allow foreign students toattend their schools and Indonesia Immigration Officials and the Police frequently

visited the schools to ensure the students attending were all Indonesian citizens

pursuant to the laws.

80. Students attending the public school system in Jakarta Indonesia at the time Obama

attended had to wear and/or carry with them identification cards, again which were

verified with the Governments records in Indonesia. The student’s identification

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cards displayed their citizenship number, their legal name, their parents names, etc.

The identification cards had to match the student’s school enrollment information.

81. Plaintiff is informed, believes and thereon alleges Obama stated his citizenship as

Kenyan on his College Admission forms to Occidental College, Columbia University

and Harvard Law School.

82. The Democratic National Committee (DNC) is supposed to represent and protect the

interests of working Americans, which includes securing a Democratic Nominee on

the Presidential Election ballot who represents the Democratic vision and who is

qualified and eligible to run for Office of the President pursuant to the qualifications

of the United States Constitution. The DNC has also promised all democratic

citizens, including Plaintiff that they will in fact uphold the Constitution and require

those in office to do the same. The DNC has failed to inquire into Obama’s

eligibility status.

83. The FEC has the responsibility to ensure the Presidential candidate is in fact eligible

to serve as President of the United States and is responsible for the administration,

enforcement and formulation of policy, exclusive jurisdiction of civil enforcement,

congressional authorities or functions with respect to elections for Federal Office, 2

U.S.C. § 437c (b).

84. The FEC is also responsible for ensuring the compliance with the Federal Election

Campaign Fund Act, which includes eligible candidates, candidates of a political

party for President and/or Vice President of the United States who have met all

applicable conditions for eligibility for the position being sought in order to receive

payments. 26 U.S.C. § 9002, et seq.

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85. The U.S. Senate, Commission on Rules and Administration and Feinstein also carry

the responsibility to ensure the Presidential candidate is in fact a U.S. “natural born”

citizen and eligible to serve the position they so seek. U.S. Senate, Commission on

Rules and Administration and Feinstein has the responsibility to ensure corrupt

practices are not taking place or corrupt actions of any member of the Senate. The

U.S. Senate Commission on Rules and Administration and Feinstein have the

responsibility of verifying the credentials, qualifications and eligibility status of all

Members of the Senate, contested elections, Federal elections generally, including the

election of the President, Vice President and Members of the Congress, Standing

Rules of the Senate, Rule 25.

86. The DNC, FEC, Feinstein and the U.S. Senate Commission on Rules and

Administration have failed Plaintiff as they have not performed their duties so

delegated to them pursuant to the Laws of our Country and their promises.

Defendants have allowed an ineligible candidate to be nominated as United States

President without performing due diligence in verifying Obama’s eligibility and/or

investigating the fraudulent acts of Obama, for which Plaintiff has been damaged.

Defendants have further allowed the illegal and fraudulent campaigning efforts of

Obama to continue in an attempt to allow an ineligible candidate to serve as United

States President in violation of our United States Constitution.

87. The PA Department of State and Pedro A. Cortés, Secretary of the Commonwealth,

PA Department of State, Bureau of Commissions, Elections and Legislation has the

responsibility of placing eligible candidates on the official ballot for the

Commonwealth of Pennsylvania. The Department of State, Bureau of Commissions,

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Elections and Legislation has failed to verify Obama’s citizenship status prior to

placing his name on the ballot in Pennsylvania.

88. The DNC, FEC, Feinstein, U.S. Senate, Commission on Rules and Administration

and the PA Department of State and Pedro A. Cortés, PA Secretary of the

Commonwealth, PA Department of State, Bureau of Commissions, Elections and

Legislation have allowed Obama’s illegal and fraudulent campaign, which Obama

has received in excess of $450 Million in donations, to continue knowing Obama is

not

 

a “natural born” citizen and knowing Obama is not eligible to take and/or servethe position of President of the United States, for which he was receiving donations.

89. Plaintiff has been severely damaged as a result of Defendants actions. Plaintiff has

been deprived liberty, property, due process of law and equal protections of the laws

all guaranteed under the United States Constitution.

90. For the above aforementioned reasons, Defendants need to immediately supply a

certified copy of Obama’s “vault” (original long version) birth certificate; certified

copies of all reissued and sealed birth certificates for Obama; a certified copy of

Obama’s Certification of Citizenship; a Certified copy of Obama’s Oath of

Allegiance taken upon the age of Majority; and certified copies of Obama’s

Admission forms for Occidental College, Columbia University and Harvard law

School. If Defendants are unable to supply said documents, Obama needs to

immediately step down and withdraw his candidacy for United States President.

WHEREFORE

,  

Plaintiff, Philip J. Berg, Esquire, respectfully prays thatthis Court:

A. Order Defendants to immediately turn over the following documents:

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1. A certified copy of Obama’s “vault” (original long version) birth

certificate;

2. Certified copies of all reissued and sealed birth certificates of

Obama in the names referred to in the caption of this lawsuit;

3. A certified copy of Obama’s Certification of Citizenship;

4. A certified copy of Obama’s Oath of Allegiance taken upon age of

majority;

5. Certified copies of Obama’s Admission forms for Occidental

College, Columbia University and Harvard Law School; and

6. Certified copies of any Court Orders or legal documents changing

Obama’s name from Barry Soetoro to Barack Hussein Obama.

B. Declare that Defendant Barack Hussein Obama, a/k/a Barry Obama, a/k/a

Barry Soetoro, a/k/a Barack Soetoro, a/k/a Barry Dunham, a/k/a Barack Dunham

is not a “natural born” or “naturalized” citizen of the United States;

C. Declare that Defendant Barack Hussein Obama, a/k/a Barry Obama, a/k/a

Barry Soetoro, a/k/a Barack Soetoro, a/k/a Barry Dunham, a/k/a Barack Dunham

ineligible to run for United States Office of the President under the United States

Constitution, Article II, Section I;

D. Preliminary and permanently enjoin Defendant Barack Hussein Obama,

a/k/a Barry Obama, a/k/a Barry Soetoro, a/k/a Barack Soetoro, a/k/a Barry

Dunham, a/k/a Barack Dunham from any further campaigning and from running

for United States Office of the President;

E. Preliminary and permanently enjoin Defendants, The Democratic National

Committee (DNC), the PA Department of State and Pedro A. Cortés, Secretary of

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the Commonwealth, PA Department of State, Bureau of Commissions, Elections

and Legislation from placing Defendant Barack Hussein Obama, a/k/a Barry

Obama, a/k/a Barry Soetoro, a/k/a Barack Soetoro, a/k/a Barry Dunham, a/k/a

Barack Dunham’s name on the ballot for election of United States President;

F. Order the FEC, Feinstein and the U.S. Senate Commission on Rules and

Administration to immediately open and conduct an investigation into the

fraudulent tactics of Obama and immediately open and conduct an investigation

into the citizenship status of Obama;

G. Waive the Governmental Claim requirement due to the urgency of this

matter;

H. Award Plaintiff such costs and fees pursuant to 42 U.S.C. § 1988 and

other applicable law; and

I. Grant Plaintiff such other and further relief as the Court deems just and

proper.

COUNT TWO

(Against All Defendants)

Civil Rights, Civil Action for Deprivation of Rights

In violation of 42 U.S.C. §1983

91. Plaintiff hereby incorporates Paragraphs 1 through 90 as if fully set forth herein.

92. Defendants, acting under the color of law and in concert with one another, engaged in

intentional due process and equal protection of the law violations. In so doing,

Defendants have caused the Plaintiff to suffer deprivation of his fundamental rights to

Z:\Forms\Obama, First Amended Complaint 100608

30

due process and equal protection of the laws secured by the United States

Constitution under the Fourteenth Amendment and the Laws of the United States.

93. Plaintiff has been deprived of money and billable hours by fraudulent means as a

result of donating money and billable hours to secure, as promised, an eligible

Democratic candidate for Office of the Presidency, in which to cast his vote. The

DNC named Obama as the Democratic Nominee, who is ineligible to serve as the

United States President as he is not a “natural born” citizen, a qualification and

eligibility requirement pursuant to Article II, Section I of the United States

Constitution. Moreover, Plaintiff has been deprived of his right to vote for an eligible

Democratic Nominee for the U.S. Office of the President.

94. On September 2, 2008, an avid Obama supporter, Fatimah Ali, an Opinion writer for

The Philadelphia Daily News reported Ms. Ali’s opinion, ”

 

If McCain wins, look fora full-fledged race and class war, fueled by a deflated and depressed country,

soaring crime, homelessness – hopelessness!

 

95. Fox News followed this story publishing, ”

 

A fanatical Obama supporter inPhiladelphia is threatening a race war if John McCain wins

 

96. Obama stated to a crowd of his supporters,

 

“I need you to go out and talk to yourfriends and talk to your neighbors. I want you to talk to them whether they are

independent or whether they are Republican. I want you to argue with them and get

in their face…You are my Ambassadors”,

 

as quoted in a newspaper articlepublished in the San Francisco Gate, by Kathleen Hennessey, Associated Press

Writer, on September 17, 2008. Obama is furthering racial tension and promoting

Z:\Forms\Obama, First Amended Complaint 100608

31

attacks on non-supporters, which is creating racial tension and violence in our

communities, of which Plaintiff has been victim too.

97. Obama and his campaign have abused their position and the law for intimidation

purposes to stop people from free speech when the speech includes criticism or

questioning of Obama in violation of Plaintiff’s and other American’s civil Rights.

98. Missouri Governor Matt Blunt issued a Press Release stating in pertinent part, ”

 

WhatSenator Obama and his helpers are doing is scandalous beyond words…… abusing

the justice system and offices of public trust to silence political criticism with threats

of prosecution and criminal punishment. This abuse of the law for intimidation insults

the most sacred principles and ideals of Jefferson. I can think of nothing more

offensive to Jefferson’s thinking than using the power of the state to deprive

Americans of their civil rights. The only conceivable purpose of Messrs. McCulloch,

Obama and the others is to frighten people away from expressing themselves, to chill

free and open debate, to suppress support and donations to conservative

organizations targeted by this anti-civil rights, to strangle criticism of Mr. Obama, to

suppress ads about his support of higher taxes, and to choke out criticism on

television, radio, the Internet, blogs, e-mail and daily conversation about the

election. “Barack Obama needs to grow up……Enlisting Missouri law enforcement

to intimidate people and kill free debate is reminiscent of the Sedition Acts – not a

free society.”

99. As a result of Obama’s message to the People of America, Plaintiff has suffered

damage to his reputation and discrimination and fears for his safety as a result of

attempting to protect his rights and verify the eligibility of Obama to serve as

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32

President of the United States. Plaintiff has been repeatedly called a racist and

verbally assaulted for bringing forward this lawsuit against Obama. Plaintiff is not a

racist and is a paid Life Member of the NAACP. Plaintiff has received numerous

nasty emails accusing him of being a racist as a result of filing this action against

Obama. Moreover, Plaintiff has been verbally assaulted by black individuals at a

local store he frequents as well as in public for bringing suit against Obama

questioning his citizenship status. All of which is in violation of Plaintiff’s right’s to

due process of the law, equal protection of the laws and the Liberty Clause secured by

the Fourteenth Amendment of the U.S. Constitution.

100. Defendants are attempting to change our United States Constitution without proper

due process of law by allowing Obama to continue his campaign and continue

seeking election as the President of the United States, knowing he is not a “natural

born” citizen and the fact he may not even be a “naturalized” citizen.

101. It has been announced in the main stream media that Obama’s “briefing” has already

begun into our National Secrets, our Nations Top Secrets, which Obama is not privy

too and in violation of our National Security, as Obama is not a legal citizen of the

United States. This has placed Plaintiff and other citizens of the United States in

grave danger. Plaintiff’s Life, Liberty and Property rights guaranteed by the

Fourteenth Amendment of the U.S. Constitution will further be violated if Obama is

allowed to be voted into and assume the position of President of the United States;

Plaintiff will be further damaged and is in serious jeopardy.

102. Obama was born in Mombosa, Kenya, and his mother was not old enough to pass on

U.S. “natural born” citizenship status to Obama,

 

United States of America v.Z:\Forms\Obama, First Amended Complaint 100608

33

Cervantes-Nava

 

, 281 F.3d 501 (2002), Drozd v. I.N.S., 155 F.3d 81, 85-88 (2dCir.1998).

103. Additionally, Obama lost any “naturalized” citizenship status when he b e c a m e a

“natural” citizen of Indonesia. Obama’s mother married Lolo Soetoro an Indonesian

Citizen in or about 1964/1965. Lolo Soetoro acknowledged Obama as his son and/or

adopted Obama thus changing his citizenship status to a “natural” citizen of

Indonesia. Under Indonesian law, when a male acknowledges a child as his son, it

deems the son, in this case Obama, as an Indonesian State citizen. Constitution of

Republic of Indonesia, Law No. 62 of 1958 Law No. 12 of 2006 dated 1 Aug. 2006

concerning Citizenship of Republic of Indonesia, Law No. 9 of 1992 dated 31 Mar.

1992 concerning Immigration Affairs and Indonesian Civil Code (Kitab Undangundang

Hukum Perdata) (KUHPer) (Burgerlijk Wetboek voor Indonesie). Republic

of Indonesia Constitution 1945, a

 

s amended by the First Amendment of 1999, theSecond Amendment of 2000, the Third Amendment of 2001 and the Four th

Amendment of 2002,

 

Chapter X, Citizens and Residents, Article 26 states “(1)Citizens shall consist of indigenous Indonesian peoples and persons of foreign origin

who have been legalized as citizens in accordance with law. (2) Residents shall

consist of Indonesian citizens and foreign nationals living in Indonesia

 

.” Obama wasa “natural” citizen of Indonesia and not a foreign national, as proven by his

Indonesian school registration

104. The DNC, FEC, Feinstein and the U.S. Senate Commission on Rules and

Administration have failed Plaintiff as they have not performed their duties so

delegated to them pursuant to the Laws of our Country and their promises.

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Defendants have allowed an ineligible candidate to be nominated as President of the

United States without performing due diligence in verifying Obama’s eligibility

and/or investigating the fraudulent acts of Obama, for which Plaintiff has been

damaged. Defendants have further allowed the illegal and fraudulent campaigning

efforts of Obama to continue in an attempt to allow an ineligible candidate to serve as

President of the United States in violation of our United States Constitution.

105. The PA Department of State and Pedro A. Cortés, Secretary of the Commonwealth,

PA Department of State, Bureau of Commissions, Elections and Legislation has the

responsibility of placing eligible candidates on the official ballot for the State of

Pennsylvania. The PA Department of State, Bureau of Commissions, Elections and

Legislation has failed to verify Obama’s citizenship status prior to placing his name

on the ballot in Pennsylvania.

106. The DNC, FEC, Feinstein, U.S. Senate, Commission on Rules and Administration,

the PA Department of State and Pedro A. Cortés, Secretary of the Commonwealth,

PA Department of State, Bureau of Commissions, Elections and Legislation have

allowed Obama’s illegal and fraudulent campaign, which Obama has received in

excess of $450 Million in donations, to continue knowing Obama is

 

not a “naturalborn” citizen and knowing Obama is not eligible to take and/or s e r v e t h e

position of President of the United States, for which he was receiving donations.

107. Plaintiff has been severely damaged as a result of Defendants actions. Plaintiff has

been deprived liberty, property, due process of law and equal protections of the laws

all guaranteed under the United States Constitution.

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108. For the above aforementioned reasons, Defendants need to immediately supply a

certified copy of Obama’s “vault” (original long version) birth certificate; certified

copies of all reissued and sealed birth certificates for Obama; a certified copy of

Obama’s Certification of Citizenship; a Certified copy of Obama’s Oath of

Allegiance taken upon the age of Majority; and certified copies of Obama’s

Admission forms for Occidental College, Columbia University and Harvard law

School. If Defendants are unable to supply said documents, Obama needs to

immediately step down and withdraw his candidacy for President of the United

States.

WHEREFORE

,  

Plaintiff, Philip J. Berg, Esquire, respectfully prays thatthis Court:

A. Order Defendants to immediately turn over the following documents:

1. A certified copy of Obama’s “vault” (original long version) birth

certificate;

2. Certified copies of all reissued and sealed birth certificates of

Obama in the names referred to in the caption of this lawsuit;

3. A certified copy of Obama’s Certification of Citizenship;

4. A certified copy of Obama’s Oath of Allegiance taken upon age of

majority;

5. Certified copies of Obama’s Admission forms for Occidental

College, Columbia University and Harvard Law School; and

6. Certified copies of any Court Orders or legal documents changing

Obama’s name from Barry Soetoro to Barack Hussein Obama.

B. Declare that Defendant Barack Hussein Obama, a/k/a Barry Obama, a/k/a

Barry Soetoro, a/k/a Barack Soetoro, a/k/a Barry Dunham, a/k/a Barack Dunham

is not a “natural born” or “naturalized” citizen of the United States;

Z:\Forms\Obama, First Amended Complaint 100608

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C. Declare that Defendant Barack Hussein Obama, a/k/a Barry Obama, a/k/a

Barry Soetoro, a/k/a Barack Soetoro, a/k/a Barry Dunham, a/k/a Barack Dunham

ineligible to run for United States Office of the President under the United States

Constitution, Article II, Section I;

D. Preliminary and permanently enjoin Defendant Barack Hussein Obama,

a/k/a Barry Obama, a/k/a Barry Soetoro, a/k/a Barack Soetoro, a/k/a Barry

Dunham, a/k/a Barack Dunham from any further campaigning and from running

for United States Office of the President;

E. Preliminary and permanently enjoin Defendants, The Democratic National

Committee (DNC), the PA Department of State and Pedro A. Cortés, PA

Secretary of the Commonwealth, PA Department of State, Bureau

of Commissions, Elections and Legislation from placing Defendant Barack

Hussein Obama, a/k/a Barry Obama, a/k/a Barry Soetoro, a/k/a Barack Soetoro,

a/k/a Barry Dunham, a/k/a Barack Dunham’s name on the ballot for election of

President of the United States;

F. Order the FEC, Feinstein and the U.S. Senate Commission on Rules and

Administration to immediately open and conduct an investigation into the

fraudulent tactics of Obama and immediately open and conduct an investigation

into the citizenship status of Obama;

G. Waive the Governmental Claim requirement due to the urgency of this

matter;

H. Award Plaintiff such costs and fees pursuant to 42 U.S.C. § 1988 and

other applicable law; and

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I. Grant Plaintiff such other and further relief as the Court deems just and

proper.

COUNT THREE

(Against All Defendants)

Civil Rights, Conspiracy to Interfere with Civil rights

In violation of 42 U.S.C. § 1985

109. Plaintiff hereby incorporates Paragraphs 1 through 108 as if fully set forth herein.

110. Defendants, acting under the color of law and in concert with one another, engaged in

intentional due process and equal protection of the law violations. In so doing,

Defendants have caused the Plaintiff to suffer deprivation of his fundamental rights to

due process and equal protection of the laws secured by the United States

Constitution under the Fourteenth Amendment and the Laws of the United States.

111. Defendants and each of them conspired with each other to deprive Plaintiff of his

right to due process, right to equal protection of the laws, and protection of the laws

of the Commonwealth of Pennsylvania, as well as Plaintiff’s Constitutional Rights

secured by the Fourteenth Amendment of the United States Constitution.

112. Obama knowing he is not a “natural born” United States Citizen and knowing he is a

citizen of Indonesia fraudulently sought and accomplished having his name placed on

the ballot for the Democratic Nominee for President of the United States, which he

accomplished.

113. Obama encouraged his supporters to act as his Ambassadors; to knock on doors, get

mad and get in peoples faces in efforts to seek their votes for Obama, which has

created violence and racial tension. Unfortunately, Obama’s supporters have

complied with Obama’s request.

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114. Obama has further fraudulently campaigned to be elected as President of the United

States and has obtained in excess of $450 Million dollars in donations based on his

fraudulent campaigning, again, knowing he is not eligible to serve as President of the

United States as he is not a “natural born” U.S. citizen, as required by the United

States Constitution, Article II, Section I.Obama is well aware he is in fact a citizen of

Indonesia.

115. Obama and his campaign have abused their position and the law for intimidation

purposes to stop people from free speech when the speech includes criticism or

questioning of Obama in violation of Plaintiff’s and other American’s civil Rights.

116. The DNC, FEC, Feinstein and the U.S. Senate Commission on Rules and

Administration have failed Plaintiff as they have not performed their duties so

delegated to them pursuant to the Laws of our Country and their promises.

Defendants have allowed an ineligible candidate to be nominated as President of the

United States without performing due diligence in verifying Obama’s eligibility

and/or investigating the fraudulent acts of Obama, for which Plaintiff has been

damaged. Defendants have further allowed the illegal and fraudulent campaigning

efforts of Obama to continue in an attempt to allow an ineligible candidate to serve as

President of the United States in violation of our United States Constitution.

117. The PA Department of State and Pedro A. Cortés, Secretary of the Commonwealth,

PA Department of State, Bureau of Commissions, Elections and Legislation has the

responsibility of placing eligible candidates on the official ballot for the

Commonwealth of Pennsylvania. The PA Department of State, Bureau of

Z:\Forms\Obama, First Amended Complaint 100608

39

Commissions, Elections and Legislation has failed to verify Obama’s citizenship

status prior to placing his name on the ballot in Pennsylvania.

118. The DNC, FEC, Feinstein, U.S. Senate, Commission on Rules and Administration,

the PA Department of State and Pedro A. Cortés, Secretary of the Commonwealth,

PA Department of State, Bureau of Commissions, Elections and Legislation have

allowed Obama’s illegal and fraudulent campaign, which Obama has received in

excess of $450 Million in donations, to continue knowing Obama is

 

not a “naturalborn” citizen and knowing Obama is not eligible to take and/or serve the position of

President of the United States, for which he was receiving donations.

119. As a result, Plaintiff has been deprived of money and billable hours by fraudulent

means as a result of donating money and billable hours to secure, as promised, an

eligible Democratic candidate for Office of the Presidency, in which to cast his vote.

The DNC named Obama as the Democratic Nominee, who is ineligible to serve as

the President of the United States as he is not a “natural born” citizen, a qualification

and eligibility requirement pursuant to Article II, Section I of the United States

Constitution. Moreover, Plaintiff has been deprived of his right to vote for an eligible

Democratic Nominee for the U.S. Office of the Presidency.

120. Plaintiff has been severely damaged as a result of Defendants actions. Plaintiff has

been deprived liberty, property, due process of law and equal protections of the laws

all guaranteed under the United States Constitution.

121. As a result of Obama’s message to the People of America, Plaintiff has suffered

damage to his reputation and discrimination and fears for his safety as a result of

attempting to protect his rights and verify the eligibility of Obama to serve as

Z:\Forms\Obama, First Amended Complaint 100608

40

President of the United States. Plaintiff has been repeatedly called a racist and

verbally assaulted for bringing forward this lawsuit against Obama. Plaintiff is not a

racist and is a paid Life Member of the NAACP. Plaintiff has received numerous

nasty emails accusing him of being a racist as a result of filing this action against

Obama. Moreover, Plaintiff was verbally assaulted by a black female in public for

bringing suit against Obama questioning his citizenship status. All of which is in

violation of Plaintiff’s right’s to due process of the law, equal protection of the laws

and the Liberty Clause secured by the Fourteenth Amendment of the U.S.

Constitution

122. For the above aforementioned reasons, Defendants need to immediately supply a

certified copy of Obama’s “vault” (original long version) birth certificate; certified

copies of all reissued and sealed birth certificates for Obama; a certified copy of

Obama’s Certification of Citizenship; a Certified copy of Obama’s Oath of

Allegiance taken upon the age of Majority; and certified copies of Obama’s

Admission forms for Occidental College, Columbia University and Harvard law

School. If Defendants are unable to supply said documents, Obama needs to

immediately step down and withdraw his candidacy for President of the United

States.

WHEREFORE

,  

Plaintiff, Philip J. Berg, Esquire, respectfully prays thatthis Court:

A. Order Defendants to immediately turn over the following documents:

1. A certified copy of Obama’s “vault” (original long version) birth

certificate;

Z:\Forms\Obama, First Amended Complaint 100608

41

2. Certified copies of all reissued and sealed birth certificates of

Obama in the names referred to in the caption of this lawsuit;

3. A certified copy of Obama’s Certification of Citizenship;

4. A certified copy of Obama’s Oath of Allegiance taken upon age of

majority;

5. Certified copies of Obama’s Admission forms for Occidental

College, Columbia University and Harvard Law School; and

6. Certified copies of any Court Orders or legal documents changing

Obama’s name from Barry Soetoro to Barack Hussein Obama.

B. Declare that Defendant Barack Hussein Obama, a/k/a Barry Obama, a/k/a

Barry Soetoro, a/k/a Barack Soetoro, a/k/a Barry Dunham, a/k/a Barack Dunham

is not a “natural born” or “naturalized” citizen of the United States;

C. Declare that Defendant Barack Hussein Obama, a/k/a Barry Obama, a/k/a

Barry Soetoro, a/k/a Barack Soetoro, a/k/a Barry Dunham, a/k/a Barack Dunham

ineligible to run for United States Office of the President under the United States

Constitution, Article II, Section I;

D. Preliminary and permanently enjoin Defendant Barack Hussein Obama,

a/k/a Barry Obama, a/k/a Barry Soetoro, a/k/a Barack Soetoro, a/k/a Barry

Dunham, a/k/a Barack Dunham from any further campaigning and from running

for United States Office of the President;

E. Preliminary and permanently enjoin Defendants, The Democratic National

Committee (DNC), the PA Department of State and Pedro A. Cortés, Secretary

of the Commonwealth, PA Department of State, Bureau of Commissions,

Elections and Legislation from placing Defendant Barack Hussein Obama, a/k/a

Barry Obama, a/k/a Barry Soetoro, a/k/a Barack Soetoro, a/k/a Barry Dunham,

Z:\Forms\Obama, First Amended Complaint 100608

42

a/k/a Barack Dunham’s name on the ballot for election of P r e s i d e n t o f t h e

United States;

F. Order the FEC, Feinstein and the U.S. Senate Commission on Rules and

Administration to immediately open and conduct an investigation into the

fraudulent tactics of Obama and immediately open and conduct an investigation

into the citizenship status of Obama;

G. Waive the Governmental Claim requirement due to the urgency of this

matter;

H. Award Plaintiff such costs and fees pursuant to 42 U.S.C. § 1988 and

other applicable law; and

I. Grant Plaintiff such other and further relief as the Court deems just and

proper.

COUNT FOUR

(Against All Defendants)

Civil Rights, Action for Neglect to Prevent

In violation of 42 U.S.C. § 1986

123. Plaintiff hereby incorporates Paragraphs 1 through 122 as if fully set forth herein.

124. Defendants, acting under the color of law and in concert with one another, engaged in

intentional due process and equal protection of the law violations. In so doing,

Defendants have caused the Plaintiff to suffer deprivation of his fundamental rights to

due process and equal protection of the laws secured by the United States

Constitution under the Fourteenth Amendment and the Laws of the United States.

125. The DNC, FEC, Feinstein and the U.S. Senate Commission on Rules and

Administration were and are well aware of Obama’s illegal activities, encouraging

Z:\Forms\Obama, First Amended Complaint 100608

43

racial tension, encouraging violence, his fraudulent campaigning, fraudulently

attempting to secure the position of President of the United States. Defendants have

failed Plaintiff as they have not performed their duties so delegated to them pursuant

to the Laws of our Country and their promises. Defendants have allowed an

ineligible candidate to be nominated as President of the United States without

performing due diligence in verifying Obama’s eligibility and/or investigating the

fraudulent acts of Obama, for which Plaintiff has been damaged. Defendants have

further allowed the illegal and fraudulent campaigning efforts of Obama to continue

in an attempt to allow an ineligible candidate to serve as President of the United

States in violation of our United States Constitution.

126. The PA Department of State and Pedro A. Cortés, Secretary of the Commonwealth,

PA Department of State, Bureau of Commissions, Elections and Legislation has the

responsibility of placing eligible candidates on the official ballot for the

Commonwealth of Pennsylvania. The PA Department of State, Bureau of

Commissions, Elections and Legislation has failed to verify Obama’s citizenship

status prior to placing his name on the ballot in Pennsylvania.

127. The DNC, FEC, Feinstein, U.S. Senate, Commission on Rules and Administration,

the PA Department of State and Pedro A. Cortés, Secretary of the Commonwealth,

PA Department of State, Bureau of Commissions, Elections and Legislation have

allowed Obama’s illegal and fraudulent campaign, which Obama has received in

excess of $450 Million in donations, to continue knowing Obama is

 

not a “naturalborn” citizen and knowing Obama is not eligible to take and/or serve the position of

President of the United States, for which he was receiving donations.

Z:\Forms\Obama, First Amended Complaint 100608

44

128. As a result, Plaintiff has been deprived of money and billable hours by fraudulent

means as a result of donating money and billable hours to secure, as promised, an

eligible Democratic candidate for Office of the Presidency, in which to cast his vote.

The DNC named Obama as the Democratic Nominee, who is ineligible to serve as

the President of the United States as he is not a “natural born” citizen, a qualification

and eligibility requirement pursuant to Article II, Section I of the United States

Constitution. Moreover, Plaintiff has been deprived of his right to vote for an eligible

Democratic Nominee for the U.S. Office of the Presidency.

129. Plaintiff has been severely damaged as a result of Defendants actions. Plaintiff has

been deprived of liberty, property, due process of law and equal protections of the

laws all guaranteed under the United States Constitution.

130. As a result of Obama’s message to the People of America, Plaintiff has suffered

damage to his reputation and discrimination and fears for his safety as a result of

attempting to protect his rights and verify the eligibility of Obama to serve as

President of the United States. Plaintiff has been repeatedly called a racist and

verbally assaulted for bringing forward this lawsuit against Obama. Plaintiff is not a

racist and is a paid Life Member of the NAACP. Plaintiff has received numerous

nasty emails accusing him of being a racist as a result of filing this action against

Obama. Moreover, Plaintiff was verbally assaulted by a black female in public for

bringing suit against Obama questioning his citizenship status. All of which is in

violation of Plaintiff’s right’s to due process of the law, equal protection of the laws

and the Liberty Clause secured by the Fourteenth Amendment of the U.S.

Constitution.

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45

131. For the above aforementioned reasons, Defendants need to immediately supply a

certified copy of Obama’s “vault” (original long version) birth certificate; certified

copies of all reissued and sealed birth certificates for Obama; a certified copy of

Obama’s Certification of Citizenship; a Certified copy of Obama’s Oath of

Allegiance taken upon the age of Majority; and certified copies of Obama’s

Admission forms for Occidental College, Columbia University and Harvard law

School. If Defendants are unable to supply said documents, Obama needs to

immediately step down and withdraw his candidacy for President of the United

States.

WHEREFORE

,  

Plaintiff, Philip J. Berg, Esquire, respectfully prays thatthis Court:

A. Order Defendants to immediately turn over the following documents:

1. A certified copy of Obama’s “vault” (original long version) birth

certificate;

2. Certified copies of all reissued and sealed birth certificates of

Obama in the names referred to in the caption of this lawsuit;

3. A certified copy of Obama’s Certification of Citizenship;

4. A certified copy of Obama’s Oath of Allegiance taken upon age of

majority;

5. Certified copies of Obama’s Admission forms for Occidental

College, Columbia University and Harvard Law School; and

6. Certified copies of any Court Orders or legal documents changing

Obama’s name from Barry Soetoro to Barack Hussein Obama.

B. Declare that Defendant Barack Hussein Obama, a/k/a Barry Obama, a/k/a

Barry Soetoro, a/k/a Barack Soetoro, a/k/a Barry Dunham, a/k/a Barack Dunham

is not a “natural born” or “naturalized” citizen of the United States;

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46

C. Declare that Defendant Barack Hussein Obama, a/k/a Barry Obama, a/k/a

Barry Soetoro, a/k/a Barack Soetoro, a/k/a Barry Dunham, a/k/a Barack Dunham

ineligible to run for United States Office of the President under the United States

Constitution, Article II, Section I;

D. Preliminary and permanently enjoin Defendant Barack Hussein Obama,

a/k/a Barry Obama, a/k/a Barry Soetoro, a/k/a Barack Soetoro, a/k/a Barry

Dunham, a/k/a Barack Dunham from any further campaigning and from running

for United States Office of the President;

E. Preliminary and permanently enjoin Defendants, The Democratic National

Committee (DNC), the PA Department of State and Pedro A. Cortés, Secretary of

the Commonwealth, PA Department of State, Bureau of Commissions, Elections

and Legislation from placing Defendant Barack Hussein Obama, a/k/a Barry

Obama, a/k/a Barry Soetoro, a/k/a Barack Soetoro, a/k/a Barry Dunham, a/k/a

Barack Dunham’s name on the ballot for election of President of the United

States;

F. Order the FEC, Feinstein and the U.S. Senate Commission on Rules and

Administration to immediately open and conduct an investigation into the

fraudulent tactics of Obama and immediately open and conduct an investigation

into the citizenship status of Obama;

G. Waive the Governmental Claim requirement due to the urgency of this

matter;

H. Award Plaintiff such costs and fees pursuant to 42 U.S.C. § 1988 and

other applicable law; and

Z:\Forms\Obama, First Amended Complaint 100608

47

I. Grant Plaintiff such other and further relief as the Court deems just and

proper.

COUNT FIVE

(Against all Defendants)

Campaign Fraud,

In violation of the Federal Election Campaign Act

2 U.S.C. § 437, et seq. and 26 U.S.C. § 9002, et seq.

132. Plaintiff hereby incorporates Paragraphs 1 through 131 as if fully set forth herein.

133. Obama committed Fraud upon Plaintiff and the American Citizens by running for

President claiming to be eligible, knowing he was not eligible, knowing he was born

in Mombasa, Kenya and his mother not being old enough to pass U.S. “natural born”

citizenship status to him. Obama is well aware his citizenship status changed from a

U.S. Naturalized citizen, if he ever held such, to a “natural” citizen of Indonesia when

his step father, Lolo Soetoro, an Indonesian citizen, legally acknowledged Obama as

his son and/or adopted Obama.

134. Obama further committed Fraud upon Plaintiff and the American people by falsifying

information on his Illinois State Bar Registration and Public Disciplinary Record.

Obama stated on his Application to the State Bar of Illinois, as proven by the Illinois

State Bar Registration and Disciplinary Record, stating he never used any other

names. Obama signed his application/registration for the Illinois State Bar under the

penalty of perjury knowing the information to be false. The fact of the matter is

Obama used the name Barry Soetoro in Indonesia and was registered as a citizen of

Indonesia on his school records. Obama further used the name Barry Obama and it is

further believed Obama used the name Barack and/or Barry Dunham.

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135. Obama attempted to defraud Plaintiff and the American people by allowing an altered

and forged Hawaii Certification of Live Birth (COLB) to be placed on his campaign

website. Obama was well aware the Government issued COLB was altered and

forged as the original document was in the name of

 

Maya Kasandra Soetoro born in1970. Maya Kassandra Soetoro’s Obama’s half sister who was born in Indonesia and

her birth was later registered in Hawaii. The altered and forged COLB is still on

O b a m a ’ s c a m p a i g n w e b s i t e l o c a t e d a t

http://my.barackobama.com/page/invite/birthcert

136. Furthermore, Obama traveled to Indonesia, Pakistan and Southern India in 1981. The

relations between Pakistan and India were extremely tense and Pakistan was in

turmoil and under martial law. The country was filled with Afghan refugees; and

Pakistan’s Islamist-leaning Interservices Intelligence Agency (ISI) had begun to

provide arms to the Afghan mujahideen and to assist the process of recruiting

radicalized Muslim men–jihadists–from around the world to fight against the Soviet

Union. Pakistan was so dangerous that it was on the State Department’s travel ban

list for US Citizens. Non-Muslim visitors were not welcome unless sponsored by

their embassy for official business. A Muslim citizen of Indonesia traveling on an

Indonesian passport would have success entering Indonesia, Pakistan and India.

Therefore, it is believed Obama traveled on his Indonesian passport entering the

Countries. Indonesian passports require renewal every five (5) years. At the time of

Obama’s travels to Indonesia, Pakistan and India, Obama was twenty (20) years old.

If Obama would have been a U.S. citizen, which he was not, 8 USC §1481(a)(2)

provides loss of nationality by native born citizens upon “taking an oath or making an

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affirmation or other formal declaration of allegiance to a foreign state…after having

attained the age of eighteen years”, in violation of 8 U.S.C. §1401(a)(1). More

importantly, in order to obtain an Indonesian Passport, you had to be an Indonesian

citizen. Since Lolo Soetoro legally acknowledged Obama as his son and/or adopted

Obama, Obama was a “natural” citizen of Indonesia, as proven by Obama’s school

record.

137. Moreover, as stated above, Obama was registered in School in Jakarta, Indonesia as

Barry Soetoro, a citizen of Indonesia, born in 1961 in Hawaii and his religion was

registered as Islam.

138. Obama fraudulently began campaigning to secure the United States Office of the

Presidency and fraudulently accepted in excess of $450 Million dollars knowing he

could never serve as President of the United States.

139. The DNC, FEC, Feinstein and the U.S. Senate Commission on Rules and

Administration were and are well aware of Obama’s illegal activities, encouraging

racial tension, encouraging violence, his fraudulent campaigning, fraudulently

attempting to secure the position of President of the United States. Defendants have

failed Plaintiff as they have not performed their duties so delegated to them pursuant

to the Laws of our Country and their promises. Defendants have allowed an

ineligible candidate to be nominated as President of the United States without

performing due diligence in verifying Obama’s eligibility and/or investigating the

fraudulent acts of Obama, for which Plaintiff has been damaged. Defendants have

further allowed the illegal and fraudulent campaigning efforts of Obama to continue

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in an attempt to allow an ineligible candidate to serve as President of the United

States in violation of our United States Constitution.

140. The PA Department of State and Pedro A. Cortés, Secretary of the Commonwealth,

PA Department of State, Bureau of Commissions, Elections and Legislation has the

responsibility of placing eligible candidates on the official ballot for the

Commonwealth of Pennsylvania. The PA Department of State, Bureau of

Commissions, Elections and Legislation has failed to verify Obama’s citizenship

status prior to placing his name on the ballot in Pennsylvania.

141. The DNC, FEC, Feinstein, U.S. Senate, Commission on Rules and Administration,

the PA Department of State and Pedro A. Cortés, Secretary of the Commonwealth,

PA Department of State, Bureau of Commissions, Elections and Legislation have

allowed Obama’s illegal and fraudulent campaign, which Obama has received in

excess of $450 Million in donations, to continue knowing Obama is

 

not a “naturalborn” citizen and knowing Obama is not eligible to take and/or serve the position of

President of the United States, for which he was receiving donations.

142. As a result, Plaintiff has been deprived of money and billable hours by fraudulent

means as a result of donating money and billable hours to secure, as promised, an

eligible Democratic candidate for Office of the Presidency, in which to cast his vote.

The DNC named Obama as the Democratic Nominee, who is ineligible to serve as

President of the United States as he is not a “natural born” citizen, a qualification and

eligibility requirement pursuant to Article II, Section I of the United States

Constitution. Moreover, Plaintiff has been deprived of his right to vote for an eligible

Democratic Nominee for the U.S. Office of the Presidency.

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143. Plaintiff has been severely damaged as a result of Defendants actions. Plaintiff has

been deprived of liberty, property, due process of law and equal protections of the

laws all guaranteed under the United States Constitution.

144. For the above aforementioned reasons, Defendants need to immediately supply a

certified copy of Obama’s “vault” (original long version) birth certificate; certified

copies of all reissued and sealed birth certificates for Obama; a certified copy of

Obama’s Certification of Citizenship; a Certified copy of Obama’s Oath of

Allegiance taken upon the age of Majority; and certified copies of Obama’s

Admission forms for Occidental College, Columbia University and Harvard law

School. If Defendants are unable to supply said documents, Obama needs to

immediately step down and withdraw his candidacy for President of the United

States.

WHEREFORE

,  

Plaintiff, Philip J. Berg, Esquire, respectfully prays thatthis Court:

A. Order Defendants to immediately turn over the following documents:

1. A certified copy of Obama’s “vault” (original long version) birth

certificate;

2. Certified copies of all reissued and sealed birth certificates of

Obama in the names referred to in the caption of this lawsuit;

3. A certified copy of Obama’s Certification of Citizenship;

4. A certified copy of Obama’s Oath of Allegiance taken upon age of

majority;

5. Certified copies of Obama’s Admission forms for Occidental

College, Columbia University and Harvard Law School; and

6. Certified copies of any Court Orders or legal documents changing

Obama’s name from Barry Soetoro to Barack Hussein Obama.

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B. Declare that Defendant Barack Hussein Obama, a/k/a Barry Obama, a/k/a

]Barry Soetoro, a/k/a Barack Soetoro, a/k/a Barry Dunham, a/k/a Barack Dunham

is not a “natural born” or “naturalized” citizen of the United States;

C. Declare that Defendant Barack Hussein Obama, a/k/a Barry Obama, a/k/a

Barry Soetoro, a/k/a Barack Soetoro, a/k/a Barry Dunham, a/k/a Barack Dunham

ineligible to run for United States Office of the President under the United States

Constitution, Article II, Section I;

D. Preliminary and permanently enjoin Defendant Barack Hussein Obama,

a/k/a Barry Obama, a/k/a Barry Soetoro, a/k/a Barack Soetoro, a/k/a Barry

Dunham, a/k/a Barack Dunham from any further campaigning and from running

for United States Office of the President;

E. Preliminary and permanently enjoin Defendants, The Democratic National

Committee (DNC), the PA Department of State and Pedro A. Cortés, Secretary

of the Commonwealth, PA Department of State, Bureau of Commissions,

Elections and Legislation from placing Defendant Barack Hussein Obama, a/k/a

Barry Obama, a/k/a Barry Soetoro, a/k/a Barack Soetoro, a/k/a Barry Dunham,

a/k/a Barack Dunham’s name on the ballot for election of P r e s i d e n t o f t h e

United States;

F. Order the FEC, Feinstein and the U.S. Senate Commission on Rules and

Administration to immediately open and conduct an investigation into the

fraudulent tactics of Obama and immediately open and conduct an investigation

into the citizenship status of Obama;

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53

G. Waive the Governmental Claim requirement due to the urgency of this

matter;

H. Award Plaintiff such costs and fees pursuant to 42 U.S.C. § 1988 and

other applicable law; and

I. Grant Plaintiff such other and further relief as the Court deems just and

proper.

COUNT SIX

(Against all Defendants)

Violation of the Freedom of Information Act (FOIA)

5 U.S.C. § 552, et seq.

145. Plaintiff hereby incorporates Paragraphs 1 through 144 as if fully set forth herein.

146. Plaintiff attempted to secure documents proving the citizenship status of Obama from

Obama the FEC, DNC, Feinstein, U.S. Senate, Commission on Rules and

Administration, however has been refused.

147. In attempt to resolve the issues regarding Obama’s citizenship status, Plaintiff served

subpoenas on the U.S. Embassy, Jakarta Indonesia, U.S. Embassy, Nairobi, Kenya,

the U.S. State Department, the Federal Bureau of Information (FBI), the Central

Intelligence Agency (CIA), The Hawaii Department of Health, Kapi’olani Medical

Center for Women and Children, Queens Medical Center, and the U.S. Senate,

Commission on Rules and Administration. Unfortunately, to date, Plaintiff has been

refused all documents.

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148. Plaintiff has attempted to obtain the appropriate documents to prove Obama’s

citizenship status, or lack there of and has requested investigation into the eligibility

status of Obama. Defendants have completely ignored the complaints and requests.

149. Plaintiff has a right, which is secured to him by our laws and the United States

Constitution, for verification of our Presidential Nominee’s eligibility to serve as

President of the United States prior to the elections.

150. Plaintiff has suffered an informational injury as a voter and member of the public; the

lack of information on Mr. Obama’s citizenship, caused by the FEC, Feinstein, the

U.S. Senate, Commission on Rules and Administration’s actions, Obama, Cortés, PA

Secretary of the Commonwealth, PA Department of State, Bureau of Commissions,

Elections and Legislation limited the information available to Plaintiff as a voter and

impaired his ability to make proper decisions and ensure he is voting for a legally

eligible Presidential candidate.

151. If a party is denied information that will help it in making a voting decision that party

is obviously injured in fact.

 

FEC v. Akins, 524 U.S. 11 (1998).152. For the above aforementioned reasons, Defendants need to immediately supply a

certified copy of Obama’s “vault” (original long version) birth certificate; certified

copies of all reissued and sealed birth certificates for Obama; a certified copy of

Obama’s Certification of Citizenship; a Certified copy of Obama’s Oath of

Allegiance taken upon the age of Majority; and certified copies of Obama’s

Admission forms for Occidental College, Columbia University and Harvard law

School. If Defendants are unable to supply said documents, Obama needs to

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immediately step down and withdraw his candidacy for President of the United

States.

WHEREFORE

,  

Plaintiff, Philip J. Berg, Esquire, respectfully prays thatthis Court:

A. Order Defendants to immediately turn over the following documents:

1. A certified copy of Obama’s “vault” (original long version) birth

certificate;

2. Certified copies of all reissued and sealed birth certificates of

Obama in the names referred to in the caption of this lawsuit;

3. A certified copy of Obama’s Certification of Citizenship;

4. A certified copy of Obama’s Oath of Allegiance taken upon age of

majority;

5. Certified copies of Obama’s Admission forms for Occidental

College, Columbia University and Harvard Law School; and

6. Certified copies of any Court Orders or legal documents changing

Obama’s name from Barry Soetoro to Barack Hussein Obama.

B. Declare that Defendant Barack Hussein Obama, a/k/a Barry Obama, a/k/a

Barry Soetoro, a/k/a Barack Soetoro, a/k/a Barry Dunham, a/k/a Barack Dunham

is not a “natural born” or “naturalized” citizen of the United States;

C. Declare that Defendant Barack Hussein Obama, a/k/a Barry Obama, a/k/a

Barry Soetoro, a/k/a Barack Soetoro, a/k/a Barry Dunham, a/k/a Barack Dunham

ineligible to run for United States Office of the President under the United States

Constitution, Article II, Section I;

D. Preliminary and permanently enjoin Defendant Barack Hussein Obama,

a/k/a Barry Obama, a/k/a Barry Soetoro, a/k/a Barack Soetoro, a/k/a Barry

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56

Dunham, a/k/a Barack Dunham from any further campaigning and from running

for United States Office of the President;

E. Preliminary and permanently enjoin Defendants, The Democratic National

Committee (DNC), the PA Department of State and Pedro A. Cortés, Secretary of

the Commonwealth, PA Department of State, Bureau of Commissions, Elections

and Legislation from placing Defendant Barack Hussein Obama, a/k/a Barry

Obama, a/k/a Barry Soetoro, a/k/a Barack Soetoro, a/k/a Barry Dunham, a/k/a

Barack Dunham’s name on the ballot for election of President of the United

States;

F. Order the FEC, Feinstein and the U.S. Senate Commission on Rules and

Administration to immediately open and conduct an investigation into the

fraudulent tactics of Obama and immediately open and conduct an investigation

into the citizenship status of Obama;

G. Waive the Governmental Claim requirement due to the urgency of this

matter;

H. Award Plaintiff such costs and fees pursuant to 42 U.S.C. § 1988 and

other applicable law; and

I. Grant Plaintiff such other and further relief as the Court deems just and

proper.

COUNT SEVEN

(Against Defendants Obama and the DNC)

Promissory Estoppel

153. Plaintiff hereby incorporates Paragraphs 1 through 152 as if fully set forth herein.

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154. Plaintiff is a life long Democrat who had always been proud of his Party. Plaintiff is

a licensed attorney in good standing and has taken an oath to uphold the United States

Constitution. Plaintiff has donated money and billable hours to Democratic

Presidential candidates as well as to the Democratic National Committee. Plaintiff

has relied on the DNC’s promises to uphold our Constitution, which includes

properly vetting our Presidential Nominee and ensuring our Party’s Nominee is

eligible to serve as President of the United States pursuant to Article II, Section 1 of

our United States Constitution.

155. In addition, Plaintiff has trusted the Federal Election Committee (“FEC”) that they

would ensure our Presidential and Congress candidates were eligible for the positions

which they were seeking and running a fair and legitimate campaign process.

Plaintiff has relied on the FEC, DNC and all our Elected Office Holders to uphold our

Constitution and to ensure an illegal alien and/or a naturalized citizen would not be

able to secure the position of President of the United States.

156. In order to be eligible and qualified to run for the Office of the President of the

United States you must be a “natural born” citizen. United States Constitution,

Article II, Section I.

157. The DNC published on their website at

 

http://www.democrats.org their 2008Democratic National Platform ”

 

Renewing America’s Promise“. The DNC’s platformof promise contain many promises to the American people.

158. The DNC promises on page iii Section IV, Renewing American Democracy further

promising

 

Open, Accountable and Ethical government; Reclaiming ourZ:\Forms\Obama, First Amended Complaint 100608

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Constitution and our Liberties; and Voting Rights

.”  

The DNC has failed to upholdand follow through with their promises.

159. The DNC promises in their promotion of Obama, Page 53,

 

“In Barack Obama’sAdministration, we will open up the doors of democracy.

 

We will use technology tomake government more transparent, accountable, and inclusive.

 

Rather than obstructpeople’s use of the Freedom of Information Act, we will require that agencies

conduct significant business in public and release all relevant information unless an

agency reasonably foresees harm to a protected interest.”

160. The DNC has pledged and promised Plaintiff and all Democratic individuals they

believe that our Constitution, our courts, our institutions and our traditions are proper

and work.

161. The DNC pledged and promised Plaintiff and all Democratic individuals they will

ensure our Constitution is not a nuisance and have assured Plaintiff and democratic

individuals the United States Constitution is the foundation of our democracy. It

makes freedom and self-governance possible, and helps to protect our security. The

Democratic Party has pledged and promised Plaintiff and other Democratic

individuals they will maintain and restore our Constitution to its proper place in our

government and return our Nation to the best traditions, including their commitment

to government by law.

162. Unfortunately, the DNC has not upheld our Constitution and/or our Laws. The DNC

is promoting an illegal candidate who is ineligible to serve as the President of the

United States. The DNC has failed to investigate into Obama’s citizenship. Obama

is not a “natural born” U.S. citizen, he is still an Indonesian citizen and ineligible to

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serve as President of the United States, United States Constitution, Article II, Section

I.

163. The DNC has promised on page 56 ”

 

Voting rights are fundamental rights becausethey are protective of all other rights. We will work to fully protect and enforce the

fundamental Constitutional right of every American vote—to ensure that the

Constitution’s promise is fully realized

 

.” “Finally, we will enact legislation thatestablishes harsh penalties for those who engage in voter intimidation and creates a

process for providing accurate information to misinformed voters so they can cast

their votes in time.”

164. The DNC has promised on page 56 ”

 

Voting rights are fundamental rights becausethey are protective of all other rights. We will work to fully protect and enforce the

fundamental Constitutional right of every American vote—to ensure that the

Constitution’s promise is fully realized

 

.” “Finally, we will enact legislation thatestablishes harsh penalties for those who engage in voter intimidation and creates a

process for providing accurate information to misinformed voters so they can cast

their votes in time.”

165. The DNC has not protected Plaintiff or other Democratic voter’s rights, they have

failed to provide accurate information, they have not investigated Obama’s eligibility

and/or citizenship status and they have allowed Obama’s tactics in promoting racial

tension and threatening to have people arrested and prosecuted if they talk negatively

or debate against Obama.

166. Based on the DNC’s promises and assurances, Plaintiff and other democratic

individuals have donated money in good faith to the DNC and other Democratic

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Presidential Nominees. Money donated to the DNC is used to

 

plan the Party’squadrennial presidential nominating convention; promote the election of eligible

Party candidates, pursuant to the United States Constitution, Article II, Section I, with

both technical and financial support; and works with national, state and local party

organizations, elected officials, candidates and constituencies to respond to the needs

and views of the Democratic electorate and the nation.

167. Obama has promised to uphold the United States Constitution and to be open and

honest with all questions presented. However, Obama has not been open and honest;

he has refused to provide proof of his citizenship status and has refused to answer

questions pertaining to his citizenship status. Furthermore, Obama is not upholding

the Constitution as he is aware he is ineligible to serve as the Pressident of the United

States. Obama has further violated the U.S. Constitution by fraudulently collecting in

excess of $450 Million dollars.

168. Obama promises on his website to

 

End Deceptive Voting Practices. “Obama stateshe will sign into law his legislation that establishes harsh penalties for those who

have engaged in voter fraud and provide voters who have been misinformed with

accurate and full information so they can vote.”

 

Obama has made the promiseshowever, has been dishonest regarding his citizenship status

 

and has refused to provehis citizenship status so Plaintiff and other voter’s can be well educated into our

Presidential candidate.

169. Obama states on his webpage at

 

http://factcheck.barackobama.com I want tocampaign the same way I govern, which is to respond directly and forcefully w i t h

the truth

 

” ~ Barack Obama, 11/08/07. Unfortunately, this is not true, Obama has not

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been honest about his citizenship and he has refused to provide proof of his

citizenship status. Instead, Obama and his campaign placed an image on Obama’s

website purporting to be an original Certification of Live Birth (COLB) of Obama’s

from Hawaii. It was later determined the COLB on http://www.fightthesmears.com turned

out to be an altered and forged COLB.

170. The DNC and FEC bear the responsibility of vetting the Democratic Presidential

candidate, among other things, to ensure the eligibility requirements pursuant to our

Constitution are met and the Presidential nominee, if elected, is qualified and eligible

to serve pursuant to our United States Constitution. The DNC has promised the

people to uphold this obligation which is part of upholding the United States

Constitution.

171. To date, the DNC has never verified the eligibility of Obama, despite knowing

Obama was not an eligible candidate, as promised, and instead nominated Obama as

the Democratic Presidential Nominee. The DNC is well aware Obama cannot hold

the United States Office of the Presidency and therefore failed to follow through on

their promises.

172. Additionally, the DNC has not upheld the U.S. Constitution, their protections of

Plaintiff and/or the Democratic citizens of the United States, nor have they done the

job they have promised Plaintiff and other Democratic citizens.

173. As a result, there is significant disenfranchisement of the Democratic Party, which

has harmed Plaintiff. The disenfranchisement is a result of the DNC allowing a noncitizen;

in fact a citizen of Indonesia, to be the Democratic Nominee, knowing

Obama cannot serve as the President of the United States, if elected. The DNC has

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allowed Obama’s fraudulent campaigning to continue and Plaintiff has been

deprived money which he donated to support an eligible Democratic Nominee to run,

and if elected, to serve as the President of the United States.

174. Plaintiff has been deprived of money and billable hours by fraudulent means as a

result of donating money and billable hours to secure, as promised, an eligible

Democratic candidate for Office of the Presidency, in which to cast his vote. The

DNC named Obama as the Democratic Nominee, who is ineligible to serve as the

President of the United States as he is not a “natural born” citizen, a qualification and

eligibility requirement pursuant to Article II, Section I of the United States

Constitution. Moreover, Plaintiff has been deprived of his right to vote for an eligible

Democratic Nominee for the U.S. Office of the Presidency.

175. Plaintiff has been severely damaged as a result of Defendants actions. Plaintiff has

been deprived of liberty, property, due process of law and equal protections of the

laws all guaranteed under the United States Constitution.

176. As a result of Obama’s message to the People of America, Plaintiff has suffered

damage to his reputation and discrimination and fears for his safety as a result of

attempting to protect his rights and verify the eligibility of Obama to serve as

President of the United States. Plaintiff has been repeatedly called a racist and

verbally assaulted for bringing forward this lawsuit against Obama. Plaintiff is not a

racist and is a paid Life Member of the NAACP. Plaintiff has received numerous

nasty emails accusing him of being a racist as a result of filing this action against

Obama. Moreover, Plaintiff was verbally assaulted by a black female in public for

bringing suit against Obama questioning his citizenship status. All of which is in

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violation of Plaintiff’s right’s to due process of the law, equal protection of the laws

and the Liberty Clause secured by the Fourteenth Amendment of the U.S.

Constitution.

177. All elements required to invoke Promissory Estoppel have been met by Plaintiff. The

DNC and Obama made a promise to Plaintiff, which Plaintiff relied upon and

expected. Not only has Plaintiff suffered economic losses; he has lost his

constitutional right to vote for an eligible Democratic candidate who can serve as the

President of the United States, if elected.

178. The only way justice can be served is by the Court enforcing the promise of the DNC

and Obama.

179. For the above aforementioned reasons, Defendants need to immediately uphold their

promises, uphold the United States Constitution and immediately supply a certified

copy of Obama’s “vault” (original long version) birth certificate; certified copies of

all reissued and sealed birth certificates for Obama; a certified copy of Obama’s

Certification of Citizenship; a Certified copy of Obama’s Oath of Allegiance taken

upon the age of Majority; and certified copies of Obama’s Admission forms for

Occidental College, Columbia University and Harvard law School. If Defendants are

unable to supply said documents, Obama needs to immediately step down and

withdraw his candidacy for President of the United States.

WHEREFORE

,  

Plaintiff, Philip J. Berg, Esquire, respectfully prays thatthis Court:

A. Order Defendants to immediately turn over the following documents:

1. A certified copy of Obama’s “vault” (original long version) birth

certificate;

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64

2. Certified copies of all reissued and sealed birth certificates of

Obama in the names referred to in the caption of this lawsuit;

3. A certified copy of Obama’s Certification of Citizenship;

4. A certified copy of Obama’s Oath of Allegiance taken upon age of

majority;

5. Certified copies of Obama’s Admission forms for Occidental

College, Columbia University and Harvard Law School; and

6. Certified copies of any Court Orders or legal documents changing

Obama’s name from Barry Soetoro to Barack Hussein Obama.

B. Order Defendant Barack Hussein Obama, a/k/a Barry Obama, a/k/a Barry

Soetoro, a/k/a Barack Soetoro, a/k/a Barry Dunham, a/k/a Barack Dunham

removed from the Presidential Ballot until his citizenship status can in fact be

verified ensuring he is eligible to serve as the President of the United States;

C. Preliminary and permanently enjoin Defendant Barack Hussein Obama,

a/k/a Barry Obama, a/k/a Barry Soetoro, a/k/a Barack Soetoro, a/k/a Barry

Dunham, a/k/a Barack Dunham from any further campaigning and from running

for United States Office of the President until he is able to prove his citizenship

status and eligibility to hold the United States Office of the Presidency;

D. Preliminary and permanently enjoin Defendants, The Democratic National

Committee (DNC), from placing Defendant Barack Hussein Obama, a/k/a Barry

`Obama, a/k/a Barry Soetoro, a/k/a Barack Soetoro, a/k/a Barry Dunham, a/k/a

Barack Dunham’s name on the ballot for election of the President of the United

States until Obama’s citizenship status and eligibility to serve as the United States

Presidency have been verified;

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E. Award Plaintiff such costs and fees pursuant to 42 U.S.C. § 1988 and

other applicable law; and

F. Grant Plaintiff such other and further relief as the Court deems just and

proper.

COUNT EIGHT

(Against Defendant Obama)

Loss of nationality by native-born or naturalized citizen

8 U.S.C. § 1481(b)

180. Plaintiff hereby incorporates Paragraphs 1 through 179 as if fully set forth herein.

181. Obama was born in Mombosa, Kenya in or about August 4, 1961. At the time of his

birth, Obama’s father was a citizen of Kenya and his mother was a U.S. citizen,

eighteen (18) years of age. The Nationality Act of 1940, revised June 1952 required

the citizen parent of a child born abroad must reside in the United States for ten (10)

years, five (5) of which were after the age of fourteen (14) in order to register the

child born abroad as a United States “natural born” citizen. Obama’s mother was not

old enough to pass on U.S. “natural born” citizenship to Obama and therefore could

only register his birth as “naturalized”.

182. Even if Obama would have been able to be registered as a U.S. “natural born” citizen

in Hawaii, which was not available, he lost his citizenship in the United States when

his mother married Lolo Soetoro, a citizen of Indonesia, and became a naturalized

citizen in Indonesia and set up residency in Indonesia with her new husband.

Minor’s follow their custodial parent’s citizenship status.

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183. Moreover, Obama’s Indonesian step father, Lolo Soetoro, signed a Government

acknowledgement form acknowledging Obama as his son and/or legally adopted

Obama, either of which changed Obama’s citizenship status to a “natural” citizen of

Indonesia. Thus, Obama could have only obtained Naturalized citizenship status in

the United States, if in fact he and/or his family filed the proper immigration

paperwork.

184. Under Indonesian law, when a male acknowledges a child as his son, it deems the

son, in this case Obama, as an Indonesian State citizen. Constitution of Republic of

Indonesia, Law No. 62 of 1958 Law No. 12 of 2006 dated 1 Aug. 2006 concerning

Citizenship of Republic of Indonesia, Law No. 9 of 1992 dated 31 Mar. 1992

concerning Immigration Affairs and Indonesian Civil Code (Kitab Undang-undang

Hukum Perdata) (KUHPer) (Burgerlijk Wetboek voor Indonesie) states in pertinent

part,

 

State citizens of Indonesia include: (viii) children who are born outside of legalmarriage from foreign State citizen mother who are acknowledged by father who is

Indonesian State citizen as his children and that acknowledgment is made prior to

children reaching 18 years of age or prior to marriage;

 

Republic of IndonesiaConstitution 1945,

 

As amended by the First Amendment of 1999, the SecondAmendment of 2000, the Third Amendment of 2001 and the Fourth Amendment of

2002,

 

Chapter X, Citizens and Residents, Article 26 states, “(1) Citizens shall consistof indigenous Indonesian peoples and persons of foreign origin who have been

legalized [sic] as citizens in accordance with law. (2) Residents shall consist of

Indonesian citizens and foreign nationals living in Indonesia

 

.”

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185. Furthermore, under the Indonesian adoption law, once adopted by an Indonesian

citizen, the adoption severs the child’s relationship to the birth parents,

 

and theadopted child is given the same status as a natural child, Indonesian Constitution,

Article 2.

186. The Indonesian citizenship law was designed to prevent apatride (stateless) or

bipatride (dual citizenship). Indonesian regulations recognize neither apatride nor

bipatride citizenship. Obama’s mother was required to renounce her U.S. citizenship

and was sponsored by her Indonesian spouse. Minor children followed their

custodial parent’s citizenship status.

187. Obama was enrolled by his parents in a public school, Fransiskus Assisi School, a

public school, in Jakarta, Indonesia. Plaintiff has received copies of the school

registration in which it clearly states Obama’s name as “Barry Soetoro,” and lists his

citizenship as Indonesian, his citizenship number as 203. Obama’s father is listed as

Lolo Soetoro, Obama’s date of birth and place of birth are listed as August 4, 1961 in

Hawaii, and Obama’s Religion is listed as Islam. This document was verified by

television show

 

Inside Edition, whose reporter, Matt Meagher, took the actual footageof the school record. At the time Obama was registered, the public schools obtained

and verified the citizenship status and name of the student through the Indonesian

Government. All Indonesian students were required to carry government identity

cards, or

 

Karty Tanda Pendudaks, as well as family card identification called a KartuKeluarga

. The Kartu Keluarga is a family card which bears the legal names of allfamily members.

 

Indonesia did not allow foreign students to attend their schools andIndonesia Immigration Officials and the Police frequently visited the schools to

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ensure the students attending were all Indonesian citizens pursuant to the laws. At

the time Obama attended school in Jakarta Indonesia, Indonesia did not allow foreign

students to attend their public schools.

188. Plaintiff is informed, believes and thereon alleges Obama stated his citizenship as

Kenyan on his College Admission forms to Occidental College, Columbia University

and Harvard Law School.

189. Furthermore, Obama traveled to Indonesia, Pakistan and Southern India in 1981. The

relations between Pakistan and India were extremely tense and Pakistan was in

turmoil and under martial law. The country was filled with Afghan refugees; and

Pakistan’s Islamist-leaning Interservices Intelligence Agency (ISI) had begun to

provide arms to the Afghan mujahideen and to assist the process of recruiting

radicalized Muslim men–jihadists–from around the world to fight against the Soviet

Union. Pakistan was so dangerous that it was on the State Department’s travel ban

list for US Citizens. Non-Muslim visitors were not welcome unless sponsored by

their embassy for official business. A Muslim citizen of Indonesia traveling on an

Indonesian passport would have success entering Indonesia, Pakistan and India.

Therefore, it is believed Obama traveled on his Indonesian passport entering the

Countries. Indonesian passports require renewal every five (5) years. At the time of

Obama’s travels to Indonesia, Pakistan and India, Obama was twenty (20) years old.

If Obama would have been a U.S. citizen, which he was not, 8 USC §1481(a)(2)

provides loss of nationality by native born citizens upon “taking an oath or making an

affirmation or other formal declaration of allegiance to a foreign state…after having

attained the age of eighteen years”, in violation of 8 U.S.C. §1401(a)(1).

Z:\Forms\Obama, First Amended Complaint 100608

69

190. If in fact Obama ever had citizenship, he lost his citizenship by becoming a “natural”

citizen of Indonesia. Obama could have gained United States “naturalized”

citizenship status, however, he and/or his family would have been required to file the

appropriate Immigration paperwork and obtain a Certification of Citizenship, which

Obama and his family failed to do.

191. For the reason’s stated herein Obama is still a citizen of Indonesia and is not a

United States “natural born” citizen, he is not a “naturalized” citizen of the United

States and is here in the United States as an “illegal alien”.

WHEREFORE

,  

Plaintiff, Philip J. Berg, Esquire, respectfully prays thatthis Court:

A. Order Defendant to prove his citizenship status and immediately turn over

the following documents:

1. A certified copy of Obama’s “vault” (original long version) birth

certificate;

2. Certified copies of all reissued and sealed birth certificates of

Obama in the names referred to in the caption of this lawsuit;

3. A certified copy of Obama’s Certification of Citizenship;

4. A certified copy of Obama’s Oath of Allegiance taken upon age of

majority;

5. Certified copies of Obama’s Admission forms for Occidental

College, Columbia University and Harvard Law School; and

6. Certified copies of any Court Orders or legal documents changing

Obama’s name from Barry Soetoro to Barack Hussein Obama.

B. Issue a Declaratory Judgment against Defendant Barack Hussein Obama,

a/k/a Barry Obama, a/k/a Barry Soetoro, a/k/a Barack Soetoro, a/k/a Barry

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70

Dunham, a/k/a Barack Dunham declaring he is not a U.S. “natural born” citizen,

he is not a “naturalized” citizen and he is still an Indonesian citizen.

C. Order Defendant Barack Hussein Obama, a/k/a Barry Obama, a/k/a Barry

Soetoro, a/k/a Barack Soetoro, a/k/a Barry Dunham, a/k/a Barack Dunham

removed from the Presidential Ballot until his citizenship status can in fact be

verified ensuring he is eligible to serve as the President of the United States;

D. Preliminary and permanently enjoin Defendant Barack Hussein Obama,

a/k/a Barry Obama, a/k/a Barry Soetoro, a/k/a Barack Soetoro, a/k/a Barry

Dunham, a/k/a Barack Dunham from any further campaigning and from running

for the United States Office of the President until he is able to prove his

citizenship status and eligibility to hold the United States Office of the

Presidency;

E. Award Plaintiff such costs and fees pursuant to 42 U.S.C. § 1988 and

other applicable law; and

F. Grant Plaintiff such other and further relief as the Court deems just and

proper.

Respectfully submitted,

s/ Philip J. Berg

Dated: October 6, 2008 _______________________

Philip J. Berg, Esquire

Attorney in

 

Pro Se555 Andorra Glen Court, Suite 12

Lafayette Hill, PA 19444-2531

Identification No. 09867

(610) 825-3134

,

 

,

.”

, , , , ,

,

Philip J Berg lawsuit, Update, October 6, 2008, Jeff Schreiber, Berg Files Motion for Leave to File an Amended Complaint, Obama is ineligible, Pedro Cortes added, Secretary of the Commonwealth, Pennsylvania

Jeff Schreiber has provided an update in the Philip J Berg lawsuit. Mr.
Berg has filed a Motion for Leave to File an Amended Complaint. Here are
some exerpts from Jeff Schreiber’s explanation:

“This morning, prominent Philadelphia attorney and former Deputy Attorney General for the Commonwealth of Pennsylvania Philip Berg filed a Motion for Leave to File an Amended Complaint in his ongoing case against Illinois Sen. Barack Obama and others, arguing that Obama is in fact not a natural born United States citizen and, pursuant to Article II, Section 1 of the U.S. Constitution is ineligible to serve as president of the United States of America.

Now, this does not mean that the amended complaint has been filed. You cannot file an amended complaint, which is why Berg filed a Motion for Leave to File.”
“In the amended complaint which Berg is seeking to file in the wake of a motion to dismiss filed on September 24 by Obama and the Democratic National Committee and his own Opposition and Brief filed last week, Berg added a few claims and a few defendants, as well as rehashed the original allegations made more than a month ago in the initial complaint.

As expected, Berg added Pedro Cortes, Secretary of the Commonwealth for the Commonwealth of Pennsylvania, given Cortes’ role in fomenting and overseeing the electoral process in the Keystone State. He has also added, however, California Sen. Diane Feinstein in her role as Chairwoman of the U.S. Senate Commission on Rules and Administration, and the U.S. Senate Commission on Rules and Administration itself. The latter, according to the amended complaint, is “responsible for investigations into the qualifications of the President and Vice President candidates Federal elections” while the former “has primary authority” for oversight with regard to aspects related to ethics, campaign and election reform.

Berg is seeking, among other things, an order that Feinstein and the Rules Commission–along with the FEC–immediately conduct an investigation into “the fraudulent tactics of Obama” and into his citizenship status as well.”

“He also added a paragraph further addressing and supporting the court’s jurisdiction over the matter at hand, questioned in the motion to dismiss filed by Obama and the DNC.”

“They are responsible for verifying the credentials and qualifications of Members of the Senate, contested elections and acceptance of incompatible offices. Moreover, in addition to the verification of a candidates qualifications, eligibility and credentials, they are responsible for Federal elections generally, including the election of the President, Vice President and Members of the Congress.”

“There is absolutely no other way for Plaintiff to ensure his constitutionally protected rights. The only option Plaintiff had was to bring this action. This is the first time in American History a “naturalized” citizen and/or illegal alien have been allowed to campaign for the Office of President of the United States. There are not any other ways to establish or determine the legal status of our Presidential Candidates, whether Republican and/or Democratic. The FEC and DNC have refused to verify and furnish Plaintiff with Obama’s eligibility or lack thereof. Plaintiff has standing to challenge any person(s) citizenship and/or nationality status pursuant to statute, 8 U.S. C. §1481(b).”

“Berg states that, even if Obama was indeed born in Hawaii to a mother who was a U.S. citizen, the situation in Indonesia, where Obama went to school and may have been formally adopted by his stepfather, it doesn’t matter. As I mentioned in Is This For Real, and Why Hasn’t the Mainstream Media Covered it Yet?, the Indonesian government only began acknowledging dual citizenship in November of 2006; in his amended complaint, Berg cites The Hague Convention of 1930 and argues that since Indonesia did not allow dual citizenship, neither did the United States when it came to Indonesia.”

Read the rest of this important article here:

http://www.americasright.com/

Help Philip J Berg expose the truth about Obama:

http://obamacrimes.com

Nashville TN, Larry Sinclair, Barack Obama, Town Hall Meeting, John McCain, Sinclair Obama drug encounter, Donald Young, October 6, October 7, 2008

I just spoke to Larry Sinclair a few minutes ago on Sunday, October 5, 2008. Larry is traveling to Nashville TN and will be there Monday, October 6 and Tuesday, October 7, 2008. Larry Sinclair will be in Nashville for the Town Hall Meeting with Barack Obama and John McCain and to tell his story of a drug and sex encounter with Obama in Chicago in November 1999. Sinclair will also share his knowledge of phone conversations with Donald Young, the gay choir director at TUCC, Obama’s former church, that was murdered in December 2007. Sinclair will also educate the public about the Philip J Berg  lawsuit that states Obama is a citizen of Indonesia.

Ever since Larry Sinclair went public with his allegations he has received non stop personal attacks and even death threats from the Obama camp. He is getting them already as preemptive strikes from the Obama camp before his visit to Nashville. I just read an ad on Craigslist in Nashville that is full of lies about Sinclair. I have covered the Larry Sinclair story more than any other source and can provide the truth about Larry Sinclair and his allegations.

Here is a brief statement I have sent to members of the media:

Larry Sinclair will arrive in Nashville on Monday for the Town Hall Meeting. I have covered Sinclair more than any other source and can separate fact from fiction.
I also helped break the Philip J Berg lawsuit and continue to report on this monumental story.
Both of these stories, in addition to continued fallout from the Tony Rezko trial, have barely been touched by the MSM.
Larry Sinclair is on a Take it to the Streets Tour and his story is not going away.
If you would like to interview Larry Sinclair, Philip J Berg
or me, let me know.
Citizen Wells

https://citizenwells.wordpress.com
http://larrysinclair-0926.blogspot.com
http://obamacrimes.com

The Citizen Wells blog is a good place to start to learn about the Larry Sinclair story as well as many other dubious aspects of Obama and his past. Another example of the Obama camp attacking people for asking questions about their messiah is the actor Jon Voight. He and his family were viciously attacked several months ago for questioning Obama.