TAITZ v OBAMA (QW) - 30 - SUPPLEMENTAL MEMORANDUM - gov.uscourts.dcd.140567.30.0

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  • 8/9/2019 TAITZ v OBAMA (QW) - 30 - SUPPLEMENTAL MEMORANDUM - gov.uscourts.dcd.140567.30.0

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    Case 1:10-cv-00151-RCL Document 30 Filed OS/24/10 Page 1 of 7

    Dr. Orly Taitz, esq29839 Santa Margarita Parkway, STE 100Rancho Santa Margarita CA 92688Tel: (949) 683-5411; Fax (949) 766-7603E-Mail: [email protected]

    UNITED STATES DISTRICT COURTFOR THE DISTRICT OF COLUMBIADr. ORLY T AITZ, ESQ, PRO SEPlaintiff,

    v.Barack Hussein Obama,

    Defendant.

    Your Honor,

    HONORABLE ROYCE LAMBERTH PRESIDING Civil Action: 10-151 RCL ADDENDUM TO REPLY TO OPPOSITION TO MOTION FOR RECONSIDERATION

    Part of the complaint in this action is a FOIA request. Mr. Obama, defendant inthis case, via US attorney's office sought dismissal of a FOIA request due to the factthat the refusal of information request by the Social Security administration was notfinal. Your Honor initially agreed, stating that the response from the Social Securityadministration was not final. Until now Taitz could not obtain a response from SSN,stating that it is a final decision.

    Yesterday Taitz received a letter from Jonathan R. Cantor, Executive Director ofOffice of Privacy and Disclosure of the Social Security Administration dated andsigned May 18, 2010. (Exhibit 1 Letter and envelope) As a stroke of providence theletter states "This is our final decision in this matter. If you still believe the decisionis incorrect, however, the law permits you to seek review in a district court of theUnited States".

    Taitz v Obama. Addendum to Reply to Motion for reconsideration1

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    3 As such an impediment was lifted, and the Plaintiff respectfully requests this4 Honorable court to grant her motion for reconsideration, so that the matter can be5 heard on the merits.6 Legal Argument7 In regards to the content of the response from the Social Security Administration,8 it relies on the finding of Department of Justice v. Reporters Committee for Freedom9 ofthe Press, 489 U.S. 749 (1989).10 It concedes following points:11 1. Under 5U.S.C. 552(b)(6) exemption from the FOIA Taitz can obtain12 Obama's application for the Social Security without Obama's consent, if other19 conditions are fulfilled.20 2. Social security or court cannot consider the identity of the requester- therefore21 the court cannot deny Taitz request due to her lack of standing or lack of22 particularized injury23 3. Social Security or courts cannot consider the purpose for which the person24 requests the information.25 4. Social security administration is obligated to provide information, ifthere is a26 public interest in knowing how SSA administers the Social Security Act.27 5. The only objection to Taitz request by the SSA, is their claim that "disclosure28 of records containing personal information about President Obama would not

    shed light on how the agency performs its statutory duties". This is the reasonSSA provides as justification for their refusal to provide the information inquestion.

    6. Taitz appeals this decision on following grounds:a. Official on line records of Selective service confirm that Barack Obama has

    been using SS number _ 4425.Taitz v Obama. Addendum to Reply to Motion for reconsideration

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    Case 1:10-cv-00151-RCL Document 30 Filed OS/24/10 Page 3 of 7

    3 b. Information requested does not represent personal information of Mr.4 Obama, but rather personal information of another individual born in5 1890, who would have been 120 years old, who is most probably deceased,6 but whose death was either never reported to the Social Security7 Administration or was deleted from the records of the Social Security8 Administration prior or around 1986, and the number was unlawfully9 assumed by Mr. Obama. According to previously submitted sworn affidavit10 of recently retired senior deportation officer with the department ofHomeland11 Security Mr. John Sampson, this Social Security number was issued to another12 individual in the state of Connecticut between 1976-1977, while Obama never19 resided there.20 c. One of the printouts provided by Mr. Sampson show Mr. Obama's origin in21 Equatorial Guiney, which is different from the official information stating his22 origin to be Hawaii and Kenya.23 d. According to previously submitted sworn affidavit from Susan Daniels,24 licensed private investigator, certified by the Department ofHomeland25 Security, this Social Security number was issued in the state ofConnecticut26 between 1976-1977, to an individual born in 1890. As Mr. Obama never27 resided in CT and was not born in 1890, Ms. Daniels concludes that this is not28 his SS number. Ms. Daniels provided a follow up report, showing that

    according to multiple national databases there are numerous Social Securitynumbers connected to name Barack Obama and Michelle Obama, none ofwhich were issued in Hawaii.

    e. According to memoirs by Mr. Obama, such as Dreams From My Father Mr.Obama started working in Baskin Robbins store in Honolulu HI around 1975-

    Taitz v Obama. Addendum to Reply to Motion for reconsideration3

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    3 1976, he needed SS number to obtain employment, and he would have had to4 obtain a SS number from HI, not CT.5 f. According to a previously submitted sworn Affidavit by retired elite Scotland6 Yard officer of anti organized crime and anti communist proliferation units7 Mr. Neil Sankey, there are multiple records in National databases, showing8 Obama using multiple Social Security numbers, which are either numbers of9 deceased individuals or numbers never assigned, none of which were issued in10 HI.11 g. According to the sworn declaration by forensic export Sandra Ramsey-Lines,12 Obama's short version certification of live birth provided to the public cannot19 be considered as genuine without forensic examination of the original birth20 certificate, which Obama refuses to unseal. Lack ofvalid original birth21 certificate with the name of the doctor and the name ofthe hospital and22 signatures, could attest to the foreign birth and could explain the need to seek23 SS numbers of deceased individuals and numbers never assigned.24 h. Madeleine Payne Dunham, Obama's maternal grandmother, used to volunteer25 in Oahu circuit court probate department, where she was able to obtain SS26 numbers of deceased in individuals. Additionally, both Ms. Payne and27 Obama's mother Ann Dunham(Obama, Soetoro) worked as loan officers and28 had an opportunity to view SS numbers of others.

    1. As the public has a right to know how SSA performs its statutory duties, thepublic has a right to know how Obama obtained these SS numbers, and see theoriginal application for SS number . " "T " "T "J , as well as other numbersused by Obama according to National databases.

    J. Without such disclosure the public will have no trust and confidence that SSAproperly performs its statutory duties, specifically in light of the fact that an

    Taitz v Obama. Addendum to Reply to Motion for reconsideration4

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    3 individual occupying the highest office in the land, could get there using4 Social Security numbers of others.5 k. Public has a right to know, what happens to estates of individuals, who are6 deceased, and whose death was never reported.7 1. The public has a right to know ifthis breach of SSA is limited to Obama, or8 whether it is widespread.9 m. Taitz would venture to submit to the court, that there was never a more10 justified need for a disclosure, as there is in this case, with a SSN wrongfully11 assumed and used by a President and Commander in Chief.12 n. Taitz will be willing to consent to have initial discovery under seal and in19 camera.20 o. Taitz is request ing discovery to be done expeditiously, as she is continuously21 subjected to death threats Exhibit 2, which would not stop, as long as this mystery22 exists and there is an incentive for some to intimidate attorneys seeking answers.23 Taitz has a family and three children, which makes this matter more urgent.2425 Wherefore, Taitz respectfully requests this Honorable court to grant her motion26 for reconsideration.2728

    /s / DR ORLY TAlTZ ESQBy:_____________Dr. Orly Taitz, Esq. (California Bar 223433)

    Attorney for the Plaintiffs29839 Santa Margarita Parkway ste 100Rancho Santa Margarita CA 92688Tel.: 949-683-5411; Fax: 949-766-7603

    Taitz v Obama. Addendum to Reply to Motion for reconsideration5

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    Case 1:10-cv-00151-RCL Document 30 Filed OS/24/10 Page 6 of 7

    E-Mail: [email protected]

    PROOF OF SERVICE

    26 I CERTIFY THAT TRUE AND CORRECT COPY OF THE ABOVE27 PLEADINGS WERE SERVED on 05.24.10. on28 Alan Burch, Assistant United States Attorney for the District of Columbia

    th5554 str.,N.W.Washington D.C. 20530 VIA ELECTRONIC FILING/s/Orly TaitzDr. Orly Taitz Esq29839 Santa Margarita PKWYRancho Santa Margarita CA 92688

    Taitz v Obama. Addendum to Reply to Motion for reconsideration6

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    Case 1:10-cv-00151-RCL Document 30 Filed OS/24/10 Page 7 of 7

    Taitz v Obama. Addendum to Reply to Motion for reconsideration7